1. Purpose

This is a formulary of prescription drugs that may be used by natuaropathic physicians in a manner that is consistent with their scope of practice.

2. Authority

In accordance with 26 VSA A § 4125(c), this formulary has been established by the Commissioner of Health with the advice of the advisor appointees described at 26 VSA A § 4126.

3. A Prohibition

A person licensed under 26 VSA Chapter 81 (Naturopathic Physicians) shall not prescribe, dispense, or administer any controlled substances except those natural medicines authorized by these rules. "Natural medicines" are substances present in or produced by nature, not artificial or man-made.

Licensed naturopathic physicians may only order, prescribe, dispense and administer certain medications of mineral, animal and botanical origin which are:

1. A "Natural" according to the following definition: -present in or produced by nature, not artificial or man made. (Source - American Heritage Dictionary)
2. A Not substances prohibited by other Vermont or federal law.
3. A Appropriate within a general naturopathic practice, that is primary care in focus, recognizing that naturopathic physicians are also specialists in natural medicines and often serve in an adjunctory capacity for other chronic illness.
4. A Prescribed in doses that are non-poisonous accepted therapeutic dosages. This is defined as a dose which by its actions does not impair function or destroy human life, and is consistent with the naturopathic principle - "First Do No Harm."
5. The substance being prescribed is clinically effective for the condition that the patient is seeking health care for. This will require the naturopathic physician to assess if the natural substance, or substances being used in a particular treatment protocol are working for that patient within a safe and reasonable amount of time for that condition. This assessment needs to be made within the context of naturopathic medical philosophy, the conventional standard of care as defined by such groups as the Vermont Program for Quality, and the patient's choice as long as adequate information and education is provided.
1. Drugs That May be Prescribed

The following products may be prescribed by naturopathic Physicians: Routes of administration are usual routes.

PO = By Mouth

IM = Intra Muscular

IV = Intra Venous

SQ = Subcutaneous

Topical = Applied To Skin

1. Amino Acids and Amino Acid Combinations: (Usually PO)

Alanine, Arginine, Aspartic Acid, Cystine, Glutamic Acid, Glycine, Histidine, Hydroxyproline, Isoleucine, Leucine, Levocarnitine, Lysine, Methionine, N-acetyl cysteine, Phenylalanine, Proline, Serine, Threonine, Tryptophan, Valine

2. Antimicrobials - naturally derived - (PO,IM, Topical)
a. Erythomycin
b. Penicillins - Amoxycillin, Ampicillin, Penicillin G, Penicillin VK
c. Tetracycline
d. Anti-fungal agents - Nystatin
3. Barrier Contraceptives
4. Botanical Extracts and their derivatives -

Botanical Medicines as exemplified in traditional botanical and herbal pharmocopea may be utilized by naturopathic physicians, following the above guidelines. The botanicals listed below represent substances that are currently available by prescription only, or they are botanicals that have both prescriptive and non-prescriptive dosage forms available.

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5. Electrolytes - (IV)

Saline, Sodium Bicarbonate, Dextrose injection, Dextrose and Saline, Lactated Ringer's Solution, Ringer's Solution

6. Expectorants and Mucolytics - (PO)

Guaiacol, Iodinated Glycerol

7. Enzyme preparations - (PO, Topical)

Amylase, Chymotrypsin, Lipase, Pancreatin, including Pancrelipase, Papain, Protease, Typsin

8. Homeopathic preparations - all prescription and non-prescription remedies that are manufactured according to the pharmaceutical guidelines set forth in the H.P.U.S. (PO, SQ)
9. Hormones - (PO, IM, Topical)
a. Adrenal - e.g., adrenal extract, cortisol, DHEA, pregnenolone
b. Gonadal - for hormone replacement purposes, does not include oral contraceptive pills or anabolic steriods
1. Estrogens - conjugated estrogens, estradiol, ethinyl estradiol, etriol, estrogens, esterified, estrone, estropipate, quinestrol
2. Progesterone
3. Testosterone
c. Thymus
d. Thyroid - preparation as defined in the USP
e. Melatonin
10. Liver Preparations - (PO, IM)
11. Minerals - (PO/Topical/IM/IV) for example: calcium compounds, calcium folinate, fluoride compounds, iodine (including potassium iodine, niacinmide hydroiodide), iron compounds, magnesium compound, potassium compounds, silver nitrate, trace mineral compounds (chromium, selenium, molybdenum, banadium, boron)
12. Miscellaneous - (PO, SQ, IM, IV, Topical)
a. Digestive aids - betaine and glutamic hydrochloric acid (non RX)
b. Biological agents - urea
c. Bile salts and Acids - Chenodiol, Cholic Acid, Chenodeoxycholic acid, Dehycrocholic acid, Ox Bile, Ursodeoxycholic acid, Ursodiol
d. DMSO, Hyaluronidase, Grain Alcohol
e. Epinephrine - (SQ)
f. Glutathione, Reduced Glutathione - (IV or PO)
g. Oxygen
13. Vaccines/Toxoids - to be used consistent with Vermont Health Department Recommendations - (IM, PO)
14. Vitamins - All prescriptions and non-prescription vitamin preparations and their deratives -(PO/IM/IV, Topical)

Vitamin A, Betacarotene and Derivatives

Thiamin (Vitamine B1)

Riboflavin (Vitamine B2)

Niacin (Vitamine B3)

Pantothenic Acid including dexpanthenol (Vitamine B5)

Pyridoxine (Vitamine B6)

Cyanocobalamin or hydroxycobalamin (Vitamine B12), including intrinsic factor

Folic Acid


Ascorbic Acid (Vitamin C)

Vitamin D (including calcitrol, calcifediol, ergocalciferol)

Vitamin E

Vitamin K (including menadiol)

15. Topical Medicines
a. Debridement/escharotic agents - Urea Cream 40%
b. Miscellaneous topical agents - Cantharidin, Capsaicin, DMSO, Selenium Sulfide 2.5%, Retin A, Hydrocortisone 1%, mineral salts such as copper sulfate to be used for iontophoresis
c. Topical antibiotics - Silver sulfadiazine cream, colloidal silver preparations
d. Scabicides and Pediculosides - Lindane, Permethrin or whichever agent is the current recommended treatment for these infections
2. Drugs That May be Used but Not Prescribed

The following products may be purchased or otherwise obtained by naturopathic physicians in any dosage form for appropriate use, but may not be prescribed:

A. Diagnostic Agents

Cobalt (57Co)



Lactulose/Mannitol Solution



B. In Vivo Diagnostic Biologicals

Tuberculin Tests

Diptheria Toxin



Candida and Trichophyton Extracts

Mumps skin test antigen

Skin test antigens, multiple

C. Topical Medicines

Podophyllum Resin 25%

Podofilox 0.5% Solution

Topical anethetics and local anasthetics as described in the USP.


This formulary will be reviewed and revised on an annual basis.


04-381 Code Vt. R. 04-030-381-X

July 7, 1998 (Secretary of State Rule Log #98-41)
March 24, 2000 (Secretary of State Rule Log #00-15); June 14, 2017 [transferred from Agency of Human Services, Department of Health by operation of law]


26 V.S.A. § 4125

State regulations are updated quarterly; we currently have two versions available. Below is a comparison between our most recent version and the prior quarterly release. More comparison features will be added as we have more versions to compare.

No prior version found.