Michael Um, ND: The Second Naturopath at the Nature Medicine Clinic — 18-Month Suspension, $189,993 in Costs, and a Texas “Church” Contract That Bought Him Nothing

Michael Um practised alongside Michael Prytula at the same St. Catharines clinic for more than twenty years, ran the same website, and offered the same treatments — oncothermia, IV chelation, ozone, photodynamic and UV light therapy for cancer. He also relied on the same defence: that a private membership contract with a Texas organisation called the Pastoral Medical Association placed his patients, and their records, beyond the reach of the College of Naturopaths of Ontario. A discipline panel rejected that argument in November 2024, suspended him for eighteen months in 2025, and the Divisional Court dismissed his appeal in April 2026.

How the investigation began: a complaint about vaccine information

The case that ended with an eighteen-month suspension did not start with an injured patient. It started with a complaint the College received about vaccine content on the Nature Medicine Clinic website.

While looking into that complaint, the College's Inquiries, Complaints and Reports Committee found other things on the same website that worried it, and flagged them to professional conduct staff, who alerted the College's CEO and Registrar, Andrew Parr. Parr had staff capture screenshots of the site, reviewed them, and on September 23, 2019 wrote a 94-page memo to the ICRC setting out his grounds for believing that Um had committed acts of professional misconduct. The ICRC approved the appointment of investigators, and an Appointment of Investigator was issued on October 7, 2019 to the firm Benard and Associates.

Two things on the website in particular drew Parr's attention. The first was that the clinic advertised ozone and chelation therapy to people who wanted to “prevent against cancer” — which, he testified, plays on fear and encourages treatment in people who have never been diagnosed with anything. The second was that the site told visitors that if they joined the Pastoral Medical Association, their records would be protected from what the site called prying government eyes, and that any complaint about the clinic's services should go to the PMA rather than to the College.

The Pastoral Medical Association workaround

The PMA is a voluntary membership organisation based in Texas. It is not a health regulatory college, it has no legal standing in Ontario, and it does not regulate naturopaths anywhere in Canada. Both Um and Prytula had been members since roughly 2015 — the year the College of Naturopaths of Ontario came into existence and the current scope-of-practice rules took effect.

Um's position, which he maintained throughout the hearing, was that PMA membership authorised him to administer treatments and perform controlled acts that a naturopath in Ontario is not permitted to perform; that people who signed the PMA agreement were “private members” rather than patients; and that as private members their files were not reachable by the College or the Ministry of Health.

The panel dealt with this in a paragraph that is worth reading twice, because it is the whole case:

Membership in the PMA does not relieve a registrant of the obligation to comply with Ontario law when offering naturopathic services. It does not matter that some clients were also PMA members — a College registrant remains bound not to provide treatment outside the scope of practice, and cannot sign away that obligation by contract. That, the panel wrote, is simply not how professional regulation works in the province.

Paraphrased from the panel's findings, DC22-05, November 14, 2024

There is one further wrinkle worth noting, because it is the only route by which a religious framing could have worked. Section 27(1) of the Regulated Health Professions Act does allow an unauthorised person to perform a controlled act while treating someone by prayer or spiritual means, in accordance with the tenets of their religion. The panel expressly considered it. It found there was some material suggesting the PMA is a Christian organisation, but no evidence at all that any treatment given at the clinic was provided by prayer or involved any spiritual element. The exemption did not apply because nothing spiritual was actually happening — oncothermia and 10-pass ozone are not prayer.

The undercover appointment, March 3, 2020

Stefanie Blacker, an investigator with Benard and Associates, attended the clinic on March 3, 2020 under the alias “Stefanie Barrett,” accompanied by a colleague posing as her husband. She audio-recorded the appointment. She told Um she was interested in IV therapy for general malaise.

According to her evidence, Um told her he offers IV chelation and recommends it to all his patients for optimal health, and that it was something they could consider at the end of her treatment plan. When she asked about platelet-rich plasma for wrinkles, he told her PRP could help. He recommended starting with trigger point injections before prolotherapy, and recommended B12 injections. If prolotherapy were needed, he said, his colleague Dr. Prytula would perform it.

