I understand the difficulty of differentiating between the protection of rights for medical cannabis patients and the I-502 mandates. Here are my particular concerns with, and reasons why I oppose, HB 2149:
1- Throughout the bill, the scientific term "cannabis" has been reverted back to "marijuana". This is an unnecessary switch back to a more inflammatory term. Since this bill, if part or all of it becomes law, is the basis for legal action, the proper scientific terms should be used. Anything else is specious.
2- Section 2.12.b. As the members of the committee with healthcare backgrounds who sponsored the bill know, there are currently NO objective measures of pain.Pain is, by its very nature, a subjective complaint. Internet research shows a single preliminary study from the Neurology department of the University of Boulder, using nMRI technology to map neuronal response to pain, but there have been no confirmatory studies to date and to ask all pain patients seeking cannabis authorizations to submit to nMRI, especially when many of them are living off of disability checks or are working poor, based on a single study is unconscionable.
Requiring that the severity of the pain significantly interfere with ADLs is an unnecessary phrase, given the current terminology of intractable pain and does not allow for relief for current patients who have relapsing or intermittent pain issues that are intractable; debilitating migraines would be a good example. They do not affect patients on a daily basis, but when they happen, patients can be sidelined for 1-4 days, unable to work, keep food down, or tolerate light, sounds, or smells.
Requiring referrals from principal care providers (as the recent amendment states) does not take into account the fact that some doctors do not believe in the use of medical cannabis and would deny their patients' requests for a referral. In many cases, such as with the VA or with larger medical groups, like UW Physicians, the PolyClinic, or MultiCare facilities, doctors are forbidden to write authorizations by their employers or their malpractice providers, on penalty of losing their jobs or their insurance coverage.
3- Section 2.12.g- Eliminating the panel of physicians who accept or deny petitions for new conditions as more research becomes available would put undue strain on patients and advocates in terms of time and money. The current panel is relatively conservative, in my opinion, but is surely a better way than requiring legislative amendments or disallowing new conditions.
4-My strong opposition to the sections creating a registry come in light of recent court findings in Mendocino County, Ca and in OR, where the DEA was allowed access to the cannabis registry.Other states with registries have been compromised and patient information has been unlawfully exposed. My concerns about patient privacy and HIPAA regulations have been voiced by many during the public comment period. A patient has an authorization on tamper-proof paper, etc in compliance with state law, and that should be all the "verification" that a state-licensed outlet should require. Currently, when a patient of mine goes to a dispensary, I am called to verify the authenticity of the authorization, including its expiration date (typically one year, in some instances 6 months). There are standard HIPAA procedures for releases of information to other healthcare providers in place now. If two providers are concurrently working with a patient, releases are not even required to discuss patient care. The issue lies in patients' discomfort in disclosing to some providers, not in the lack of access to available information.
5- Section 5.2 - Limitations are too low. Severe epilepsy patients may use more than 8 ounces in a week or so. Requiring a physician to attest to being the primary care professional treating the patient- Many patients come to me as part of their healthcare team. I encourage them to tell their primary care doctor, their oncologist, their rheumatologist, or any other specialists about their cannabis authorization. At the present date, there are 3 major drug interactions indicated for cannabis (theoretical, according to Rxlist.com). While I do a medication and supplement review at each visit and discuss potential interactions with patients, many other primary care providers (PCPs) don't do this because they do not have the time or training.
For many of these patients, they would be candidates for the higher levels of possession proposed but their primary care professionals will not write authorizations. For others, their PCP is not the one handling the opiate. chemotherapeutic or other medications, it is a specialist such as an oncologist or pain doctor. Where is the burden of proof that cannabis requires more stringent oversight than these medications?
Home growing- Many of my patients come from rural parts of the state, where patient access points are few and of poorer quality than seen in the cities. Other patients live on a severely fixed income, often times less than $1000/month. These patients typically qualify for my sliding fee scale at the $20/visit level because their income is so low. They need the ability to grow their own plants because it is cost-prohibitive for them to afford their medication through dispensaries at today's prices, not to mention the proposed increases in costs via state-run recreational outlets.By lowering the plants from 15 to 3, it is ensured that any trouble with the growing process will wipe out a patient's medication supply easily.
6- Section 11- While I approve of the idea of a working group to create standards of care for physician guidance, particularly one that includes professionals with actual botanical medicine training (naturopathic physicians),what we currently know about cannabis is that different people react to different amounts, preparations, and strains of the plant so a standard dosing schedule would be very difficult to determine. My typical recommendation for patients in this area is to begin dosing in the evening, or when there will be no chance for them to be impaired behind the wheel, in order to find an effective dose for them, while minimizing any impact on their lives during the process.
Thank you for reading my concerns. I am happy to answer any questions by you in person, or via phone or email. I strongly believe that feedback from physicians is sorely lacking in HB 2149 and oppose its passage.
About me: I am a 4th generation Washingtonian, in the second generation to make a career in healthcare. I have family who have served in the armed forces and those who currently serve in law enforcement. I have over 25 years' experience working with children and families, studied botanical medicine for five years as part of my naturopathic doctorate studies, and have extra training in drug-herb interactions. My volunteer activities include working with the Sea-King County Public Health Reserve Corps, the Red Cross, the Make-a-Wish Foundation, my local Rotary and Chamber of Commerce chapters, and serving on the board of the Ballard Boys & Girls Club. In short, I believe that I am fulfilling my calling to serve families in my community and to practice responsible medicine. Part of my family practice includes writing cannabis authorizations for eligible patients of all ages, in accordance with state law.