Testimony on HB 1998
Chairman Sturla and members of this committee. Good afternoon and thank you for inviting the Pennsylvania Medical Society here today to present testimony on House Bill 1998.
I am Peter S. Lund, MD. Currently, I am the president of the Pennsylvania Medical Society. In addition I practice urology in Erie.
Let me begin by first stating that the goal of health care professionals is to help patients either maintain or improve their daily health. This is done through evidence-based, peer-reviewed science that leads us to the best treatment options that are safe for those that we care for.
Because of our belief that treatment options should be safe as well as proven by science, the Pennsylvania Medical Society cannot support House Bill 1998, which essentially recognizes the practice of naturopathic medicine.
Some modalities used in naturopathy are controversial. And there can be large differences among naturopathic providers and the lack of scientific data and documentation of the safety and efficacy of naturopathic processes.
The treatment protocols that physicians use in the practice of medicine are based on rigorous scientific testing. More significantly, our profession is practiced around the world, and the result is that there is a tremendous knowledge base that is the foundation for our training as physicians.
Alternative therapies are not subject to detailed safety assessment. Some naturopathic modalities and remedies are known to be harmful if not properly used. As you know, it’s not unusual for drug trials to last years as part of the ongoing concern for patient safety.
Across the country, the overwhelming majority of states do not recognize naturopathic medicine. In fact our research indicates that two states – South Carolina and Tennessee – make it illegal to practice naturopathic medicine.
Furthermore, not one of Pennsylvania’s bordering neighbor states – New Jersey, New York, Ohio, West Virginia, Maryland, or Delaware – acknowledges this profession through licensure.
Outside of the fact that naturopathy doesn’t go through the same level of testing as conventional medicine, there remains flaws in HB 1998 as it is written.
For example, this bill would allow naturopathic specialists to remove foreign bodies located in superficial tissues. Superficial tissues as recognized by medical experts have many anatomic structures that if not recognized can be injured. The consequence of these injuries can be and have been devastating including necrotizing fascitits, skin necrosis, loss of anatomic function, paralysis, loss of nerve function, and chronic pain syndromes.
Plus by giving the naturopathic specialists the permission to remove foreign bodies or operate on superficial tissue, they would be considered to be practicing surgery. It would be dangerous to put a scalpel in the hands of someone who doesn’t have a complete trained in surgical technique and principals. To be adequately trained to do surgery requires a minimum of three years of direct supervise training after four years of medical school. This is a safety issue first then a quality issue. In medicine it is not what you know it is missing what you don’t know that can cause harm to the patient. The first tenant in medicine is “do no harm”.
We’re also very concerned about the broadly worded definition of the scope of practice as outlined in Chapter 7 of the bill. We have questions about the qualifications of naturopathic doctors to interpret laboratory studies. The peculiar wording of language relating to prescribing in the section on prohibitions is also a serious concern.
And that takes me to my next point: Continuing Medical Education.
After years of medical school and after residency programs have been completed, a medical doctor still must have 100 hours of continuing medical education every two years. It’s a process designed to keep medical specialists at the top of their game in an ever changing medical world. And, it’s designed to maintain patient safety.
Unlike physicians, naturopathic specialists do not have the same rigid requirements to address patient safety. In fact, HB 1998 would let naturopathic specialists treat patients with only 24 hours of continuing education during the same two-year period.
Furthermore, at this time no major research university or college in the United States has a degree-granting program for naturopathic specialists. In fact, as I reviewed the Website of the American Association of Naturopathic Medical Colleges, there are only four in the United States and two in Canada.
This concerns the Pennsylvania Medical Society because it is likely that the number of naturopathic specialists in Pennsylvania could not financially support the operations of licensure, its board, and its investigators. Other states that have studied this have come to the same conclusion. In fact a 2004 study conducted by a Florida legislative committee on proposed licensure of naturopathic specialists concluded that “the small number who would be licensed would have difficulty meeting requirements to fund the cost of administering licensure and support for a board.”
That same Florida legislative committee also concluded that of the scientifically acceptable naturopathic procedures that the public is already protected as those procedures can be conducted by licensed medical doctors and osteopathic physicians as well as other practitioners such as chiropractors who use those procedures.
So, at a time when patient safety is of utmost concern, Pennsylvania should work towards ensuring the proven procedures and medications are being administered by those with a broader knowledge of medicine. This is in the best interest of patient safety, and should not be lowered.
Also, speaking of patient safety, there’s no mention of medical liability insurance for naturopathic specialists in House Bill 1998. In Pennsylvania, physicians must carry liability insurance with coverage limits of $1 million per occurrence / $3 million aggregate as a condition of licensure. Accidents do happen, and this insurance protects both the injured patient as well as the medical professional’s personal assets.
Should a naturopathic specialist commit malpractice, HB 1998 does nothing for the injured individual or the specialist. The injured individual may have no recourse. And, because the legal system is so expensive, it’s questionable that they would even have their day in court.
As a matter of policy, the Medical Society doesn’t believe that medical liability insurance should be linked to our licenses. However, we find it particularly troubling that this proposed legislation would not impose such a requirement on a group with far less clinical training than physicians.
I realize that some individuals will want to portray everything that I just said as protecting territory. But the reality is that this is about protecting patients. HB 1998 does not raise patient safety to the highest level possible, particularly since many aspects of naturopathic medicine are controversial and have not been proven through science.
Again, I want to state that the Pennsylvania Medical Society does not support HB 1998.
Thank you. I will be happy to answer your questions.
Last Updated: 8/1/2008