About the standard
CPSA issued the Cannabis for Medical Purposes (CMP) standard of practice in April of 2014, due to a need to provide physicians with direction on the use of cannabis for medical purposes, to ensure public safety and to provide a means of monitoring the authorization of cannabis for medical purposes.
The standard required physicians to register with CPSA as “authorizers” and submit a Patient Medical Document for each authorization. These documents are manually tracked for CPSA’s Cannabis for Medical Purposes program, using TPP Alberta infrastructure. As cannabis does not have a DIN, the information must be collected separately and is not included in Alberta Netcare, Pharmaceutical Information Network (PIN).
CPSA receives approximately 6,000 authorizations (Patient Medical Documents) per month. The manual entry of this data is resource-intensive and the cost of monitoring medical cannabis is significant (Resources and statistics memorandum).
CPSA has not had any requests for this data from external sources apart from two research requests, and has had one intervention using authorization information for patients under 18 years of age.
Since legalization of recreational cannabis in 2018, there has been a downward trend in the number of authorizations. Health Canada data indicates this number decreased in Alberta from 110,189 in October 2018 to 63,359 in June 2020.
Health Canada provides a quarterly report for any physician authorizations over 25 grams per day of cannabis, for patients who grow their own CMP. This may be useful information for monitoring purposes. Review of this information does not indicate inappropriate or unsafe authorizations.
Changes in the draft
- Remove the requirement for physician authorizers to submit a Patient Medical Document, while noting Health Canada’s requirements for submission have not changed.
- Discontinue CPSA’s monitoring of cannabis for medical purposes.
- Continue to require physicians to notify the Cannabis for Medical Purposes program before beginning to authorize medical cannabis, which will allow us to provide physicians with educational resources and updates on CMP.
- Retain the requirements for:
- documentation of evaluation
- risk assessment
- informed consent
- review of prescription database
- compliance with provincial and federal regulations
- retaining copy of medical document
- Modify re-evaluation frequency to at least once every six months to reduce barriers to access.
- Clarified expectations regarding authorizing for patients without a longitudinal treating relationship or direct communication with a primary care provider who has a longitudinal treating relationship with the patient
- Retain prohibitions on:
- dispensing or providing cannabis to any patient or person
- applying to become a licensed producer
- accepting incentives or rebates for providing authorizations
- charging patients or licensed producers for activities associated with authorizing medical cannabis
Explore the changes in the draft standard even further
Your opinion matters
Any changes to CPSA Standards of Practice impact your day-to-day practice. Your input is vital to ensuring the standards strike an appropriate balance between serving patient needs and setting reasonable expectations for your medical practice.
This consultation closed March 17, 2021, thank you for your participation and feedback. Once amendments are finalized and approved by CPSA Council, physicians will be notified and made aware of any new expectations via The Messenger newsletter.
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All feedback is subject to the CPSA’s Privacy Statement. CPSA reviews all comments before publication to ensure there is no offensive language, personal attacks or unsubstantiated allegations.
CPSA members, partner organizations, other health care professionals and Albertans were invited to provide feedback from Feb. 16-March 17, 2021. Council will consider non-nominal feedback when approving final amendments to the standard this spring.
Feedback on Consultation 020
Inhaled cannabis is the most common form in which patients are using it. This is very damaging to the respiratory system. CPSA should look at longer-term harm as they set the policies. All practitioners planning to prescribe cannabis should be required to take a course on the effects to the respiratory system. Carcinogens abound (not any safer than cigarettes). Vaped forms have even more harmful concerns.
As a Respirologist, I do believe that inhaled cannabis use (for medical or other) should be banned from any CPSA licensed practitioner.
It seems mostly straightforward and reasonable. I do have two considerations I'd like to raise.
1. I believe that the efforts to "avoid negative connotations" are sometimes too strenuous in documents such as this, such that the actual meaning (denotation) is actually lost or distorted. For example, instead of "misuse or abuse" the phrasing for "emerging substance use disorder" has been substituted. This really isn't the same thing and actually risks conflating episodic behavior and a diagnosable medical condition. (You can probably only call something like this "emerging" in a retrospective fashion, anyway. It's like trying to time the stock market - a fool's errand).
It is possible to be "too woke." If you'll allow me to provide an admittedly digressive example, there is a movement (in the UK, at least) to re-define "breast milk" as "human milk" or "chest milk." Of course, we all know that the breast and chest are actually different things, that men actually DO have breasts (albeit usually underdeveloped ones), and that this (i.e. "breastedness") literally is one of the major things that defines homo sapiens as belonging to the mammal class of the animal kingdom.
2. Other than that, my main (and more relevant) concern with the general climate in cannabinoid prescribing is that society and patients increasingly seem to view this as a panacea. Discussions with respect to "evidence-based indications" for therapeutic choices do not go well when "their other doctors" apparently had no problem with giving them what they wanted.
I sense that both of my opinions are probably minority positions now, so I'll leave it at that.
I do have concerns that we are "loosening" regulations for our physician members. Regular users of cannabis has an addiction potential of close to 10% in the whole population and even higher in "at risk' individuals. There is evidence that the liberal use of opioids for chronic pain has contributed to the opioid crisis when we "allowed' physicians to prescribe without oversite. The co occurring "addiction" prevalence of chronic opioid users can be as high as 25%. I would object to extend the follow up period to 6 months. Constant follow up is needed to look for developing addiction and I have seen too many cases of physicians ''just prescribing' and allowing use of 3 gms a day which in my opinion is NOT evidence based and with a high rate of "addiction" in these individuals and they will need to be identified early.
Thank you so much for allowing us to put our feedback in here. These are absolutely a big positive change and relief especially the 6 months period for patients reassessment instead of every 3 months. I am happy with these changes.
I would welcome the change , if I have a long term relationship with the patient and the prescription is valid for a year, is it still neccessary to continue 6 monthly follow ups if the cannabis is helping and the dose does not change. In my view, compliant patient for whom the dose does not need to be adjusted, would one a yearly consultation not be appropriate ?
I believe the current trend will continue, given the difference of price between the medically prescribed cannabis and the over the counter product that is commercialized and sold by the same companies that are registered for medical marihuana. It is hard to understand why so many regulations are in place to prescribe marihuana medically, so many checks and balances when it is so difficult to kill someone with marihuana. However a regular prescription let a patient acquire opioids in a middle of an escalating epidemic of opioids use and death by their use.
These two elements are the main ones that have to be considered going forward.
I fully support the above changes. I found in my practice, once recreational cannabis was legalized and also when my patient population realized that authorized use did not equate to having drug plan coverage, the requests for medical marijuana went from about 20 per day to 1 per month. There is little value in monitoring the authorization of medical use in an environment where every corner supplies recreational cannabis and there is no penalty for people to grow their own at home. People nation wide are deciding for themselves which medical indication cannabis works for, and how much to use.
While I agree with the suggested changes, it does seem strange that this is required any longer, while cannabis products are not paid for through healthcare insurance.