July 28, 2023

Board of Naturopathy Moves Forward with Non-Surgical Cosmetic Procedures Rulemaking

The Board of Naturopathy has issued a CR-102 that would allow naturopaths to perform nonsurgical cosmetic procedures, the latest step in their years-long effort to increase their scope of practice to include the performance of these procedures. While disappointing, the CR-102 is specific to the use of botulinum toxin, not dermal fillers. The CR-102 does require naturopaths to complete training on aesthetic injectable technique, but there is no hourly requirement or required number of procedures to be performed under supervision.

The WSMA, partnered with the Washington Academy of Eye Physicians and Surgeons, the Washington State Dermatology Association, and Washington Society of Plastic Surgeons, has opposed this rulemaking at every opportunity, citing patient safety concerns. We've also shared that this procedure is inconsistent with naturopathic medicine and that this rulemaking subverts the legislative process, as the Legislature sets scope of practice. As a result of this advocacy, dermal fillers were excluded from the proposal.

We will continue to share our concerns with this proposal via both written and verbal comments. If you have questions about how you can share your thoughts with the Board of Naturopathy, contact WSMA Associate Policy Director Billie Dickinson.