HOUSE OF REPRESENTATIVES STAFF ANALYSIS
BILL #: HB 843 Naturopathic Medicine
SPONSOR(S): Smith
TIED BILLS: HB 845 IDEN./SIM. BILLS: SB 898
REFERENCE ACTION ANALYST STAFF DIRECTOR or
BUDGET/POLICY CHIEF
1) Healthcare Regulation Subcommittee 12 Y, 4 N Guzzo McElroy
2) Appropriations Committee Aderibigbe Pridgeon
3) Health & Human Services Committee
SUMMARY ANALYSIS
Naturopathic physicians diagnose, treat, and care for patients using a system of practice that bases treatment
on natural laws governing the human body. These practitioners may provide treatment to patients using
psychological, mechanical, and other means to purify, cleanse, and normalize human tissues for the
preservation and restoration of health. This may include the use of air, water, light, heat, earth, food and herb
therapy, psychotherapy, electrotherapy, physiotherapy, minor surgery, and naturopathic manipulation.
Naturopathic physicians are trained in standard medical sciences and in the use and interpretation of standard
diagnostic instruments. Naturopathic medicine stresses a holistic approach to health care, which involves
studying, and working with the patient mentally and spiritually, as well as physically, and developing an
understanding of the patient in the patient’s chosen environment.
Naturopathic practitioners were licensed in Florida from 1927 to 1959, when the Legislature abolished the
licensing authority for naturopathy. Only those naturopathic practitioners licensed at that time who had been
residents of Florida for two years were authorized to renew their licenses.
HB 843 reestablishes licensure and regulation of naturopathic physicians, and establishes new standards for
the practice. The bill provides licensure authority over naturopathic physicians to the Department of Health
(DOH). The bill creates the Board of Naturopathic Medicine to assist DOH in the regulation of naturopathic
physicians.
The bill has no fiscal impact on state or local government.
The bill provides an effective date of December 31, 2024.
This docum ent does not reflect the intent or official position of the bill sponsor or House of Representatives .
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 FULL ANALYSIS
I. SUBSTANTIVE ANALYSIS
A. EFFECT OF PROPOSED CHANGES:
Background
Naturopathy
The term “naturopathy” was used in the late nineteenth century to refer to an emerging system of
natural therapies and philosophy to treat disease. Naturopathic physicians diagnose, treat, and care for
patients using a system of practice that bases treatment on natural laws governing the human body.
These practitioners may provide treatment to patients using psychological, mechanical, and other
means to purify, cleanse, and normalize human tissues for the preservation and restoration of health.
This may include the use of air, water, light, heat, earth, food and herb therapy, psychotherapy,
electrotherapy, physiotherapy, minor surgery, and naturopathic manipulation. Naturopathic physicians
are trained in standard medical sciences and in the use and interpretation of standard diagnostic
instruments. Naturopathic medicine stresses a holistic approach to health care, which involves
studying, and working with the patient mentally and spiritually, as well as physically, and developing an
understanding of the patient in the patient’s chosen environment.
Florida Licensure and Regulation of Naturopathy
Naturopathy was initially recognized by the Legislature in the Medical Act of 1921 1, which defined the
practice of medicine and exempted naturopaths from the medical practice act. Naturopathic
practitioners were first licensed in Florida in 1927.2 Doctors of Naturopathy were required to observe
state, county, and municipal regulations regarding the control of communicable diseases, the reporting
of births and deaths, and all matters relating to the public health as was required of other “practitioners
of the healing arts.” Between 1947 and 1954, legal cases were decided regarding the rights of
naturopaths to prescribe narcotic drugs. The Circuit Court in Pinellas County held that practitioners of
naturopathy had the right to prescribe narcotic drugs.3 On appeal, the Florida Supreme Court affirmed
the lower court’s decision.4
In 1957, the Legislature abolished the Board of Naturopathic Examiners, significantly revised the
regulation of naturopathy, and placed the regulation under the Florida State Board of Health. 5
Naturopaths were classified into three groups based on the length of time that the practitioner was
licensed in the state. Under that law, those licensed less than two years could not renew their licenses;
those licensed more than two years but less than 15 years could not prescribe medicine in any form;
and those licensed more than 15 years could not prescribe narcotic drugs. The Florida Supreme Court
held that the naturopathic laws, as amended by ch. 57-129, L.O.F., were unconstitutional and void.6
In 1959, the Legislature abolished the licensing authority for naturopathy. 7 Only those naturopathic
practitioners licensed at that time who had been residents of Florida for two years prior to enactment of
ch. 59-164, L.O.F., were authorized to renew their licenses.
1 See chapter 8415, Laws of Florida.
2 See chapter 12286, Laws of Florida.
3 In re: Complaint of Melser, 32 So.2d 742 (Fla.1947). See also State Department of Pub lic Works v. Melser, 69 So.2d 347 at 353 (Fla.