Two things he did not say, on her evidence: that he was not authorised to provide chelation, PRP or trigger point injections; and that she would need to join the PMA to receive any of it. So whatever the PMA agreement was doing in theory, a member of the public who walked in off the street was simply offered the treatments.

What Um admitted

Um denied that any of it amounted to professional misconduct. But he admitted most of the underlying conduct, and his admissions are the backbone of the finding. Under Ontario Regulation 168/15, a naturopath may only inject substances listed in Table 2, and may only compound substances listed in Table 5. Neither table includes ozone, oxygen, blood, plasma, or EDTA and its salts.

He also conceded that naturopaths are not allowed to treat cancer, that it is outside the scope of the profession, and that the College has approved no formal training for it. What he would not concede was that the clinic's website said otherwise.

“Killing cancer cells”

The Notice of Hearing alleged the clinic advertised that its practitioners could treat cancer, HIV and AIDS, could cure cancer or kill cancer cells, and could achieve “complete cancer resolution.” Um's answer was that the exact words used did not literally promise a treatment or a cure.

The panel had the website in front of it, along with everything linked from it, and did not accept the distinction. It found the language — and it singled out “killing cancer cells” — unclear, confusing and capable of misleading the public. Prytula, testifying in Um's defence, offered a version of the same distinction: the clinic does not treat cancer, he said, but does treat “the mechanisms that cause cancer.”

The search warrant

On August 6, 2020, investigator Dean Benard attended the clinic with the Appointment of Investigator and summonses for both Um and Prytula. Um was at the clinic that day, seeing patients, and did not come out to meet him. He later testified that he did not understand why he needed to speak to Benard and trusted his colleague to handle it.

Prytula handled it by refusing to produce the treatment records of PMA members, on the basis that they were not patient records and that the request was government overreach. Benard left Um's summonses with Prytula, who agreed to pass them on. Prytula later denied ever receiving them.

Because the records were not produced, Benard applied for and obtained a search warrant, executed at the clinic on August 19, 2020 with two police officers present to keep the peace. Um was not there. Prytula was outside gardening; he initially refused entry, then unlocked the door after being told a locksmith would otherwise be called. The College's witnesses said the search then proceeded smoothly and professionally. Prytula testified that Benard had threatened him with arrest and was aggressive; a recorded interview with one of the attending police officers, conducted by Um's own counsel, did not support that.

Even after the warrant, records were still missing. The complete PMA agreement was not produced to the College until 2024 — by Um's legal representative, after the matter had already been referred to the Discipline Committee.

Six motions, none successful

Um brought four motions at the merits stage, all dismissed on November 14, 2024:

• Section 8 Charter (unreasonable search): The panel found the warrant was properly requested under s. 77 of the Health Professions Procedural Code, properly issued by a Justice of the Peace who was told what the documents were and why the registrants had refused them, and reasonably executed.
• “Ultra vires” appointment of investigator: Um argued that because Parr's memo used qualifying words like “may have,” he had not formed the required belief. The panel read the 94-page memo, found it stated in terms that Parr believed on reasonable and probable grounds that misconduct had occurred, and noted that Parr's careful hedging elsewhere was precisely because findings are for the Discipline Committee, not the Registrar.
• Section 11 Charter and abuse of process: Um argued that the possibility of a fine payable to the Minister of Finance amounted to a “true penal consequence” under R. v. Wigglesworth, so he was a person charged with an offence. The panel found s. 11 does not apply to discipline hearings: a registrant is not charged with an offence, the proceedings are not criminal, and a professional penalty exists to secure compliance within the profession, not to redress a wrong to society at large. On delay, it found that much of it was caused by his own failure to cooperate.
• Section 7 Charter (vagueness): Rejected. The panel noted that practising a regulated health profession in Ontario is a privilege, not a right, and that no s. 7 interest was engaged by the wording of a Notice of Hearing.

