Bastyr University’s MPH and MPH/ND programs should not be accredited
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The motto of the American Public Health Association is “For science. For action. For health.” Accreditation of a Master of Public Health (MPH) and a combined Master of Public Health/Naturopathic Doctor (MPH/ND) program at Bastyr University would make a mockery of that axiom.

Bastyr University’s application for accreditation of its MPH and MPH/ND programs has been accepted by the Council on Education for Public Health (CEPH), the accrediting agency recognized by the U.S. Department of Education for public health education schools and programs. (The CEPH is the successor to the American Public Health Association’s original accreditation program.) A site visit is scheduled on January 6, 2022, and the anticipated decision date on the application is “TBD 2022”, per the CEPH website.

According to my recent telephone conversation with a CEPH rep, the scheduling of a site visit means that CEPH is fairly confident that accreditation will be granted and the sooner public comments on the application are submitted, the better, so the CEPH can take them into account when making a final decision. (I did not mention a particular school in my inquiry.)

In my opinion, granting accreditation to a Bastyr MPH or MPH/ND program would give undue luster to a school that specializes in the teaching of pseudoscience and concomitantly dilute the value of an MPH degree from an accredited school. After all, if a school teaching, say, that humans are channeled with “meridians” funneling “energy” about their bodies can have an accredited MPH program, what does that say about the validity of accreditation everywhere?

Before we go further, however, a word about accreditation of schools in the U.S., which, unlike quality-control schema in other countries, is not actually run by the government. The Department of Education has basically farmed that task out to private accreditation agencies which, if not managed in the public interest, can create a fox-guarding-the-henhouse situation.

Most importantly for our purposes here, in granting authority to these private agencies, one criteria wholly absent from the qualifications is that education be science-based. This means that, once an accrediting agency is approved, the schools it oversees are free to teach all the pseudoscience they want as long as their accrediting agency is simpatico.

Nothing in the CEPH guidelines, of course, suggests the agency is tolerant of pseudoscience. In fact, its accreditation criteria requires that programs ensure its graduates “are grounded in public health knowledge” and “can discuss the science of . . . prevention in population health”, among other science-related criteria. The same cannot be said, however, of Bastyr’s accreditation by the Council on Naturopathic Medical Education or the Accreditation Commission for Acupuncture and Oriental Medicine. Thus, to the extent CEPH is relying on accreditation by those agencies to ensure that MPH students would find themselves in a suitably science-based institution, it shouldn’t.

Nor should the fact that naturopathic doctors are licensed in some states be treated as an indication of their scientific legitimacy. Legislation is all-too-often political, not evidence-based, as demonstrated by legislative attempts to mandate the teaching of creationism and to require doctors to perform medically unnecessary procedures prior to performing abortions. Such is the case with naturopathic licensing.

Bastyr rejects science and evidence

With that, let’s turn back to the reasons for denying accreditation to Bastyr’s MPH and MPH/ND programs.

Bastyr University is a private alternative medicine school in Washington offering degrees in naturopathy, acupuncture and Chinese medicine, among others. Bastyr’s curriculum is not entirely evidence-based and, in some cases, not even compatible with basic scientific principles, including chemistry and physics. This matters because, in my view, the public health profession cannot stand with one foot in science and one foot in pseudoscience without its credibility being destroyed. Public health must be grounded wholly in the acceptance of the scientific method and its fruits, and an institution that rejects the scientific method cannot remain true to the principles underlying public health.

A few examples from Bastyr’s curriculum should suffice to illustrate the school’s rejection of science and evidence.

Bastyr’s acupuncture and traditional Chinese medicine programs purport to draw on “both traditional Chinese medicine and biomedical concepts” incorporating “Eastern and Western healing traditions”. In other words, the body of scientific knowledge underlying medicine is reduced to just another “concept” or “healing tradition” which can be accepted or rejected in favor of the pseudoscience of acupuncture and TCM.

Bastyr’s acupuncture and TCM course descriptions illustrate the extent to which so-called “Western medicine” is put on equal footing with the pseudoscientific concepts. Thus, in anatomy, students are taught “Western anatomy and acupuncture energetic anatomy”, which are “bridged in this course”, and “anatomical connections to acupuncture point location” (Course BC4102). Students learn, as factual, that the body contains meridian channels and 365 acupoints (AM5100), “tongue and pulse” diagnosis (AM 7402), and the “TCM empirical model of pathophysiology of health disharmonies according to Zang Fu and [“meridian”] channel theories” and the “etiology, signs and symptoms, and patterns that create disease” per TCM. (AM5203). It is worth noting that the photos on Bastyr’s website illustrating its acupuncture program show needles being inserted without regard to basic sterile technique (i.e., the use of gloves).

Bastyr also offers courses (and, formerly, a Masters Program and certificate) in ayurvedic “science”. Ayurveda is a pre-scientific belief system originating in India based on concepts of human functioning and claims of health benefit that are unsupported by basic science or evidence of effectiveness.  Yet, according to a paper presented by the head of the ayurvedic program at Bastyr (and posted on Bastyr’s website), ayurveda will “cure and remove illness and disease of Ill people” and will “prevent disease”.

