On October 4, 2018, the Member attended before a panel of the Inquiries, Complaints and Reports Committee (the Panel) to be cautioned.
At the outset of the Caution, the Panel established that the Member, without having any direct contact with a patient, requisitioned tests and adjusted the baseline therapeutic compound formula for the patient using her authority as a naturopathic doctor under the guise of being a salaried employee at a company hiring unregulated staff to provide direct patient services.
The Member was cautioned that in Ontario, lab tests need to be requisitioned by members of regulated Colleges who have the authority to requisition the testing under the Laboratory and Specimen Collection Centre Licensing Act, 1990 (LSCCA). The fact that she allowed her authority as a naturopathic doctor to be used in the requisitioning of tests for a patient whom she has never met, and may never have had the intention of meeting, was of grave concern to the Panel. The Member was reminded that if a naturopath is requisitioning a test, he/she reasonably owes a duty of care to the patient.
The Panel also noted that allowing a company to requisition and send out lab requisitions to patients using the Member’s authority, and via the Member’s direct contract with the lab, may also be perceived as a conflict of interest, as this arrangement may have reasonably influenced the Member’s ability to objectively carry out her duties and responsibilities as a health care professional.
In addition to the above, the Panel expressed their concern that the Member was essentially involved in prescribing Vitamin A, Vitamin D, and folic acid prior to having met the Standard for Prescribing, including the successful completion of a course and an examination on prescribing administered or approved by the College.
In conclusion, the Member was warned that should there be a similar complaint before the ICRC in the future, the ICRC will likely take stronger action, including the possibility of a Referral to the Discipline Committee.