Information for Pharmacists
Can NDs dispense medication?
Technically, NDs can dispense medication - however, you must ensure that you are meeting all applicable state laws when dispensing medication (e.g. pharmacy laws, labelling laws, etc.).
What substances may a licensed naturopathic doctor prescribe?
NDs are independently allowed to prescribe, furnish, order or administer all synthetic and natural hormones, as well as epinephrine. The state board, the Naturopathic Medicine Committee, has a notice about this on their website
To prescribe, furnish, or order any other legend drugs (i.e. antibiotics, hypertensives, etc.) or Schedule III-V Controlled Substances, an ND must have signed a supervision agreement with an MD or DO licensed in California as per Business and Professions Code Section 3640.5 within the Naturopathic Doctors Act. The supervision agreement includes a formulary and standardized protocols or procedures which include: "which naturopathic doctors may furnish or order drugs, which drugs may be furnished or ordered under what circumstances, the extent of physician and surgeon supervision, the method of periodic review of the naturopathic doctor's competence, including peer review, and review of the provisions of the standardized procedure."
The only requirement for providing the protocol developed between the ND and his/her supervising physician to a pharmacist is with respect to the ND's specific standardized protocol/procedure relating to controlled substances. Section 3640.5(f) states:
"Drugs furnished or ordered by a naturopathic doctor may include Schedule III through Schedule V controlled substances under the California Uniform Controlled Substances Act (Division 10 (commencing with Section 11000) of the Health and Safety Code) and shall be further limited to those drugs agreed upon by the naturopathic doctor and physician and surgeon as specified in the standardized procedure. When Schedule III controlled substances, as defined in Section 11056 of the Health and Safety Code, are furnished or ordered by a naturopathic doctor, the controlled substances shall be furnished or ordered in accordance with a patient-specific protocol approved by the treating or supervising physician. A copy of the section of the naturopathic doctor's standardized procedure relating to controlled substances shall be provided upon request, to a licensed pharmacist who dispenses drugs, when there is uncertainty about the naturopathic doctor furnishing the order."
The CNDA does not have the prescribing protocols for California-licensed naturopathic doctors, and the Naturopathic Medicine (Committee of California, the state body that governs California licensed naturopathic doctors, does not have these either. These are developed and maintained between each naturopathic doctor (ND) and his/her supervising physician if the naturopathic doctor wants to prescribe any legend or Schedule III - V drugs other than natural and synthetic hormones, including testosterone; epinephrine for anaphylaxis; and vitamins, minerals, amino acids, glutathione, botanicals, and their extracts, homeopathic medicines, electrolytes, sugars, and diluents, all of which a California-licensed naturopathic doctor may prescribe independently without a supervising physician. (See California Business and Professions Code section 3640.7 for the list of what California-licensed naturopathic doctors can prescribe and administer independently).
As a pharmacist, may I fill an ND's prescription for scheduled hormones if the ND doesn't have a supervising MD/DO?
Yes. According to the Naturopathic Practice Act, “Notwithstanding the requirements of Section 3640.5 or any other provision of this chapter, a naturopathic doctor may independently prescribe epinephrine to treat anaphylaxis and natural and synthetic hormones” (emphasis added). Source: Section 3640.7 of the California Business & Professions Code.
The Naturopathic Medicine Committee has also posted a notice on their website regarding the independent hormone prescription privileges of licensed Naturopathic Doctors. That notice can be found online.
If a pharmacist has questions about filling a prescription from an ND, where can he/she obtain help and information?
The regulations dealing with the prescribing authority of NDs can be found in the Business and Professions Code sections 3640-3645. To review these provisions, you may access the Laws & Regulations section of the Naturopathic Medicine Committee's website.