The rejection of science at Bastyr is further illustrated by its naturopathy curriculum, which, for example, includes five separate homeopathy courses as well as clinical education in homeopathy. (The homeopathy department is headed by a ND who holds an appointment as an associate dean at Bastyr.)

Homeopathy is quackery. The overwhelming scientific consensus is that homeopathy is highly implausible, unsupported by scientific evidence, ineffective in treating illness and, when relied upon instead of actual medicine, dangerous and even deadly. The FDA has acknowledged that all homeopathic remedies on the market today are there in violation of the FD&C Act because they lack the legally required FDA pre-market review for safety and efficacy. (At the present time, the FDA is exercising its enforcement discretion and targeting only homeopathic remedies raising certain safety concerns.)

Thus, Bastyr is currently teaching students a thoroughly discredited method of diagnosis and treatment using a product that is illegal under federal law.

Over half of Bastyr’s faculty have degrees in “alternative medicine”, such as naturopathy, acupuncture, and chiropractic. Only a handful have PhD, MD, or MPH degrees. Bastyr’s Research Institute reports only three currently ongoing studies and only two published studies in the last decade.

There is no critic of Bastyr more informed than Britt Hermes, a former licensed ND who graduated from Bastyr in 2011. Britt left naturopathic practice when she caught another ND using an illegal cancer drug on patients and

began scrutinizing my education and training at Bastyr University. What I learned is frightening.

Since then, Britt has become a whistleblower whose writing (including her own blog and posts on SBM) and media appearances have exposed the bogus claims made by alternative medicine practitioners and the dangerous therapies used by naturopathic doctors, including those to treat cancer. For this, she won the John Maddox Prize, a joint initiative of the charity Sense about Science and the journal Nature, recognizing her championing of science in the face of hostility and legal threats. (One legal threat came from Bastyr University itself, apparently upset regarding her revelations about her education there.) She is currently a PhD student in evolutionary biology at the University of Kiel.

Britt describes naturopathic education as

riddled with pseudoscience, debunked medical theories, and experimental medical practices. . . . After breaking down the clinical training hours and assessing the quality of the medical training, I believe the quantity and quality of the training provided by Bastyr University is scant, lacks the application of medical standards of care, and includes pseudoscientific diagnostic methods and treatments of real and fake diseases. . . . To the best of my memory [in clinical training at Bastyr], I was rarely asked about the medical standard of care for a diagnosis and treatment plan. The treatments offered to patients were usually abundant and seemed like a toss-up. . . . Of the hours that Bastyr provided to me and my classmates in purported primary care training (748 hours), one quarter of this time was spent in case preview and review. The remaining 75% (561 hours) contained dubious diagnostics and experimental treatments that were so embedded within a pseudo-scientific and pseudo-medical practice that the student clinician loses the ability to assess what is truth and what is make-believe. When homeopathic remedies are presented on the same level as antibiotic treatment, the naturopathic student is lost, and I don’t blame them.

She adds, in another post:

Pre-clinical coursework at accredited naturopathic programs is also not so rigorous or science-based, though on paper ND credit hours match an MD or DO program. Indeed, naturopathic programs teach classes with the same titles as those in medical schools. Naturopathic classes, including basic sciences courses, are almost entirely taught by other naturopaths or other practitioners of alternative medicine, such as doctors of naprapathy. The pediatrics courses assign reading from anti-vaccine authors, like Bob Sears, and overall the reading load seems quite low for what would be expected from MD and DO students.

The accredited naturopathic curriculum also includes a large amount of pure pseudoscience, with the most glaring examples being three quarters spent on homeopathy . . .

In addressing students who ask her whether they should go to naturopathic school (The answer? No.) Britt tells them:

Accredited naturopathic schools are disguising the naturopathic education of nonsense as a distinct, and better, form of primary care medicine. Sadly, these schools are getting away with what I consider to be education fraud. The truth is that naturopathic education is riddled with pseudoscience, debunked theories, and experimental medical practices.

Given immunization’s vital role in public health and the concern about vaccine hesitancy, Britt’s experiences in “the fatally flawed pediatric training that NDs receive in their accredited programs” are particularly concerning. In her elective pediatrics clinical shift:

I didn’t see any newborns. We talked to parents about what supplements to take in order to “boost the immune system.” We counseled about alternative vaccine schedules and didn’t actually give out vaccines. What kind of primary care training is this? . . .

It should be appalling for anyone to see Dana Ullman’s Homeopathy for Children and Infants and Dr. Bob Sears’s The Vaccine Book, not once, but twice in the [pediatrics course reading] list! All of my syllabi for the Bastyr pediatrics courses included these texts.

While the pediatrics courses discussed vaccines and official immunization schedules, this was always in the context of stirring controversy. Take, for example, the following class note I made about counseling parents on alternative vaccine schedules:

When discussing vaccination with parents these questions need to be discussed separately: Which ones to give? When to give chosen immunizations? How many doses are recommended? Advise parents to ask the following questions in order to assist them in making the choice to vaccinate or to refuse to vaccinate: What is the seriousness of the disease? What is the risk of getting the disease? How easy is the disease to treat? What is the risk of vaccinating for the disease? How do vaccines affect our immune systems? How does exposure to childhood disease affect our immune systems? What is the general health of my child? What will my child be exposed to? If my child were to get sick because we didn’t vaccinate him how would we feel? If my child were to get sick from a vaccine how would we feel?

