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INM Responds to NIH Requests on Determinants of Whole-person Health and ODS Strategic Planning

Michelle Simon, PhD, ND Michelle Simon, PhD, ND
Quantum University


The Institute for Natural Medicine recently responded to two requests for information from the National Institutes of Health (NIH). The NIH has established a focus on Whole Person – Whole Health for its research initiatives, which we referenced in both of our responses.

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The first request was from the NIH National Center for Complementary and Integrative Health (NIH NCCIH) and was a Request for Information on the Identification of a Set of Determinants for Whole Person Health. Our organization applauds NCCIH and its director, Dr. Helene Langevin, for spearheading a direction for NCCIH that helps prioritize a patient-centric health care treatment paradigm. The second request came from the NIH Office of Dietary Supplements (ODS) and invited comments and suggestions for their strategic plan. We again referenced the NIH focus on Whole Person and Whole health in the submission.

INM’s NCCIH Recommendations

In formulating our response to the NCCIH RFI, INM convened our ND Advisory Council. The council primarily drew upon the work done by the U.S.. Naturopathic Medicine profession in writing a Whole Person Health Determinants of Health (DOH) framework, published in 1998. Refined and expanded versions of the guidance documents are in PubMed (2010, PMCID: PMC2883816) and medical textbooks, including The Textbook of Natural Medicine, 3E, 4E and 5E (2020) and The Scientific Basis of Integrative Health, 3E (2017). The recommendations list from INM included the maximum allowed amount of 20 determinants and grouped them into the following subcategories:

• Innate – encompassing adverse childhood experiences, genetic and epigenetic influences, and resilience.

• How We Live – including spiritual life, meaningful personal life and safe work environments

• Exposure to Nature/Natural Environment – improvements in clean air and water, exposure to natural systems, cycles and green spaces

• Diet, Nutrition, Digestion – access to nutrient-dense, uncontaminated foods

• Rest and Movement – improving the quality of rest, sleep, recreation, mobility and vitality

• Socioeconomic – this vast category includes acceptance of culture and community; overcoming income disparity; inclusive belonging regardless of race, gender, sexual orientation or ethnicity; reducing discrimination; and improving education, access to health care and governmental programs.

We believe this effort will help deliver a whole-person approach to health and wellbeing. As a naturopathic doctor, I could not be more supportive. The white paper we published last year, Naturopathic Physicians – Specialists in Whole Person Health, is a good reference to explain how our profession relies on these determinants as the foundation for the Therapeutic Order approach (see pages 12-14 in the white paper mentioned above). This could also be a model to inform the transformation of our health care system to include naturopathic medicine in conventional health care settings. INM’s Recommendations For ODS Outcomes Research

By building upon our recommendations regarding whole person health determinants, we felt that the ODS could contribute significantly and in measurably important ways to these Whole Person – Whole Health research initiatives.

Outcomes research on integrated, complex systems of the human body, which meets a gold standard, must capture a multivariate approach for treatment. A recognition of the interconnectedness of multiple disciplines is essential. For example, there is good evidence related to specific nutrients for particular ailments, lifestyle medicine, the efficacy of body-mind medicine, etc.

Accordingly, supplement trials for 2022-2026 designed in the context of this whole person perspective will greatly further NIH’s Whole Person – Whole Health research initiatives. If the ODS changes how they study specific nutrients in context with all other nutrients required to address a disease state, it will yield rich, new efficacious results and fill existing knowledge gaps. This is especially important since supplements do not work in isolation; they work in a system that includes internal and external determinants of health. A shift in how the ODS studies natural ingredients is the most significant thing they can do differently as the organization moves forward in the next four years.

Well over 100 years ago, the naturopathic profession evolved from medical doctors who were disenchanted with the way medicine was practiced. Today, the whole-health movement, which is beginning to mirror how NDs practice, is again being joined and led by MDs looking for better patient care. A significant difference between then and now is that we have evidence-based models in naturopathic, integrative and functional medicine, which can help guide the inquiry and development of new, improved, patient-centric, whole-healthcare systems. These are exciting times and full of promise. Naturopathic physicians are ready to participate in the discussion wherever and whenever possible.


www.nccih.nih.gov/grants/request-for-information-rfi-identification-of-a-set-of-determinants-for-whole-person-health. https://casetext.com/federal-register/request-for-information-rfi-inviting-comments-and-suggestions-on-an-ods-strategic-plan.

Fleming SA, Gutknecht NC. Naturopathy and the primary care practice. Prim Care. 2010 Mar;37(1):119-36. doi: 10.1016/j.pop.2009.09.002. PMID: 20189002; PMCID: PMC2883816.

Zeff JA, Snider, P. A Hierarchy of Healing: The Therapeutic Order A Unifying Theory of Naturopathic Medicine. In book: The Textbook of Natural Medicine 4E. 2013 Jan. Elsevier. Editors: Pizzorno J, Murray M. Online at ResearchGate.

Revised and updated Whole Person Health DOH list also in: The Textbook of Natural Medicine 5E. 2020 Jun. Elsevier. Editors: Pizzorno J, Murray M.


Michelle Simon, PhD, ND President & CEO, Institute for Natural Medicine In 1992, the leadership core of naturopathic doctors established the Institute for Natural Medicine (INM) as a not for profit organization dedicated to advancing natural medicine. The purpose of the INM is to increase awareness of, broaden public access to, and encourage research about natural medicine and therapies. Among its milestones the INM counts the launch of the Association of Accredited Naturopathic Medical Colleges (AANMC) as an independent organization, leading California’s efforts to obtain licensure, developing an interactive childhood education program focused on healthy eating and lifestyles called Naturally Well in 2017, and expanding residency access by establishing and funding a residency program in 2018. INM has joined forces with the American Association of Naturopathic Physicians (AANP), serving as the charitable arm, to deepen access to naturopathic care, public education and research. Dr. Michelle Simon serves as president and CEO of INM, is a licensed naturopathic physician, clinician, educator, and leader in many organizations dedicated to improving the quality and delivery of health care. In addition to holding a naturopathic doctorate from Bastyr University, she also holds a PhD in Biomedical Engineering from the University of North Carolina at Chapel Hill. Dr. Simon has served on the boards for the Integrative Healthcare Policy Consortium (IHPC), the AANP and the Naturopathic Physicians Research Institute (NPRI). Dr. Simon also served nine years on the Washington State Health Technology Clinical Committee which is part of the Health Technology Assessment program that examines the scientific evidentiary basis for efficacy, safety and cost effectiveness of health care technologies. She was also an invited participant for health care economics at “Summit on Integrative Medicine and the Health of the Public” at the Institute for Medicine (IOM) in 2009. Dr. Simon was recognized as the 2018 Physician of the Year by the AANP.