Introduction

As part of its strategic plan for 2023-2027, the Council of the College of Naturopaths of Ontario established as a strategic objective that Naturopathic Doctors are trusted because they are effectively regulated. The Council set out several priorities in support of this objective, including that “the College examines the regulatory model to maximize the public protection benefit to Ontarians.”

As a part of this review, the College may consider both changes to the existing regulations made under the Naturopathy Act, 2007, as well as enacting new regulations under its regulation making authority.

In line with these considerations, the College of Naturopaths of Ontario is undertaking a preliminary consultation on the potential for establishing a program for naturopathic specialties.

At this time, the College seeks the input of its registrants, the public, and system partners on whether the Council should consider changes to the current approach to the classes of regulation as set out in the Registration Regulation made under the Naturopathy Act, 2007. A decision to proceed with changes to the classes of registration has not yet been made, and all feedback will be brought forward in any subsequent decision-making process by the Council of the College.

Background

Over the course of the first decade as the regulatory authority for naturopathic doctors in Ontario, several questions have arisen with respect to the regulation of the naturopathic profession in Ontario. One of those questions that emerged even prior to proclamation of the Naturopathy Act, 2007 was whether NDs in Ontario should be permitted to specialize.

Currently, Naturopathic Doctors in Ontario are not permitted to indicate that they specialize within the practice of the profession. Doing so, could result in an investigation by the College for professional misconduct under paragraph 31 of section 1 of the Professional Misconduct Regulation (Ontario Regulation 17/14) which states:

1. The following are acts of professional misconduct for the purposes of clause 51 (1) (c) of the Health Professions Procedural Code:
31. Inappropriately using a term, title or designation indicating or implying a specialization in the profession.

Although indicating that one specializes is not allowed, it is permitted for an ND to focus their practice in specific areas and to advertise the “focus of their practice.” This preliminary consultation is seeking input on whether the College should alter or remove the prohibition in the Professional Misconduct Regulation and institute a program for specialization.

Regulation Making Authority

If the Council of the College, in consultation with the Ministry of Health, were to propose changes to enable specialization, the authority to do so rests in section 95(1) of the Health Professions Procedural Code, Schedule 2 of the Regulated Health Professions Act, 1991 which states:

Regulations

95 (1) Subject to the approval of the Lieutenant Governor in Council and with prior review of the Minister, the Council may make regulations,
(e)  defining specialties in the profession, providing for certificates relating to those specialties, the qualifications for and suspension and revocation of those certificates and governing the use of prescribed terms, titles or designations by members indicating a specialization in the profession;

Supporting Documentation

In line with the intent of this consultation, a supporting document has been created, providing greater context for the questions that a program of specialization might raise. As this is a preliminary consultation on this topic, these documents have not been vetted or approved by the Council of the College. The documents include:

Name	Description
White Paper – Naturopathic Specialization	This document sets out various issues a program of specialization would raise. It sets out seven areas of consideration on which the College is seeking input from the public, the profession and system partners.

Consultation Areas

Through this consultation, the College is seeking feedback in 10 specific areas of consideration. In support of this, an online form is available for individuals and organizations to provide feedback.

Consideration 1: General Approach to Specialization.
Consideration 2: Criteria for Naturopathic Specialty Program.
Consideration 3: Other criteria for specialization.
Consideration 4: Naturopathic Specialties.
Consideration 5: Impact on Regulation of the Profession.
Consideration 6: Feedback on Classes Considerations.
Consideration 7: Drugs, substances and lab tests.

Feedback

The College is seeking feedback from all registrants, the public, naturopathic organizations, and other regulatory bodies. Feedback may be provided through the College’s online submission form or by written letter or email.

All feedback must include the name of the individual submitting the feedback for validity purposes. Anonymous submissions will not be considered and will not be retained by the College.

Feedback can be provided to the following addresses:

Written correspondence by mail:	College of Naturopaths of Ontario 10 King Street East, Suite 1001 Toronto, ON  M5C 1C3
Written correspondence by facsimile:	(416) 583-6011
Written correspondence by e-mail:	general@collegeofnaturopaths.on.ca
On-line form:	On-line Feedback Form

Time

Consultation will begin on or about May 14, 2025, and will conclude on or about June 27, 2025.

Our Thanks

The College thanks everyone for reviewing these consultation materials and providing feedback.