1954).
4 Supra. See also Attorney General Opinion 54-96 and s. 893.02(19), F.S., relating to controlled substances, which defines
“practitioner” to include “… a naturopath licensed pursuant to chapter 462, F.S.” In 1939, the 5th Circuit Fed. Ct. (which includes
Louisiana, Mississippi, and Texas) interpreted the Federal Narcotic Drug Act which determined that a “naturopath” was not a
“physician;” therefore, they were prohibited from prescribing narcotic drugs. The court determined that even under phytotherapy, they
could not prescribe drugs. Perry v. Larson, 104 F.2d 728 (1939).
5 Ch. 57-129, Laws of Fla.
6 See Eslin v. Collins, 108 So.2d 889 (Fla. 1959).
7 See ch. 59-164, Laws of Fla.
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 Currently, chapter 462, F.S., governs the practice of naturopathy within the Department of Health
(DOH). The current practice act includes a wide variety of healing techniques but prohibits surgery,
chiropractic medicine, and the practice of “materia medica”, a term that includes the prescription of
drugs.8
Chapter 462, F.S., prohibits the issuance of a license to any person who was not practicing naturopathy
in Florida as of July 1, 1959.9 The chapter also authorizes DOH to adopt rules to implement the
regulation of naturopathic medicine including the establishment of fees.10 Additionally, it provides
procedures for naturopathic physicians licensed prior to 1959 to renew their license.
Draft legislation proposed by the Florida Naturopathic Physician Association was introduced in 2004
and 2006 to reestablish regulation of naturopathic medicine through licensure. A 2004 Sunrise Report
on Proposed Licensure of Naturopathic Physicians, by the Florida House of Representatives,
Committee on Health Care, concluded that “while there is evidence for support of licensure based on
the existence of accredited training programs and licensure examinations, there is no documented
evidence of substantial risk from not licensing naturopathic physicians. Moreover, there is potential risk
from licensing naturopathic physicians and allowing them to provide a broad range of primary care
services.”11
National Accreditation
The Council on Naturopathic Medical Education (CNME) accredits four-year, campus-based doctoral
programs in naturopathic medicine (ND programs) that qualify graduates for licensure in the U.S. and
Canada. CNME-accredited ND programs may also incorporate online/distance education coursework,
as well as hybrid courses that combine online and in-person components. The CNME does not accredit
ND programs that are taught entirely or primarily using online/distance instruction, and these types of
programs do not qualify individuals for licensure. CNME’s accreditation standards cover areas such as
ND program length and content, clinical training requirements, faculty qualifications, student services,
student and program assessment, facilities, and library resources.12
There are five accredited colleges of naturopathic medicine in the United States: Bastyr University,
San Diego, California; Bastyr University, Kenmore, Washington; National University of Health Sciences,
Chicago, Illinois; National University of Natural Medicine, Portland, Oregon; and Sonoran University of
Health Sciences, Tempe, Arizona.13 The graduates of these programs receive a Doctor of Naturopathic
Medicine degree after four years of professional study. Admission requirements include completion of a
bachelor’s degree before matriculation into the naturopathic medicine program with specified
exceptions, including the following courses: inorganic chemistry with lab, organic chemistry with lab,
biology with lab, physics, and psychology.
8
S. 462.01(1), F.S., “Natureopathy” and “naturopathy” are defined as synonymous terms and mean the use and practice of
psychological, mechanical, and material health sciences to aid in purifying, cleansing, and normalizing human tissues for the
preservation or restoration of health, according to the fundamental principles of anatomy, physiology, and applied psychology, as may
be required. Naturopathic practice employs, among other agencies, phytotherapy (botanical \herbal medicine), dietetics, psychotherapy,
suggestotherapy (process of influencing attitudes and behaviors by suggestions), hydrotherapy (scientific use of water in the treatment
of diseases), zone therapy (a process of using various points on the human body causing a reflex action in another part of th e body to
treat disease and relieve pain), biochemistry, external applications, electrotherapy (generation of heat in the body by use of electrical
current), mechanotherapy (manipulation of the body tissues and joints), mechanical and electrical appliances, hygiene, first aid,
sanitation, and heliotherapy (the use of sun rays in the treatment).
9 S. 462.023, F.S.
10 Id.
11 Florida House of Representatives, Committee on Health Care, Sunrise Report on Proposed Licensure of Naturopathic Physicians
(Jan. 2004), available at https://centerforinquiry.org/wp-content/uploads/sites/33/quackwatch/fl_sunrise_2004.pdf (last visited January
21, 2024).
12 Council on Naturopathic Medical Education, Naturopathic Program Accreditation, available at https://cnme.org/naturopathic-
accreditation/#overview (last visited January 21, 2024).
