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Board advances 2026 sunset report draft, pushes for fictitious-name permits and title protections
Summary
Board staff reviewed a draft 2026 sunset report and recommended several policy requests — including authority to require fictitious‑name permits and stronger title protection — and outlined a timeline for finalizing the report and gathering additional data before November.
Board staff reviewed the draft 2026 sunset report at the Sept. 17 meeting of the California Board of Naturopathic Medicine and asked members to confirm content and prioritize several new issues the board plans to deliver to the Legislature.
Staff member Rebecca told members she had added background, data tables and draft recommended solutions and asked for direction about where to place historical context and technical comparisons of educational training in the report. "I will be adding the fictitious name permit information back in here," Rebecca said, describing a proposal to require licensees who practice under any name other than their legal name to register that name with the board.
Why it matters: staff and board members framed the new items as consumer‑protection measures the Legislature requested during the previous sunset review. The board is seeking statutory authority to require fictitious name permits (to link business names to licensees for enforcement), expanded title protection (to limit use of terms that imply licensed status), authority to direct continuing education, and further consideration of scope items such as a formulary and minor office procedures. Board members also asked staff to add discussion of fiscal impacts tied to the board’s relatively small licensee population.
Major points discussed
- Fictitious-name permit: Rebecca said a fictitious-name permit (FNP) program would require licensees to register business names used for practice and mirror existing programs at the Medical Board of California and the Osteopathic Medical Board. She told members the FNP would allow staff to tie consumer complaints to a named legal entity and to enforce naming and ownership rules.
- Title protection: The draft restates the board’s concern that unlicensed practitioners commonly use medical-sounding titles and that consumer complaints indicate some users believe those practitioners are licensed. The board proposes stronger title protection to improve consumer clarity; one member asked staff to add explicit language noting consumers have complained about the problem.
- Continuing education and scope: Staff noted the board lacks explicit statutory authority to require directed continuing education and recommended adding that as a new issue. Members also asked that the report continue to press formulary and minor office procedures (MOP) items as unresolved public-safety and access issues.
- Enforcement, online practice and unlicensed activity: Staff will add enforcement data showing that a large share of complaints involve unlicensed practice. The draft will also note limited staff ability to track how many licensees generally provide telehealth or maintain websites; enforcement records can, however, identify online unlicensed activity when it is the subject of a complaint.
Data gaps and next steps
Rebecca said several data tables remain in progress (including fiscal tables for FY 2023–24 and enforcement conviction statistics) and proposed issuing a short survey to recent licensees to better understand new-licensee attrition. She told the board she would try to circulate the survey within weeks so results could be considered before the board must finalize the report in November.
Timeline and approvals
Rebecca outlined the final schedule: a working draft will be discussed at the Oct. 8 meeting, a finalized draft will be reviewed at a special Nov. 19 meeting and the board will approve the published report at a Dec. 3 meeting for submission to the Legislature.
Board direction
Members asked staff to: add a succinct historical introduction and place technical education comparisons in the education section; include a sentence in the fictitious-name and title-protection discussion noting consumer complaints; pursue a targeted survey of licensees before the November finalization; and add fiscal‑impact language linking limited scope to budget pressures. Staff agreed to circulate revised sections and requested board review before the October meeting.
Ending: Staff will continue drafting and circulate updated narrative and tables; board members indicated support for the listed new issues and the deadlines to finalize the report for legislative submission.
