Introduction

The Council of the College of Naturopaths of Ontario (the Council) is undertaking a consultation on a draft Framework for the Evaluation of Laboratory Test Submissions. The intent of the consultation is to obtain feedback on the framework, which would guide both the submission process by which system partners seek the support of the Council for requests to the Ministry of Health to add or modify laboratory tests that Ontario NDs are able to use as a part of practice, as well as to guide the decision-making process of the Council.

Background

The Council is required to review requests from individual practitioners, system partners and patient advocates for changes or additions to the list of laboratory tests that can be performed and ordered by Naturopathic Doctors.

The regulation governing these tests is one made under the Laboratory and Specimen Collection Centre Licensing Act (LSCCLA), not under the rubric of the Regulated Health Professions Act, 1991 or the Naturopathy Act, 2007. As such, the Council does not have direct control over these regulations; however, historically, the Ministry of Health, which does have control over the LSCCLA regulation, has sought the support of the Council for any requests for changes to the laboratory test list.

This was true in the lead up to proclamation of the Naturopathy Act, 2007 when commensurate changes to the LSCCLA regulation authority laboratory testing and requisitioning by NDs officially allowed NDs access to Ontario’s laboratory system. It was also true in late 2024 when the Ministry received a request from a system partner for changes and asked that the organization first seek the support of the Council.

In late 2024, the College received a submission from the Ontario Association of Naturopathic Doctors (OAND) for changes to the list of laboratory tests accessible by the profession. As part of its review, the College sought advice from an external reviewer with knowledge and experience with laboratory testing.

In receiving the advice, it became clear that in addition to proceeding with the review of the submission itself, a framework would be helpful, moving forward, to reduce the size of submissions by eliminating tests that would not, or could not be considered.

The purpose of creating a framework for the evaluation of laboratory test submissions is to ensure transparency in the evaluation process, as well as to support the mandate of the Council and the College, which is to serve and protect the public interest.

In the absence of such a framework, the public, the profession, and system partners would have no clear understanding of what the Council might support and why. By establishing the framework, it will be clear to all involved which tests might be approved by the Council.

Although the Ministry of Health has been consulted in developing the framework, it does not bind the Ministry to accede to a request for laboratory testing supported by the Council. The decisions on inclusion of laboratory testing belong exclusively to the Ministry based on parameters set by the Ministry.

The framework’s intent, if approved, is to allow the College staff to conduct an initial review and apply it to any submission. This would potentially reduce the size of the list of lab tests by eliminating those that do not fit within the framework.

This also would reduce costs to the College as the lab tests that are beyond consideration as set out in the framework would not require an expert review.

Supporting Documentation

In line with the intent of this consultation, a supporting document has been created, providing greater context for the questions that testimonials might raise. This document has been reviewed by and approved, in principle, by the Council for the purposes of enabling this consultation.

Name	Description
Framework for the Evaluation of Laboratory Test Submissions	This document sets out the proposed criteria by which the Council would evaluate a submission for adding or modifying lab tests available to Ontario NDs as well as guiding outside organizations in terms of the submission requirements.

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 September 25, 2025, and will conclude on or about October 31, 2025.

Our Thanks

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

Andrew Parr, CAE

Chief Executive Officer