Additional Clarification on Lab Testing

Dear Registrants,

On July 21, 2021, the College issued an advisory to Registrants relating to lab test ordering and two specific tests of concern. Following up to that advisory, the Ontario Association of Naturopathic Doctors (OAND) issued a statement to its members which contained information that the College is now clarifying for all Registrants.

The OAND has said that “ICL is Ministry licensed and accredited and there has been no claim of inappropriate action on their part, or the part of NDs who ordered a test through them.” The intent of the advisory is to alert Registrants to the issues and does not initiate regulatory action on the part of the College. However, Registrants should be aware that the issuance of the advisory does not prohibit a patient who has been impacted by this issue from filing a complaint with the College. All complaints received by the College must be investigated under the Regulated Health Professions Act, 1991.

  • Given that Public Health Units may be contacting patients for whom the ICL GI Map and ICL Lyme disease test results have been reported, patient reactions may be varied. Registrants may wish to be proactive and contact patients for whom these tests have been ordered.

The OAND also stated “Please remember though the Ontario rules stipulate that you cannot order tests from the United States or other countries directly. They have to be “brokered” through an accredited Ontario laboratory.” This is incorrect and could lead to challenges for Registrants.

  • According to information provided to the College by the Ministry, when requisitioning a lab test from a lab, the lab must be licensed to perform the test and must perform that test. They cannot send that test to another lab outside of Canada*.

Finally, the OAND, in their statement, indicated that “it is important to note though that this issue is between ICL and Public Health/the Ministry of Health/CONO, and NDs are only peripherally involved.” While this was likely intended to be reassuring, it is also not entirely accurate and it oversimplifies the situation.

  • The Ministry of Health Laboratory Services Branch concerns itself with labs and lab testing.
  • Public Health Ontario and the Chief Medical Officer of Health concern themselves with diseases of public health significance (DOPHS).
  • The Ministry of Health Regulatory Oversight Branch concerns itself with the regulation of the profession and the College, while the College is to address compliance with the regulatory framework, including NDs ordering lab tests.

NDs are not merely peripherally involved. The Public Health alert to the local Public Health Units specifically identified NDs as being responsible for ordering these tests and creating a situation where reports of false positives were being filed.

The College has developed a Fact Sheet on the topic to provide Registrants with guidance to support their requisitioning tests from laboratories, including questions to ask a laboratory when you are being approached surrounding new tests available for your patients.

Finally, we would like to encourage Registrants to contact the College if you have questions about lab tests or any other regulatory matters. Gaining an understanding of the rules governing the profession is best accomplished through direct interaction with the people enforcing those rules, otherwise, there are risks of misinterpretation and “broken telephone” issues.

Please e-mail any questions to


Kind regards,

Andrew Parr, CAE
Chief Executive Officer



* A company that has labs in both Canada and the United States where they are all accredited within their respective regulatory framework, and where the lab is licensed to perform the test could, in theory, send the test outside of Canada to one of their other labs for processing. To the best of our knowledge, no such situation exists, although this is similar to an Ontario lab that has a division in Alberta.

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