Naturopathic students are essentially trained in alternative vaccines schedules, which lead parents to not vaccinate. If this isn’t smoking gun proof that naturopaths are anti-vaccine to the core, then what is? I noticed that missing from my notes are discussions about how to advocate for the official vaccination schedule and alleviate parental fear of toxins, for example.

An archived page from Bastyr’s teaching clinic website falsely claims that influenza vaccines weaken the immune system and that the vaccine isn’t recommended if you are healthy. Included among the many homeopathic remedies listed on an archived page from the clinic’s dispensary are fake homeopathic vaccines (including a fake “MMR” vaccine) and homeopathic nosodes like Influenzinum.

Specifically regarding homeopathy, Britt reveals:

When I was in school at Bastyr University, my naturopathic instructors would often tell students stories about the miraculous healing powers of homeopathy, even in life and death situations. There were presented cases of severely depressed patients taking Aurum, a remedy made from gold, who were cured of their suicidal ideations. I remember stories using homeopathy to treat acute asthma attacks as students, we were also taught keep our own homeopathic first-aid kits at home, and Bastyr in June 2017, wrote “Homeopathy could be a great solution for your natural first aid kit for summer.”

Naturopathy is not compatible with public health

In addition to an accredited MPH program, Bastyr is seeking accreditation of a combined MPH/ND program. Given naturopathy’s hostility to vaccination and science-based practice, there exists an inherent tension between it and public health. In my view, this would require either that naturopathy unqualifiedly reject its foundation in pseudoscience (highly unlikely) or that public health accommodate naturopathy’s junk science (hopefully unlikely) for the two to co-exist in one program.

To augment the disturbing information about naturopathy specific to Bastyr already exposed in this post, a few additional observations about naturopathic practice in general are in order.

First, naturopathy’s antipathy to vaccination is well documented. Studies of naturopathic students indicate that their support for vaccination decreases with each year of education. Naturopathic care is associated with fewer vaccinations and increased likelihood of vaccine-preventable disease: in one Ontario naturopathic practice just under 9% of the pediatric patients were unvaccinated and, in a survey of Massachusetts homeopaths and naturopaths, most did not recommend vaccination. Naturopathic anti-vaccination rhetoric was more recently documented in this journal article.

NDs’ use of unconventional therapies, including lightly-regulated compounded drugs, can be dangerous, especially when they venture into serious diseases like cancer. In 2019, the FDA issued a proposed rule rejecting eleven substances nominated by the American Association of Naturopathic Physicians (AANP, the ND equivalent of the AMA) for use in drug compounding, including curcumin and cesium chloride. Curcumin was the active ingredient in an intravenous infusion that killed the patient of a California-licensed naturopathic doctor and Bastyr graduate, who administered it to his patient for eczema. Cesium chloride is a dangerous and ineffective naturopathic cancer treatment, previously the subject of an FDA safety alert. If finalized, which seems highly likely considering the solid science behind it, the rule will, thankfully, prohibit the use of these and other substances in compounded drugs. Yet, the AANP is fighting the FDA’s decision with a Citizen’s Petition and, potentially, a lawsuit, despite the fact that the evidence it presented in support of its nominations was soundly rejected by the FDA’s panel of experts.

Most recently, NDs have been taken to task for their unproven COVID-19 nostrums. Both the AANP and the California Association of Naturopathic Doctors have been promoting the unproven COVID-19 therapeutic, IV Vitamin C, despite the Australian Government’s recent safety alert finding “no robust scientific evidence to support the usage of this vitamin in the management of COVID-19”.

Because applications for accreditation are not available to the general public, I have no idea what representations Bastyr University made in its application, although I doubt the information in this post is included. The CEPH normally works with applicant programs that are part of the mainstream American college and university system and it is understandably unfamiliar with the alternative universe of schools with alternative medicine programs. It should proceed very cautiously in this arena and do its own research. In the end, I hope the CEPH will agree that an educational institution that won’t commit to science and evidence cannot co-exist with a profession whose commitment to science and evidence is at the heart of its protection of public health.

I will be submitting a comment to the CEPH and hope those of you who are concerned about public health will do the same. As well, if you know others who might be interested, especially those who are in the public health field or hold public health degrees, it would be valuable to pass this information on and ask that they consider commenting as well. According to my telephone conversion with the CEPH, comments can be submitted by email to [email protected].

The mailing address is: Council on Education for Public Health, 1010 Wayne Ave., Suite 220, Silver Spring, MD 20910.

For further information on submitting comments, the CEPH telephone number is (202) 789-1050. (There is a “Complaint Procedure” that covers both accredited and applicant schools, but based on the information I got by telephone, and on reading the complaint procedure, it does not appear to apply to general comments of this nature on a school’s application.)

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