July 2018 - Volume 15 - Issue 1 | Monday July 16, 2018

“Your Patient’s Pain Management and Low-THC Cannabis — Where to Start”

I recently had the opportunity to attend the South Florida Medical Cannabis Symposium for Physicians, presented by Canna Holding, along with physicians, attorneys, patient advocates and other healthcare practitioners around the state. The symposium was a great educational session designed to give an initial understanding, centered around education, of the endocannabinoid system, pain relief using cannabis, legal, and other physician concerns around cannabis. I spoke to several attendees who had an interest but did not know where to start.

Here are a few actions I would suggest to get started:
1. Florida Department of Health Compassionate Use Site - This is the starting point to understand the framework to get started. http://www.floridahealth.gov/programs-and-services/office-of-compassionate-use/index.html. There is a section specifically for physicians.
2. Active Physician License
a. Unrestricted License as a Physician- per Florida Statue Chapter 458 or
b. Osteopathic Physician per Florida Statue Chapter 459
3. Compassionate Medical Cannabis CME Course- This is a required prerequisite before getting authorized, and just because you take the class does not guarantee getting a license. You can access it at http://www.flcannabisce.com/. There is a fee to take the class and at the time of writing it was $995.
After you meet those basic guidelines and get approved then you have to follow several legal requirements, as stated on the Compassionate Use site:
• Physicians may only order low-THC or medical cannabis for a patient if he or she has treated that patient during the immediate preceding three months.
• Physicians must determine that the risks of treating the patient with low-THC or medical cannabis are reasonable in light of the potential benefit to the patient.
• If a patient is younger than 18 years of age, a second physician must concur with the low-THC or medical cannabis order, and such determination must be documented in the patient’s medical record.
• An ordering physician must maintain a patient treatment plan that includes the dose, route of administration, planned duration, and monitoring of the patient’s symptoms and other indicators of tolerance or reaction to the order for low-THC or medical cannabis. The physician must submit a patient treatment plan for each patient quarterly to the University of Florida College Of Pharmacy, or any time the plan changes.
• An ordering physician must enter an order of low-THC or medical cannabis for the named patient into the Compassionate Use Patient Registry, and update the registry to reflect the contents of the order. The physician must update the registry within days after any change is made to the original order and must deactivate the patient’s registration when treatment is discontinued.
• A physician may not order more than a 45-day supply of low-THC or medical cannabis for a patient.
Once you have considered all of this, you can’t forget to have written policy and procedures along with training for you and your team. It is important to ensure you have a compliance framework in place, just like you see for hospitals or other practices.
Document, document, document! Did I mention you should document what you are doing? The cannabis industry is heavily regulated and it is so important to have good document controls in place. When a risk event happens, you want to be able to provide any records or documents in minutes and not hours. If you are still keeping track of policies and procedures with paper and binders, it’s time to move towards the great digital divide.
To help make the move, consider an online document management platform. One that I use and recommend to clients is PowerDMS.com. It’s been successfully implemented by over 300 entities in Florida alone, over 200 of which are law enforcement who use it for their policy, procedure and training management. This is a solution that will give you peace of mind with its version control, audit capabilities, and overall control of your documents.

TGunther Group focuses on compliance and assists businesses with putting together a compliance framework with the use of technology and processes. You can reach out to Tim Gunther by email, tim@tgunthergroup.com.

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