Dear Minister,

The ANPA is very supportive of both the government guidance relating to the crisis and the positive actions taken by the Australian people in following best practice to mitigate the impact of the virus.  However, the current restrictions in Victoria, and specifically Melbourne, have raised some queries from naturopathic practitioners.

We thank the Premier and DHHS for the guidelines on who may continue to operate included medical and allied health practitioners.  The current Stage 4 Industries – Distribution guidelines issues with the Premiers statement on business restrictions (DHHS, 2020) state that “…Community based services which are based on a referral from a registered medical practitioner (General practitioner and/or medical specialist). This includes all clinical and allied health services…

As there is no single universally accepted definition of allied health services (AHS), but rather a variety of accepted professions that may differ between various states and departments, this leaves many practitioners unsure of their position.  Naturopathic practitioners are currently self-regulated through their professional associations, rather than AHPRA, and naturopathic services are utilised by a large proportion of the population.

There is general agreement on some basic principles of what constitutes AHS: health professionals that are not part of the medical, dental or nursing professions. They are university qualified practitioners with specialised expertise in preventing, diagnosing and treating a range of conditions and illnesses. Allied health practitioners often work within a multidisciplinary health team to provide specialised support for different patient needs (AHPA, 2017).

In reference to the state guidelines I suggest that naturopathic practitioners fulfill the necessary criteria to continue practice as AHS:

  1. there are no restrictions in residents seeking healthcare,
  2. medical/specialist practitioners can (and do) refer to naturopathic practitioners, and
  3. naturopaths are included in the ‘all allied health services’ clause based on the generally accepted definition of AHS.

I feel it is important to reiterate a key focus of naturopathic practice is preventative health measures, such as dietary and stress management strategies tailored to an individual, that provide a strong foundation for improved individual health, but also reduce the future burden on the medical system – a system that is generally at or near capacity, let alone during a pandemic.  The ANPA feels that by supporting practitioners in this essential task, we are not only supporting the individuals directly consulting naturopathic practitioners, but also the wider circle of their families, friends, co-workers and even their tangential medical community, whose efforts can be focused on the needs of acute patients.  The last few months have shown that many people will delay or avoid seeking medical treatment for what are perceived as less important issues, even when delaying care may exacerbate underlying or chronic health conditions, but would feel more comfortable attending a naturopathic practitioner.

The ANPA is strongly urging practitioners to consult remotely where possible and take all necessary safety precautions to protect themselves, their patients and their community where remote consulting is not possible.

We would like clarification on the following points:

  1. Are naturopathic practitioners considered AHS in Victoria?
  2. Are any modalities of their practice excluded? 

Naturopathic practitioners have long fulfilled a need in societies worldwide for a flexible model of care that is gentle and patient focused – Australia is no different and we urge the department to support this important health care option.

Kind regards,


Marta Browne

BSc (Micro/Para) BA (Psych) GradDip (Psych) Dip (Mgt) AdvDip (Nat) CD

ANPA President