January 3, 2020
ICA Opposes Attempts to Expand Doctors of Chiropractic Scope of Practice to Include the Prescribing of Dangerous Drugs and Administration of Natural Substances Under Certain Circumstances
The principle concern of the International Chiropractors Association (ICA) is the risk to public safety related to an expansion of scope of practice that would allow doctors of chiropractic to ‘administer’ (via injection) dangerous ‘articles of natural origin’ (that currently require a medical prescription).
The ICA has three primary concerns:
1. The inherent risks to patients
2. Misleading language being promoted to state legislatures.
3. Substandard educational programs being used to promote new prescribing rights for chiropractors.
Background: In recent years there have been increasing attempts in state legislatures to modify state laws to allow doctors of chiropractic to “administer articles of natural origin” and to authorize licensed pharmacist “to fill such chiropractors orders for articles of natural origin.” Examples of natural substances described in at least one pending bill states that doctors of chiropractic who have completed continuing education courses may, “store, possess, prescribe, and administer articles of natural origin, including vitamins, minerals, amino acids, fatty acids, hyaluronic acid, enzymes, saline, anti-oxidants, dextrose, glandulars, cellular components, extracts, water, botanicals, phytonutrients, and homeopathics.”
Misleading Language: The terminology being presented to legislators by those promoting these changes are misleading. Three terms are particularly problematic – ‘administration’, ‘chiropractic orders’ and ‘of natural origin’:
- The phrase “of natural origin” is not a regulatory term per se. Articles of natural origin range from opium, amniotic fluid being marketed by some as a stem cell treatment, dextrose, as well as vitamins and minerals. If taken orally, many of the products ‘of natural origin such as vitamins, botanicals, minerals, dextrose, and water fall into federal food and dietary supplement regulations overseen by the US Food and Drug Administration (FDA) and do not require a prescription or a pharmacist to dispense. Many homeopathic oral remedies are available ‘over the counter’ as well. Homeopathic medicines fall into a unique regulatory category at the FDA. Prescribed homeopathic medicines are a complex and highly specialized field separate from chiropractic, for which a few hours online or in a continuing education program would be inadequate to address the nuances of prescribing non-OTC homeopathic remedies.
- The term ‘chiropractic orders’ is simply a term for a medical prescription written by a Doctor of Chiropractic. Any “natural substance” that is not available “over the counter” and can only be obtained from a pharmacist is, by definition, “a dangerous drug”.
- The term ‘administration’ is so broad that it also includes injectable products. The route of ‘administration’ determines the level of regulation applied at the federal level. By federal food and drug law, any product including products of natural origin that do not require a prescription for the oral product, become prescription drugs if they are administered by needle or IV. The term administration can be interpreted by regulators to include not only topical application, and oral administration, but also administration by injection (needle or IV).
Examples of products that can be sold with and without a prescription or ‘chiropractic order’:
- Water is a perfect example. Water to drink does not require a prescription. Products that contain water and are administered topically such as saline contact lens solutions are regulated by the FDA as over the counter (OTC) drugs. Products containing water (such as Saline) that are administered through a needle including IVs are regulated by the FDA as prescription drugs. They require a prescription. This regulatory status is critical to the establishment and management of quality control measures in manufacturing and distribution including of compounded pharmaceuticals. Compounded substances of natural origin produced without stringent FDA oversight have resulted in serious adverse outcomes for patients. Six months ago, the FDA created a Compounding Risk Alert Website noting there have been serious adverse events and deaths.(https://www.fda.gov/drugs/human-drug-compounding/compounding-risk-alerts)
- Dextrose tables are common OTC products used by individuals with Type 1 diabetes when blood sugar levels become dangerously low. Dextrose that is delivered via a needle (injected or by IV) is a prescription drug.
Substandard Training: The Council on Chiropractic Education (CCE) is the recognized accrediting body for the chiropractic profession. Special medical training, including lengthy and intensive medical residency programs, are normally required in order to be granted the authority to write prescriptions for dangerous drugs including substances of natural origin that will be delivered via injection. At present, there are no CCE accredited chiropractic educational programs that provide this very specialized training. ICA opposes a scope of practice expansion of something as potentially harmful as drug prescribing and injecting based on any educational program not accredited by CCE nor tested for by the National Board of Chiropractic Examiners.
Risk to Patients: Authorizing new medical procedures not included in the regular curricula of CCE accredited chiropractic programs poses a danger to the public.
ICA also opposes extending the scope of practice of chiropractors to grant prescribing rights or to administer invasive techniques such as injections in any manner that circumvents the responsibility of the appropriate Medical and Pharmacy Boards to ensure the safety of the public.
The Mission of the International Chiropractors Association (ICA) is to protect and promote chiropractic throughout the world as a distinct health care profession predicated upon its unique philosophy, science, and art of subluxation detection and correction.
Contact: Beth Clay, Acting Executive Director at firstname.lastname@example.org.