Good morning Chairwoman Harhart, Chairman Readshaw and members of the House Professional Licensure Committee. Thank you for the opportunity to share with you the position of the Pennsylvania Medical Society on House Bill 1717.
My name is Marilyn Heine, MD, and I am currently president of the Pennsylvania Medical Society. By way of background, I completed my undergraduate degree at Brandeis University and attended the Robert Wood Johnson Medical School in New Jersey, being graduated after four years with an MD degree. I completed a sub-internship at Memorial Sloan Kettering Cancer Center in New York, my three year internship and residency in internal medicine at Thomas Jefferson University Hospital in Philadelphia and my four year clinical and research fellowship at Thomas Jefferson University’s Cardeza Foundation and the Medical College of Pennsylvania. Today, I practice emergency medicine in Montgomery County and hematology/oncology in Bucks County.
As we all know, and have come to expect, health care services are delivered to patients via a medical “team.” Whether this “team” is helping a critically injured patient at a trauma center, a pregnant woman whose baby is in fetal distress, or a young child complaining of a sore throat, we all work together with the best interest of our patients in mind. While the Pennsylvania Medical Society and I do not accept the tenets of naturopathic medicine, I recognize that there are individuals who seek this help.
Webster’s dictionary defines naturopathy as a system of treatment of disease that avoids drugs and surgery, and emphasizes the use of natural agents (such as air, water and herbs) and physical means (such as tissue manipulation and electrotherapy).
As a medical doctor, a physician, I believe in the science of medicine. That is, evidence-based and peer-reviewed medicine. For example, when I recommend a specific treatment protocol for a 32-year-old woman just diagnosed with stage 4 inflammatory breast cancer, I do so based on the results of hundreds of clinical trials and years of painstaking scientific research done by the experts in the field and the Food and Drug Administration. Again, evidence-based medicine.
Because of this fundamental belief and approach in treating human disease, the Pennsylvania Medical Society cannot support House Bill 1717. While I recognize that the proponents of this legislation wish to establish naturopathic licensure in Pennsylvania in order to differentiate themselves from lesser trained naturopathic practitioners, the bill goes well beyond that stated goal. Ironically, we oppose this bill largely on that very same premise…prohibiting non-physicians and lesser trained individuals from practicing medicine. With that said, I would like to briefly share with you some specific objections to the language found in this proposal.
Most alarming is the potential latitude given to naturopaths regarding their scope of practice which can be found in Chapter 4 of the bill. I would draw your attention to the first section of that chapter, specifically Section 401, line 7-10, where the scope of practice of naturopathy is loosely defined as “consistent with naturopathic education and training.” To me, this begs the question and further suggests that their scope of practice could change anytime their educational curriculum changes. This “open-ended” language does not provide what we believe would be a clear delineation as to what a naturopath can and cannot do in treating a potential patient.
You will likely hear today that a naturopath’s didactic education is similar, if not identical, to that of a medical physician. While the curriculum of the National College of Natural Medicine does include courses in anatomy, basic science, biochemistry, and pathology, it also includes courses such as hydrotherapy, Chinese medicine, homeopathy, botanical material and hydro/massage. I would respectfully submit that their course of study pales in comparison to the rigors of medical education here in the Commonwealth. Interestingly, their course work also includes several “minor surgery labs” and “pharmacology” which seems inconsistent with the tenets of “natural healing” and speaks directly to their desire to practice well beyond the confines of their philosophy.
The Textbook of Natural Medicine, written by Joseph E. Pizzorno, ND, provides perhaps the best glimpse into the practice of naturopathy. Originally published in 1985, this textbook, now in its third edition, is widely studied in schools of naturopathy. Though I won’t go into great detail here today with what is contained in this textbook, I will simply provide you with a quote from Arnold S. Relman, MD, professor emeritus, Medicine and Social Medicine, Harvard Medical School, and editor-in-chief emeritus of The New England Journal of Medicine . In 2001, Dr. Relman reviewed the second edition of this textbook as part of a legislative inquiry into naturopathic medicine in Massachusetts. Dr. Relman’s findings were presented to the Massachusetts Special Commission on Complementary and Alternative Medical Practitioners. His said at that time:
Primary care practitioners whose education does not include the use of prescription drugs simply cannot be expected to provide effective and safe care for many serious conditions they are likely to encounter. While it is true that unnecessary or inappropriate use of drugs is harmful, and that even proper usage of drugs can sometimes cause serious reactions, there can be no doubt that on balance prescription drugs have been enormously beneficial, and that drugs will be even more important in the future. The anti-pharmaceutical bias of naturopathic education (as illustrated in the Textbook) therefore poses real risks for patients who rely on naturopaths for the management of their illnesses. Without prompt and appropriate drug therapy many patients with serious diseases will die.
In further review of the bill, Section 401 allows naturopaths to order imaging studies, provide barrier contraception and perform behavioral medicine. It also spells-out “routes of administration” that include ocular, rectal, vaginal, and subcutaneous. Barrier contraception? Does this language refer to condoms, or, are they proposing to surgically implant through the vagina and into the uterus an IUD? I would certainly hope not. Why would a practitioner who does not necessarily embrace “conventional medicine” want to order an MRI, CAT scan, or even an x-ray? And, exactly what are they proposing to “administer” through an individual’s rectum, eye, or other orifice?
While language prohibiting the prescribing, dispensing, or administering of any controlled substance is spelled-out under the “prohibitions” section of the bill, it expressly qualifies that prohibition by stating “except as authorized by this act.” The very next section of the bill, Section 402 grants naturopaths with the authority to prescribe prescription drugs including “antimicrobials and bio-identical hormones.” This adds to the intrigue. Are naturopaths asking the legislature for licensure or are they asking to be granted permission to practice medicine? Section 401 and 402 contains considerable language to suggest the latter.
Lastly, I draw your attention to Section 506 of House Bill 1717, where naturopaths are given the statutory authority to use the term “physician” in their title. For obvious reasons, not the least of which being the many years it takes to educate and train a medical physician, we vehemently oppose the unearned use of the title “physician” by any health care provider other than a medical physician. To grant naturopaths the authority to use the word “physician” in their title will mislead and confuse patients and potentially lead to serious harm.
In conclusion, let me revisit for just a moment, my use of the term “medical team.” The Pennsylvania Medical Society recognizes that it takes a team of professionals to successfully treat an ill patient. From the pediatric neurosurgeon to the visiting home nurse, we all work together as a team. But, we can’t allow the lines of professional expertise and qualifications to become blurred. This is not unique to medicine or health care. Many professions embrace this same thinking…attorneys, engineers, architects and so on.
House Bill 1717 seeks far more than licensure status here in Pennsylvania. It is my hope that you carefully consider the entire scope of what this measure seeks to accomplish and vote against its passage.
Thank you again for the opportunity to appear before you today regarding House Bill 1717. To the best of my ability, I would be happy to take any questions you may have.