What NDs can Prescribe

Under the Naturopathy Act, 2007, Registrants are authorised to perform the controlled act of “prescribing, dispensing, compounding or selling a drug designated in the regulations.”

The designated drugs are listed in Table 3 of the General Regulation below. Registrants may only prescribe the allowed drugs in accordance with any limitations outlined in the table.

When prescribing a drug, the general requirements for performing a controlled act outlined on the Controlled Acts page do not apply. Instead, the Regulation establishes the following requirements that Registrants must meet to prescribe a drug:

  • The Registrant can only prescribe a drug to a patient.
  • The drug can only be prescribed for therapeutic purposes.
  • The Registrant must have sufficient knowledge skill and judgment about the drug and the patient’s condition to prescribe the drug.
  • The Registrant must determine that the patient’s condition warrants the prescribed drug, having considered the risks and benefits of prescribing the drug and other circumstances relevant to the patient.
  • The Registrant must notify the patient’s other primary health care providers that they have prescribed the drug for the patient and provide the details of the prescription within a reasonable amount of time, unless the patient does not consent to the disclosure.
  • Where a limitation, route of administration or dosage is indicated in Table 3, the Registrant can only prescribe the drug in accordance with those conditions.

What is on a prescription?

Part II (Controlled Acts) of the General Regulation requires that a prescription contains the following:

  • the name and address of the patient for whom the drug is prescribed;
  • the name, strength (where applicable) and quantity of the prescribed drug;
  • directions for use of the drug, including dose, frequency, route of administration and any special instructions;
  • the name, signature, address, telephone number and College registration number of the Registrant issuing the instruction;
  • the date the prescription was issued;
  • the number of refills that the Registrant has authorised; and
  • any other information required by law.

Registrants must maintain a patient record for individuals prescribed a drug that includes:

  • details of the reason for prescribing the drug;
  • a copy of the prescription given to the patient;
  • a record of the results of any laboratory or other tests that the Registrant considered in deciding to prescribe the drug; and
  • the names and addresses of the patient’s other health care providers who were notified, and how the notification was given.

Additional education and training

A Registrant may only prescribe a drug to a patient if they have met the Standard of Practice for Prescribing, which requires that they successfully complete a College approved course and examination in Therapeutic Prescribing. The College’s Naturopathic Doctor Register includes information about whether a Registrant has met this standard of practice.

When is a prescription not required?

A prescription is not required when a Registrant is recommending that a patient take a natural health product (but note below that certain natural health products have been identified as drugs). Such natural health products include the following:

  • a plant or plant material, an alga, a bacterium, a fungus or a non-human animal material;
  • any extract or isolate of the above substances, or a synthetic duplicate;
  • any of these vitamins, or a synthetic duplicate: biotin, folate (dosage dependent), niacin, pantothenic acid, riboflavin, thiamine, A (dosage dependent), B6, B12, C, D (dosage dependent), E, K1 (dosage dependent), and K2 (dosage dependent);
  • an amino acid, or a synthetic duplicate;
  • an essential fatty acid, or a synthetic duplicate;
  • a mineral; or
  • a probiotic.

Some natural health products have been identified as drugs, either entirely or based on certain dosages. A Registrant is expected to know when a substance is a drug by using the Prescription Drug List, made under the Food and Drugs Act (Canada) or National Association of Pharmacy Regulatory Authorities (NAPRA) Schedule 1.

What can be prescribed?

Substances on the Health Canada Prescription Drug List and the NAPRA Schedule 1 require a prescription. Of those substances, only the drugs listed on Table 3 of the General Regulation may be prescribed by a Registrant who has met the standard of practice for prescribing in accordance with the Standard of Practice for Prescribing.

  • Table 3

    Below you will find the information in Table 3 of the General Regulation. Every precaution has been made to provide an accurate reproduction, but in the case of a discrepancy, please defer to the actual regulation. The notes describe how limitations on the drug should be applied. These notes are for information purposes and do not constitute advice from the College.

     