After the finding, and before penalty, he brought two more. The first alleged a reasonable apprehension of bias — in part because the panel chair had once said he could not immediately recall a point of testimony from the previous day, and in larger part because Um's representative noticed that the reasons closely resembled those released in Prytula's case a week earlier.

The panel's answer to that is the most interesting passage in the penalty decision. It confirmed it had never seen the Prytula decision before receiving a copy on this very motion. The overlap had a much simpler explanation: the two men worked at the same clinic, were jointly responsible for the same website, faced nearly identical allegations, were represented by the same paralegal, who brought virtually the same motions in both proceedings, and were prosecuted by the same College counsel making the same responses. Prytula testified at both hearings, as did Parr and Benard. Similar submissions in, similar reasons out.

The second motion asked that the decision be declared a nullity for excess of jurisdiction; the panel found it simply re-argued points already decided, and dismissed it.

The penalty, and what makes it unusual

The College asked for a reprimand, an eighteen-month suspension, extensive terms, conditions and limitations, and two-thirds of its costs. Um's paralegal declined to make submissions on penalty at all, telling the panel that he could not defend the case because he did not know what the decision meant, and that the only appropriate remedy was recusal of the panel. He asked instead that the College pay Um's costs on the basis that the prosecution had been unwarranted — a request the panel found difficult to reconcile with having just found misconduct proven.

The panel granted the College's order in full. Beyond the suspension and reprimand, the terms include:

• Indefinite limits confining him to substances and routes actually listed in Tables 1 and 2, and drugs listed in Tables 3 to 6, of the General Regulation; and barring him from recommending any product not approved by Health Canada for patient use.
• Public signage. He must post a notice — in the waiting room, in every examination and treatment room, and on his professional website — stating that he is not authorised to administer substances by injection other than those in Table 2. Every patient he treats or offers to treat must sign a form confirming they have been told the same thing.
• Remedial work within twelve months: the PROBE ethics course, passed unconditionally; the College's jurisprudence course; a documented review of every standard he was found to have breached; and meetings with a College-selected regulatory expert who must report on whether he has actually developed insight.
• A practice monitor after the suspension ends, inspecting his clinic, his website and his client charts on a rolling basis, indefinitely, until the College is satisfied the restrictions are no longer needed.
• A letter to every PMA client. This is the unusual one. He must write, in terms the College approves, to all of his clients who were PMA members, telling them that he was wrong to say the College could not access their records, wrong to say the PMA agreement authorised the services they received, that he has been found to have committed professional misconduct, and that neither he nor the clinic will provide those services going forward.

That last term is the point of the whole case. The PMA arrangement worked, to the extent it worked at all, because patients were told a story about who was watching. The order requires him to go back and untell it.

The appeal

Um and Prytula appealed together to the Divisional Court. Their appeals were heard on February 11, 2026 before Regional Senior Justice Newton and Justices Backhouse and Matheson, and dismissed in reasons released April 24, 2026 — on every ground, with $12,500 in costs against each of them. Prytula's revocation and Um's suspension both stand.

Why both files belong here

It would be easy to read Um's case as the junior partner's version of Prytula's. The two files came out of one investigation, one clinic and one website, and the paper trail overlaps almost completely. But the outcomes diverged sharply, and the reason is instructive.

Prytula was revoked. The panel in his case found him ungovernable, and pointed to a warning history running back through 2002, 2008 and 2019 — including the Letter of Caution that came out of Dr. Terry Polevoy's own 2006 complaint to the Board of Directors of Drugless Therapy – Naturopathy, which the College cited as an aggravating factor. Um had no comparable history. He made admissions at the hearing, which the panel treated as mitigating, and he received a suspension with a route back.

What the two files share is the underlying theory: that a private contract with an out-of-province organisation can carve a licensed practitioner out of the regulatory system he belongs to. Two separate panels and a three-judge Divisional Court bench have now said it cannot. That is the useful precedent, and it applies well beyond St. Catharines — PMA-style “private membership association” agreements are marketed to practitioners across North America on exactly this promise.