13 Council on Naturopathic Medical Education, Accredited Naturopathic Schools, available at https://cnme.org/accredited-
programs/#schools (last visited January 21, 2024).
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 Other State Licensure of Naturopathy
Currently, 24 states regulate naturopathic doctors.14
According to the Association of Accredited Naturopathic Medical Colleges, to be licensed as a primary
care naturopathic physician by a state which requires licensing, one must: 15
 Graduate from a four-year, professional-level program at an accredited naturopathic medical
school that is recognized by the United States Department of Education;
 Pass the two-part Naturopathic Physicians Licensing Exam, which covers basic sciences,
diagnostic and therapeutic subjects, and clinical sciences; and
 Pass jurisprudence examinations and meet other state requirements for regulated professions
including background checks and continuing education.
Effect of the Bill
The bill creates standards for the licensure and regulation of naturopathic physicians.
Board of Naturopathic Medicine
The bill creates the Board of Naturopathic Medicine within DOH. The bill provides for the composition
of the seven-member board, appointed by the Governor and confirmed by the Senate, to include the
following:
 Five licensed naturopathic physicians who are Florida residents.
 Two who are not health care practitioners and who are Florida residents.
 At least one who is 55 years of age or older.
The bill provides for staggered terms by requiring three members to be initially appointed for four-year
terms, two members for three-year terms, and two members for two-year terms. As the terms expire,
the Governor must appoint successors for terms of 4 years.
The bill requires the board, in conjunction with DOH, to establish a disciplinary training program for
board members. The disciplinary training program must provide initial and periodic training on the
grounds for disciplinary action, the actions that may be taken by the board and DOH, changes in
relevant statutes and rules, and any relevant judicial and administrative decisions. A member of the
board may not participate on a probable cause panel or in a disciplinary decision of the board unless
they have completed the disciplinary training program.
Board members must attempt to complete their work on a probable cause panel during their terms of
service. However, if consideration of a case has begun but it is not completed during a board members
term of service, the board may reconvene as a probable cause panel to complete their deliberations
on the case.
Scope of Practice
The bill establishes the scope of practice for naturopathic physicians to include the diagnosis,
prevention, and treatment of any human disease, pain, injury, deformity, or other physical or mental
condition for therapeutic or preventative purposes. Treatment by a naturopathic physician may include
the prescription of lifestyle changes, natural medicines, vitamins, minerals, dietary supplements,
botanical medicines, medicinal fungi, and homeopathic medicines. Naturopathic physicians may
prescribe legend drugs as specified by the Naturopathic Medical Formulary established under s.
14 Association of Accredited Naturopathic Medical Colleges, Naturopathic Doctor Licensure, available at https://aanmc.org/licensure/
(last visited January 21, 2024). The states include Alaska, Arizona, California, Colorado, Connecti cut, Hawaii, Idaho, Kansas, Maine,
Maryland, Massachusetts, Minnesota, Montana, New Hampshire, New Mexico, North Dakota, Oregon, Pennsylvania, Rhode Island,
Utah, Vermont, Washington, and Wisconsin (plus the District of Columbia and Puerto Rico).
15 Id.
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 462.025, F.S., in accordance with the educational standards and requirements set by the Council on
Naturopathic Medical Education, or an equivalent body.
The bill authorizes the board to establish by rule standards of practice and standards of care for
particular practice areas, including, but not limited to, education and training, equipment and supplies,
medications as specified by the Naturopathic Medical Formulary under s. 462.025, assistance from and
delegation to other personnel, transfer agreements, sterilization, records, performance of complex or
multiple procedures, informed consent, and policy and procedure manuals.
The bill prohibits a naturopathic physician from performing any of the following duties:
 Prescribing, dispensing, or administering and legend drug other than those authorized under
the Naturopathic Medical Formulary established under s. 462.025, F.S.
 Performing any surgical procedures.
 Practicing or claiming to practice as a medical doctor or physician, osteopathic physician,
dentist, podiatric physician, optometrist, psychologist, nurse practitioner, physician assistant,
chiropractic physician, physical therapist, acupuncturist, midwife, or any other health care
practitioner as defined in s. 456.001, F.S.
 Using general or spinal anesthetics.
 Administering ionizing radioactive substances.
 Performing chiropractic or osteopathic adjustments or manipulations that include high-velocity
thrusts at or beyond the end range of normal joint motion, unless the naturopathic physic ian is
also licensed as a chiropractic physician or an osteopathic physician.
 Performing acupuncture, unless also licensed as an acupuncturist.
 Prescribing, dispensing, or administering for cosmetic purposes any nonprescription drug or
legend drug listed in the Naturopathic Medical Formulary.
Licensure
Initial Licensure
The bill requires an applicant for licensure as a naturopathic physician to meet the following
requirements, which must be certified by the board:
 Be at least 21 years of age.
 Have