So we read the Legislative Review of the Cannabis Act: Final Report of the Expert Panel, and the section on medical access is page 66 if you are interested in reading
. Most of the recommendations were reasonable, but we are just going to write about what we would do versus a commentary and we will acknowledge our HUGE bias we have as we are pharmacists. We also know there are huge potential economic impacts to certain LPs, and to the federal and provincial governments. So we may make it all sound easy and simple, we understand how certain parties may not wish to see these changes.
By the way – Europe, Israel and Australia – medical cannabis is via pharmacies. Not that they have executed it perfectly, but the model has been established outside of North America.
1 – Allow pharmacies to carry or be a pickup site for medical cannabis.
It is mind boggling that this was never an option day one – even before the Cannabis Act. Who has more experience with controlled drugs, reconciliation and distribution? The current option of mail delivery of a physician office only is to limiting. Some patients have no doctor, do not live even close to their doctor, and some patients do not want to be stuck at home waiting for couriers, or then go to the post office/depot to sign and pick-up their order. This is such a simple fix. Allow pharmacies to either carry products in the pharmacy regularly (many may not – space/odour), or at least allow cannabis into their pharmaceutical distribution chains to allow 24-48 hour delivery to the pharmacy for the patient. Medical cannabis being picked up with their other prescribed medications reduces unfair stigmas. Simple. Every patient’s options are met with this addition.
We also feel their is an improved health outcome aspect for patients to get their cannabis at the pharmacy, beside having a truly complete medication profile and drug interaction checking. It creates and opportunity to for patients to ask questions, speak to health care professionals about any health or drug related problems – cannabis, pharmaceuticals, or illicit substances. Personal interactions are always an opportunity for both the patient and the health care professional to learn more about each other, and discuss how to achieve the patient’s health goals. Remember, budtenders are not allowed to answer cannabis, health questions, and nor should they – they are not licensed health care providers.
2 – Allow pharmacies to compound with cannabis and have higher limits.
In Canada, the debate goes on with THC limit in the adult recreational space, and many patients claim they need significantly higher dosing than allowed in the recreational space. If a patient truly needs a special ratio, or a dose of a cannabis product, allow the pharmacies to compound patient specific product, under prescribers orders, which is in their scope of practice, or at least be able to receive these high dose, high risk products from producers, and dispense them in well labelled and safe packaging for the receiving patient. The public remains safe, and patients have access to therapeutic dosing under the supervision of the pharmacist and prescriber.
3 – Mirror cannabis prescribing requirements to other pharmaceutical prescriptions or controlled substance.
The special “medical document” required for cannabis is overkill in so many ways, and also not very useful in others. Prescribers should require no other requirements to prescribe cannabis as they would for a cholesterol medication or opiate. Keep it simple. However there needs to be some improvement over just grams per day. Perhaps that may be okay for dried flower, but the dried flower equivalents format by Health Canada makes no sense either. For oral/topical products, and a THC/CBD dose, or limit, and put directions on the product – i.e. CBD 50 mg TID – three times a day. Just tossing patients out to the world with 2 or 3 grams per day medical allowances is too all over the place. Just be a bit more specific. Example:
Take 5mg THC po (oral) TID , 25 mg CBD po (oral) TID. Apply 0.3%THC:0.3%CBD Cannabis Cream QID (four times a day)to knee. May use 0.5 grams dried flower up to three times a day as needed for breakthrough pain. May use 20 inhalations of THC vape per day. Some sort of guidance. If they want to restrict to a strain or a brand, that is up to the prescriber and patient.
We do think there should be some ability for pharmacists to prescribe cannabis as well. Cannabinoids are safer substitutes for many sleeping medications and pain medications. Pharmacist’s are the most accessible healthcare practitioner, and are drug experts. If the patient can go to recreational market, why can’t a pharmacist prescribe the product?
4 – Medical Cannabis should have no HST. (Excise ideally too)
No other prescription has HST applied. This is a simple solution. Cannabis under medical access has no HST applied. Easily monitored and tracked via pharmacies now. The reason we said excise ideally, is we realize the government does require revenue from the cannabis space. In a perfect world, all medications are free. That is just not reality, and the Canadian government has a massive deficit. We would take the 13-15% HST savings, or a small reduction of excise (ON/AB/SASK – additional tax removal) as a compromise. Just trying to be a bit realistic. But yes, it would be fantastic to just drop excise duty from medical cannabis – ethically it should be, but realistically, we just do not see it happening.
5 – Maintain Medical Cannabis Growing and Direct LP Medical Channels Service.
Our goal is to augment the current medical access program to make it more flexible, and keep patient’s choices and rights maintained. We support home growing and designated growing, but we would suggest not a limit to the grow license, perhaps just a better reporting method to ensure home growing of product is going where it belongs – to patients only. Also, many LPs sell medically direct to patients are already, so if patient’s want to maintain that process, let it continue. Adding pharmacy access points does not mean, close other routes.
Final Issues
These seem simple enough ideas but there are a lot of moving parts. Do pharmacies stock product, or order direct from LPs or provincial distributors (i.e. OCS), or does it enter the pharmacy distribution system that is already established for controlled drug storage and shipping. Do pharmacies have the space? Who is paying the excise duty? The LP? The Distributor? The pharmacy? Doe pharmacies need excise stamps? This is all besides he federal/provincial act and regulation changes that need governmental approval.
We do not expect changes fast, even if the government were tomorrow to agree with the changes above. The implementation of these processes is quite large in itself. We opened Optimus Cannabis because we wanted to be able to provide patients with education and access to medical cannabis for their health gaols. For now in Canada, this is the only way.