Collecting Specimens and Ordering Laboratory Tests - Frequently Asked Questions


These questions and the answers to them are intended as general guidance to the most common questions about specimen collection and ordering laboratory tests.  The responses are not legal or practice advice and are not intended as such.  For more detailed information on the subject, readers should review the relevant statutes, regulations and standards of practice and consult with legal counsel.

Index of Questions


Can a naturopath take blood from a patient in their office?
Can a naturopath still prick a finger for an IgG test?
Can a naturopath milk a finger after a patient has pricked the hand?
Can a naturopath order a test directly from a lab without an MD signing?
Should a naturopath use a specific form when ordering labs?
Who is responsible for the regulation on specimens and laboratory access?
Can a naturopath order lab tests from out-of-province laboratories?
Where is the list of lab tests that a naturopath can order?
Can a patient use a testing kit and have the results sent to their ND?
Can a patient show a naturopath a test result obtained from other sources? If so, can the naturopath use it?

Answers


Can a naturopath take blood from a patient in their office?

Yes, but only for the purposes of performing the seven point-of-care tests authorized in the General regulation.

Can a naturopath still prick a finger for an IgG test?

IgG testing as a point-of-care test (finger pricking and in-office testing) is not permitted under the General regulation. However, a naturopath can requisition this test through specimen collection centres in Ontario.

Can a naturopath milk a finger after a patient has pricked the hand?

The process described is the collection of a specimen of blood. A naturopath can only collect blood and perform naturopathic examinations if it is authorized under the General regulation,. In this scenario, the naturopath is collecting a specimen of blood with the intention of testing that blood.  In doing so, the naturopath can only perform one of the seven point-of-care tests authorized in the regulation.  

Asking a patient to prick their hand or finger does not allow the naturopath a means of circumventing the regulation and its intent.

Can a naturopath order a test directly from a lab without an MD signing?

It depends on the test. The Ministry of Health and Long-Term Care now allows a naturopath to requisition:
  • the taking of a specimen by an Ontario specimen collection centre; and
  • the performance of a test on that specimen in an Ontario laboratory.  
With that authority, naturopaths no longer require signatures of other regulated health care providers.

Naturopaths can only order tests that are authorized to the profession in the regulation.  If a test is not authorized, it cannot be obtained by the naturopath by having another health care provider co-sign the form.  

In some cases, another health care provider might requisition a test that is not authorized to a naturopath; however, in doing so, the test results are sent to the signing health care provider who would then, with patient consent, share the results with the naturopath.  This presumes that the other health care provider has a patient-practitioner relationship with the patient.

Should a naturopath use a specific form when ordering labs?

There are no specific requisition forms for collecting a specimen and ordering a laboratory test. The College of Naturopaths of Ontario is in discussions with the Ministry of Health and Long-Term Care about developing such a form.

Who is responsible for the regulation on specimens and laboratory access?

The Ministry of Health and Long-Term Care, through the Laboratory and Specimen Collection Centre Licensing Act.  While the College of Naturopaths of Ontario may be asked for recommendations or submit recommended changes, the final decision rests with the Ministry.

Can a naturopath order lab tests from out-of-province laboratories?

No. Naturopaths may requisition tests or take and send samples only to laboratories licensed under the Laboratory and Specimen Collection Centre Licensing Act, which is Ontario-based legislation.

Where is the list of lab tests that a naturopath can order?

The official list is contained in the regulations made under the Laboratory and Specimen Collection Centre Licensing Act.  Click here to see that regulation.  The College has also summarized the list of labs in this section of the website.

Can a patient use a testing kit and have the results sent to their ND?

No. Such testing kits involve the patient collecting his or her own sample, placing it in the provided carrier, and sending it to a laboratory. These kits, which must be approved by Health Canada, require a requisition form for a laboratory to perform the test. For the results to be sent to the naturopath, the test must be among those that a naturopath has the ability to order. If the naturopath cannot requisition the performance of the test by an Ontario laboratory, then the laboratory would not perform the test.

Asking a patient to collect his or her own specimen, depending on the nature of the specimen, could put the patient at risk of harm, which could result in complaint about the naturopath.

A naturopath who asked a patient to collect their own specimen and send that specimen outside Ontario is attempting to circumvent the legislative framework around specimen collection and laboratory testing in Ontario. That could make the naturopath subject to a complaint or Registrar’s report.

Can a patient show a naturopath a test result obtained from other sources? If so, can the naturopath use it?

To derive and communicate a diagnosis, a naturopath can use any tests that are reasonably available to them, provided:
  • The test was obtained from a reliable source.
  • The results can be deemed to be valid.
  • The naturopath has the knowledge, skill and judgment to interpret the test results.  
This may become of considerable importance should an investigation result from a complaint or a Registrar’s report; these factors could determine whether a referral to the Discipline Committee is warranted.