Introduction

As part of its strategic plan for 2023-2027, the Council of the College of Naturopaths of Ontario established as a strategic objective that Naturopathic Doctors are trusted because they are effectively regulated. The Council set out several priorities in support of this objective, including that “the College examines the regulatory model to maximize the public protection benefit to Ontarians.”

As a part of this review, the College may consider both changes to the existing regulations made under the Naturopathy Act, 2007, as well as enacting new regulations under its regulation making authority.

In line with these considerations, the College of Naturopaths of Ontario is undertaking a preliminary consultation on the potential for changes or additions to the classes of registration available to the profession through the College.

At this time, the College seeks the input of its registrants, the public, and system partners on whether the Council should consider changes to the current approach to the classes of regulation as set out in the Registration Regulation made under the Naturopathy Act, 2007. A decision to proceed with changes to the classes of registration has not yet been made, and all feedback will be brought forward in any subsequent decision-making process by the Council of the College.

Background

The Registration Regulation, Ontario Regulation 84/14 made under the Naturopathy Act, 2007 establishes three classes of registration in which a certificate of registration may be issued:

1. General class.
2. Inactive class.
3. Emergency class.

The emergency class of registration was added in 2023 at the request of the Ontario Government as part of its future pandemic planning efforts.

In addition to establishing the classes, the Regulation also sets out the requirements that must be met for a certificate of registration in that class to be issued, any terms, conditions, and limitations on those certificates, and moving from one class of registration to another.

During the process of developing the Registration Regulation, consideration was given to other classes of registration to be available which were subsequently ruled out by the Council. For example, consideration was given to establishing an academic registration class for individuals who devote most of their time to education of students in a naturopathic program. Such a class of registration would enable the individual to retain their use of title while not being permitted to see patients.

This consultation explores many of the alternative approaches to the current limited classes of regulation to determine whether potential changes might provide better public protection for Ontarians while enabling better access to the profession by NDs.

Regulation Making Authority

If the Council of the College, in consultation with the Ministry of Health, were to propose changes to the Registration Regulation, the authority to do so rests in section 95(1) of the Health Professions Procedural Code, Schedule 2 of the Regulated Health Professions Act, 1991 which states:

Regulations

95 (1) Subject to the approval of the Lieutenant Governor in Council and with prior review of the Minister, the Council may make regulations,

• (0.a) omitted;
• (a)  prescribing classes of certificates of registration and imposing terms, conditions, and limitations on the certificates of registration of a class;
• (b)  respecting applications for certificates of registration or classes of them and the issuing, suspension, revocation and expiration of the certificates or classes of them;
• (c)  prescribing standards and qualifications for the issue of certificates of registration;
• (d)  prescribing certain registration requirements as non-exemptible requirements for the purposes of subsection 18 (3) and 22 (8);
• (e)  defining specialties in the profession, providing for certificates relating to those specialties, the qualifications for and suspension and revocation of those certificates and governing the use of prescribed terms, titles or designations by members indicating a specialization in the profession;
• (f)  requiring, for purposes associated with the registration of members, the successful completion of examinations as set and approved, from time to time, by the College, other persons or associations of persons and providing for an appeal of the results of the examinations; …

In addition to providing valuable information about the profession to the public, making changes to the Registration Regulation could add a valuable tool in the regulatory framework for the College. It would also provide valuable context to the naturopathic profession in Ontario.

Supporting Documentation

In line with the intent of this consultation, several supporting documents have been created, providing greater context for what changes might be considered. As this is a preliminary consultation on this topic, these documents have not been vetted or approved by the Council of the College. The documents include:

Name	Description
White Paper – Classes of Registration	This document sets out various issues the College has encountered since proclamation of the Naturopathy Act, 2007 on the classes of registration and related matters. It sets out 10 areas of consideration on which the College is seeking input from system partners and the profession.
Appendix A – Comparison of Classes of Registration	This document sets out a comparative analysis of the nomenclature for classes of registration for naturopathic doctors in Canada and for other professions in Ontario.
Appendix B – Reinstatement Provisions in Ontario Health Profession Regulation	This document sets out approaches to reinstatement where such provisions exist for health professional regulation.

Consultation Areas

Through this consultation, the College is seeking feedback in 10 specific areas of consideration. In support of this, an online form is available for individuals and organizations to provide feedback.

Consideration 1: Nomenclature or names of the classes of registration.
Consideration 2: A non-clinical class of registration.
Consideration 3: A student class of registration.
Consideration 4: A transitional, supervised, or provisional class.
Consideration 5: Should changes be made to the Inactive class?
Consideration 6: Extended Classes of registration.
Consideration 7: Naming of extended classes, if needed.
Consideration 8: Rostering for Certain Controlled Acts.
Consideration 9: Reinstatement provisions.
Consideration 10: Other matters that might be addressed.

Feedback

The College is seeking feedback from all stakeholders, including 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

The College will be providing the opportunity for feedback. Consultation will begin on or before March 12, 2025, and will conclude on or about April 25, 2025.

Our Thanks

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

Andrew Parr, CAE
Chief Executive Officer