Naturopathic medicine sits in an unusual legal spot. In some states a naturopathic doctor holds a full medical license with a fingerprint based criminal history check behind it. In other states the title carries no license at all. A clinic, hospital system or integrative health practice that wants to hire or credential a naturopathic doctor has to figure out which world it is in before it can decide what a background check should even cover.
Which states actually license naturopathic doctors
About two dozen states and the District of Columbia have a licensing law for naturopathic doctors or naturopathic physicians, each administered by its own medical board, health department, or professional licensing office. Where a state has adopted a licensing law, that state’s board is the primary source for scope of practice, continuing education, and any criminal history or fingerprint requirement. Where no licensing law exists, there is no state board process for this title, and an employer should not assume one exists just because neighboring states have one.
State board fingerprint and background check rules
The three rules below come directly from each state’s licensing board. They are not identical, and an employer verifying a candidate’s history should read the specific state’s current page rather than assume the pattern carries over.
| State | Licensing authority | Background check method | Source |
|---|---|---|---|
| Washington | Washington State Department of Health | Background check processed for every applicant; DOH may require a fingerprint based check through the Washington State Patrol and the FBI | doh.wa.gov |
| Oregon | Oregon Board of Naturopathic Medicine | National criminal record check under state statute and rule, completed through a fingerprint appointment with a state contracted vendor before initial licensure or licensure by reciprocity | oregon.gov/obnm |
| California | California Board of Naturopathic Medicine | Fingerprinting required of all licensure applicants, submitted through the state’s Live Scan program | naturopathic.ca.gov |
In Washington, the Department of Health states that a background check is processed for every applicant and that the agency will contact an applicant directly if a fingerprint based state and FBI check is required, as described on the Department of Health naturopathic physician application page. Oregon’s board requires a national criminal record check for both initial licensure and licensure by reciprocity, scheduled through a fingerprint vendor before the applicant sits for the jurisprudence exam, per the Oregon Board of Naturopathic Medicine applicant page. California directs every naturopathic doctor applicant to complete fingerprinting through the state’s Live Scan system, as explained on the California Board of Naturopathic Medicine Live Scan page.
What this means for a hiring clinic
None of these state processes substitute for an employer’s own screening. A state board background check confirms the person was eligible to be licensed at the time of licensure. It does not tell a clinic whether a candidate has a more recent arrest, a different jurisdiction’s record, or a motor vehicle issue relevant to a driving role. Clinics generally still order their own consumer report in addition to confirming the license is active and in good standing with the applicable state board.
States without a naturopathic licensing law
Where a state has not enacted a naturopathic licensing law, there is no state board fingerprint or criminal history process tied to this title, because there is no licensing board to run one. Rules on who may use the title “doctor” or practice medicine without a license vary by state and are set in each state’s medical practice act, so an employer in an unlicensed state should check that state’s own law rather than assume a national rule, and should not represent to applicants or the public that a license exists where it does not.
NPDB queries for naturopathic practitioners
The National Practitioner Data Bank is a federal data bank that collects reports on medical malpractice payments and certain adverse licensure and clinical privileges actions against health care practitioners. Access is limited to eligible entities defined in federal regulation, such as hospitals, health plans, and state licensing boards, not to every employer. The query and reporting framework is set out in the Health Care Quality Improvement Act regulations at 45 CFR Part 60, and the data bank’s own guidance on registration and eligibility is on the National Practitioner Data Bank site. A clinic that is itself an eligible entity, or that works through a hospital credentialing office that is, may query the data bank as part of credentialing a naturopathic doctor; a typical employer running a pre-hire background check generally is not an eligible querying entity on its own.
OIG exclusion screening for naturopathic providers who bill
A naturopathic doctor who bills Medicare, Medicaid, or another federal health program, or who works for a practice that does, is generally subject to exclusion screening against the Department of Health and Human Services Office of Inspector General’s List of Excluded Individuals and Entities. Federal law bars excluded individuals from working in any capacity for a provider that bills federal health programs, and payment made for items or services they furnished can expose the employer to civil monetary penalties. Background on the exclusion authority and the list itself is available from the HHS Office of Inspector General exclusions program. Practices that bill commercial insurance rather than federal programs should check their own payer contracts, since some private payers require the same screening by contract even where federal law does not reach the arrangement directly.
What a clinic or employer typically verifies
| Check | Purpose | Who generally runs it |
|---|---|---|
| State license verification | Confirms the naturopathic doctor is currently licensed and in good standing in a licensing state | Employer, using the state board’s public license lookup |
| Criminal history background check | Reviews county, state, and federal criminal records for the individual, separate from any state board check at licensure | Employer, through a consumer reporting agency |
| NPDB query | Surfaces reportable malpractice payments and certain adverse actions | Eligible entities only, such as hospitals and health plans |
| OIG and SAM exclusion check | Confirms the individual is not barred from billing federal health programs | Employer or billing practice, before and during employment |
FCRA basics for employers ordering the check
When a clinic or staffing agency orders a background check on a naturopathic doctor candidate through a consumer reporting agency, the Fair Credit Reporting Act and its implementing rule, Regulation V, set out the employer’s duties. Generally the employer must give the applicant a clear, standalone disclosure that a background check will be obtained, get the applicant’s written authorization, and, if the employer may take an adverse action based on what the report shows, send a pre-adverse action notice with a copy of the report and a summary of the applicant’s rights before any final decision, followed by an adverse action notice if the employer proceeds. These obligations are described in the Consumer Financial Protection Bureau’s guidance on Regulation V and the Fair Credit Reporting Act. A background check does not show the same things in every state, and whether an older record appears at all can depend on state law, so employers should not assume a report will or will not contain a given record.
Reveal Background works with employers and health care organizations to build FCRA compliant screening programs that fit licensed and credentialed roles. Learn more at Reveal Background.
For related screening questions, see our guides on acupuncturist license background checks and healthcare exclusion screening against the OIG LEIE and SAM lists.
Frequently asked questions
Do all states require a background check to become a licensed naturopathic doctor?
No. Only states that license naturopathic doctors require a background check as part of licensure, and the process varies by state. States without a naturopathic licensing law do not have a state board background check tied to this title.
What kind of background check do naturopathic doctor applicants go through?
In licensing states, applicants typically submit fingerprints for a state and FBI criminal history check through the state board or a state designated vendor, as Washington, Oregon, and California each describe on their own board pages.
Can a clinic check the NPDB for a naturopathic doctor?
Only entities that qualify as eligible NPDB users under federal regulation, such as hospitals, health plans, and state licensing boards, may query the data bank, and only for reportable adverse actions or malpractice payments.
Why would a clinic run an OIG exclusion check on a naturopathic provider?
If the provider will bill Medicare, Medicaid, or another federal health program, confirming the person is not on the OIG List of Excluded Individuals and Entities helps the clinic avoid civil monetary penalty exposure.
What happens if a state does not license naturopathic doctors?
In states without a naturopathic licensing law, there is generally no state board background check tied to the title, and employers typically rely on a standard consumer background check plus whatever title restrictions exist under that state’s own law.
What FCRA steps must an employer follow before running a background check on a naturopathic doctor candidate?
Generally an employer must provide a standalone disclosure, get written authorization, and, if it may take an adverse action based on the report, send a pre-adverse action notice with the report and a summary of rights before deciding, followed by an adverse action notice if it proceeds.
This article is general information, not legal advice. State and federal rules change, and employers should confirm current requirements with the applicable state board and their own counsel before making a hiring decision.