     Drug

     Limitations, routes of administration, dosages

     Explanatory note

    Adenosine triphosphate Only if prescribed for intravenous injection to be administered by the Registrant in his or her office to the patient. This is only a drug when it is prescribed for intravenous injection. It appears on this list to allow Registrants to access the drug from pharmacies. A Registrant might also write a prescription to allow a patient to pick up the drug at a pharmacy and bring it to an appointment for injection.
    Calcium Chloride Only if prescribed in injectable form for intravenous injection to be administered by the Registrant to the patient. This is only a drug when it is prescribed for intravenous injection. It appears on this list to allow Registrants to access the drug from pharmacies. A Registrant might also write a prescription to allow a patient to pick up the drug at a pharmacy and bring it to an appointment for injection.
    Calcium Gluconate Only if prescribed in injectable form for intravenous injection to be administered by the Registrant to the patient. This is only a drug when it is prescribed for intravenous injection. It appears on this list to allow Registrants to access the drug from pharmacies. A Registrant might also write a prescription to allow a patient to pick up the drug at a pharmacy and bring it to an appointment for injection.
    Colchicine Must not be prescribed unless the drug is botanical colchicine, compounded from the corm of colchicum autumnale. This limitation requires that only the botanical version of colchicine that is compounded from the corm of colchicum autumnale is prescribed.
    Dextrose Injection May only be prescribed when in concentrated solutions for intravenous injection to be administered by the Registrant to the patient. This drug may only be prescribed in concentrated solutions for intravenous injection. It appears on this list to allow Registrants to access the drug from pharmacists. A Registrant might also write a prescription to allow a patient to pick up the drug at a pharmacy and bring it to an appointment for injection.
    Digitalis Purpurea and its glycosides Only if prescribed in conjunction with monitoring of patient’s serum levels by Registrant. This drug always requires a prescription. In addition, a Registrant must monitor the patient’s blood serum levels when prescribing this drug.
    Estrogen (bioidentical) Only if prescribed in topical or suppository form. This always requires a prescription and may only be prescribed in a topical or suppository form.
    Folic Acid Only if prescribed in oral dosage containing more than 1.0 mg of folic acid per dosage or, where the largest recommended daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 1.0 mg of folic acid. This is only a drug when prescribed in a dosage of more than 1 mg per dose or more than 1 mg of daily dose. A Registrant may prescribe at this level or higher where indicated. Folic acid below 1 mg per dose or per daily dose is not a drug and does not require a prescription.
    L-Tryptophan Only if prescribed for patient’s use in oral dosage form at a concentration of more than 220 mg per dosage unit or per daily dose. Recommended daily dose must not exceed 12 g and must be provided. May be prescribed as a single ingredient intended for intravenous injection. This is only a drug when it is prescribed in oral dosage at a concentration of more than 220 mg per dosage unit or per daily dose. The daily dose must not exceed 12 g. The drug may be prescribed as a single ingredient for IV therapy.
    Levocarnitine and its Salts Only if prescribed for the treatment of primary or secondary levocarnitine deficiency. This is only a drug when prescribed for the treatment of primary or secondary levocarnitine deficiency in which case a prescription is required. If recommended for any other condition, it is not a drug and a prescription is not required.
    Nitroglycerin Administered to a patient by the Registrant in his or her office only in emergency circumstances and only for angina pectoris. Dosage: 1 to 2 metered doses (0.4 or 0.8 mg nitroglycerin) administered on or under the tongue, without inhaling. The mouth must be closed immediately after each dose (up to 3 doses in total, at least 5 minutes apart). A sublingual tablet may be used (0.3 or 0.6 mg for initial dose). Maximum dose of 1.8 mg. This drug appears on this list only to ensure that a Registrant can obtain it from a pharmacy for in office use. It may be administered by the Registrant only in office, only in emergency circumstances and only for angina pectoris following the explicit dosing requirements.
    Pancreatin Only if prescribed in a dosage form that provides more than 20,000 USP units of lipase activity per dosage unit or for the treatment of pancreatic exocrine insufficiency. This drug requires a prescription only when it is in a form that provides more than 20,000 USP of lipase activity per dosage or at any dosage amount when prescribed for the treatment of pancreatic exocrine insufficiency. Lower dosages for other conditions do not require a prescription.
    Pancrelipase Only if prescribed in a dosage form that provides more than 20,000 USP units of lipase activity per dosage unit or for the treatment of pancreatic exocrine insufficiency. This drug requires a prescription only when it is prescribed at more than 20,000 USP of lipase per dose or when it is being prescribed for treatment of pancreatic exocrine insufficiency. Lower dosages for other conditions do not require a prescription.
    Pilocarpine and its salts Must not be prescribed unless, 1. the drug is botanical pilocarpus, compounded from the leaves of pilocarpus microphyllus, 2. the Registrant monitors his or her patient’s drug levels during treatment with the drug and, 3. the drug is never prescribed to treat a patient with glaucoma. This drug may only be prescribed in its botanical form as identified and requires that the Registrant monitors the patient’s levels during treatment. The drug cannot be prescribed to treat a patient with glaucoma.
    Podophyllotoxin Must not be prescribed unless, 1. the drug is botanical podophyllotoxin compounded from podophyllum peltatum and, 2. the drug is never prescribed to treat a patient with rheumatoid arthritis. This drug may only be prescribed in its botanical form as identified and cannot be prescribed to a patient with rheumatoid arthritis.
    Progesterone (bioidentical form) Only if prescribed in a topical or suppository form. Progesterone requires a prescription and may only be prescribed in topical or suppository form.
    Rauwolfia No limitation, etc., specified.
    Thyroid No limitation, etc., specified. There are no limitations regarding dosages. Thyroid is listed as it appears on the Prescription Drug List and only refers to desiccated thyroid.
    Vitamin A Only if prescribed in oral dosage form containing more than 10,000 International Units of Vitamin A per dosage or, where the largest daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 10,000 International Units of Vitamin A. Vitamin A requires a prescription only when it is prescribed for oral use at more than 10,000 IU per dose or where the largest daily does would be more than 10,000 IU. At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration.
    Vitamin D Only if prescribed in oral dosage containing more than 1,000 International Units of Vitamin D per dosage or, where the largest daily dosage would, if consumed by a patient, result in the daily intake by that patient of more than 1,000 International Units of Vitamin D. Vitamin D requires a prescription only when it is prescribed for oral use at more than 1,000 IU per dose or where the largest daily does would be more than 1,000 IU. At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration.
    Vitamin K1 Only if prescribed in oral dosage when the maximum daily dose is more than 0.120 mg. Vitamin K1 requires a prescription only when it is prescribed for oral use at more that 0.120 mg per day. At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration.
    Vitamin K2 Only if prescribed in oral dosage when the maximum daily dose is more than 0.120 mg. Vitamin K2 requires a prescription only when it is prescribed for oral use at more that 0.120 mg per day. At lower levels, it does not require a prescription nor is a prescription necessary for other routes of administration.
    Yohimbine and its salts Must not be prescribed unless the drug is botanical yohimbine, compounded from the bark of pausinystalia yohimbine. This is always a drug and always requires a prescription. It may only be prescribed in its botanical form as identified.