From Elizabeth Porter to the Oregon Cannabis Commission
Thank you for the opportunity to comment. I wanted to be present at this meeting, but due to my involvement with recovery efforts from Hurricane Florence in coastal NC, I am unable to present my comments personally. Please accept them in writing.
I have been an OMMP (Oregon Medical Marijuana Program) patient for five years. I previously lived and worked in a prohibition state where I feared for my safety acquiring or using this plant, so I am very grateful to the people and government of Oregon for the opportunity to have safe access to medical cannabis. That said, safe access comes at an unnecessarily high social and economic cost, and this hurts the public health and the economy of Oregon, and it hurts patients. More patient focused, balanced policies would fix these problems.
From my perspective, I am at a disadvantage as an OMMP patient because I have not been able to grow cannabis for myself. That has put me at the mercy of growers and retailers to acquire cannabis medicine. If I relied only on retail purchases, the quantity of medicine I need would be cost prohibitive. If I relied only on the kindness and generosity of growers, I’d have an unreliable and sometimes less effective source of medicine (since patients are usually gifted what cannot be sold). Neither solution takes us to where the citizens of Oregon voted this program: to treat cannabis as a medicine.
OMMP seems more like a law enforcement program than a public health program. This is further reason to leave the program. From the OMMP web: “The Oregon Medical Marijuana Program administers the cardholder registry for medical marijuana patients.” There is scant little, if any, information to be found that is either public health oriented or medical for patients. Cannabis is now available to all Oregon adults over-the-counter, anonymously – and without annual fees or reporting on a registry, so there is unnecessary bureaucracy in in the OMMP that punishes patients and is a deterrent for participation. If the tax and other savings do not exceed the costs to certify and register, it makes no sense participating even if my use is clearly medically warranted. Unless possibly if there were other program benefits that justified the costs.
What would I expect to see in a public health cannabis program that is patient focused? Some basic community/ecosystem outcome indicator data, an easy way / portal to report adverse events, and community resources for patient support and civil rights advocacy. A patient focused program should have a more holistic approach to public health, where cannabis can be assessed for benefits and not just potential risks. If we are recognizing cannabis as a medical therapy, we should fund and evaluate its use as part of a health “system”, and not just collect the federally funded negative indicators, such as product diversion and teen use.
Program optics also matter. It appears, when I look at the OMMP web site, that cannabis commerce is more important than patient health to the OMMP, when residency restrictions are reversed for individuals involved in cannabis commerce but are not removed for out of state patients who wish to seek treatment in Oregon. This should change. The state should also have reciprocity with other state medical cannabis programs.
It also makes no sense and diminishes program credibility when cannabis, now available over-the-counter, must be controlled by physicians-only to qualify for “medical access”. This is not a good use of physicians in Oregon. In Lane County, the majority of citizens get their primary care from nurse practitioners or other non-allopathic providers. It’s plainly disingenuous, and not public health oriented, to claim that only allopathic/osteopathic (MDs and DOs) physician providers can make a professional assessment on behalf of their patients concerning cannabis, when other clinicians routinely administer other, more medically risky, healthcare interventions. Consequently, most patients are forced to visit a once-a-year ‘medical’ clinic to get their medical cannabis permission slip signed. That charade diminishes the credibility of the program. I’m a glaucoma patient. My eye doctor is a Doctor of Optometry with post-doctoral training in glaucoma management, who has managed my eye care for over ten years, and who actually recommended I use cannabis (when I developed severe adverse reactions to the conventional medications). However, since he is not an MD or DO he cannot sign my annual medical use permission slip. So I pay for a visit to a “clinic” so an allopathic physician without any specialized training in glaucoma or without the equipment needed to assess the condition can sign my form. Again, that diminishes the credibility of the program. That should change. The physician is not needed to verify that the patient has a qualifying condition and to review pertinent medical history for conditions that would contraindicate use. In fact, medical records clerks, who prepare and review healthcare claims for the healthcare and insurance industry, have the requisite skills to verify this information from medical chart notes. Use of allopathic/osteopathic (MD and DOs) physicians to sign off on these tasks is wasteful and unnecessary.
For someone (like me) who pays the full registration price every year and does not have a designated grower, there are few advantages to participating in the OMMP moving forward. Previously, one small advantage, the ability to negotiate and purchase larger quantities of cannabis for a discount with retailers, ended with the newly enacted one ounce daily purchase restrictions. This new restriction further cripples the state medical program. There are too many restrictions placed on the medical program that appear to be aimed at dismantling the program and not enhancing public health. There should be less red tape and easy ways for patients to directly acquire cannabis from OMMP and OLCC licensed growers. It adds unnecessarily to the cost of the cannabis when it has to be transferred from an OLCC grower to a retailer to donate the product to patients. With the surplus product in the system, there should be an incentive to remove tested product out of the cannabis tracking system to transfer to patients easily and without added red tape. This would be mutually beneficial for patients and growers / producers.
I also seriously urge the OMMP to address the issue of continued stigma against medical cannabis patients. There are more adverse public health effects from the stigma associated with medical cannabis use than with the biochemical effects of the plant. I believe research will corroborate my assertion. Social stigma influences the delivery of medical care, and this is evident in the OMMP. Perhaps the most obvious stigma perpetuated is related to the lack of medical parity in addressing mental health conditions. Here’s the proverbial “elephant in the room”: The most frequently used reason for cannabis use is for stress and anxiety. However, a patient with an anxiety disorder (other than PTSD, which is treated as a distinct “veterans” disorder not related to other anxiety disorders) cannot participate in OMMP. This is wrong. There are a myriad of mental health conditions that could be treated with cannabis; and I see stigma not science, as the barrier to use.
I also see a serious problem trying to superimpose the reductionist (single molecule, controlled dosage) paternalistic, medical paradigm to therapeutic use of cannabis. Part of the therapeutic value of cannabis is in its anthropological roots in the use of botanical medicine: the variable sensory experience, the botanical variability, and the consumption of the substance in a supportive, therapeutic social setting – the very things that are criticized for the substance being “unmedical” may actually increase the substance’s therapeutic value. For that reason, I am skeptical that parking the program with allopathic medicine is the right place for it. That’s why I see the medical advice of finding the right strain for me as shear folly. The variability is part of the solution. I also strongly encourage lifting the ban and allowing social use for medical patients.
Although my reason for joining the OMMP as a patient was in addressing my glaucoma when conventional medicines failed, it has allowed me to substitute cannabis for a variety of other allopathic medications prescribed for other chronic health conditions I have. As a 60+ year old, I am on no other medications now, whereas I took multiple daily medications before using medical cannabis. I would like to be able to realize the savings to my health insurance plan and be able to choose the best medicine for my health, not just the medicine covered by my plan. At the very least, cannabis as medicine should be an affordable and non-stigmatized alternative to allopathy.
If the OMMP can work on behalf of program participants, supporting research and outcome studies and facilitating, rather than impeding safe access, this would be a reason for continued participation. I would also strongly recommend the state establish a type of investigational new drug program similar to the federal compassionate use program to help remove the stigma and institutional problems related to the conflict in state-federal scheduling, and the loss of civil rights state cannabis patients face when choosing this therapy. This protection would keep me participating in the OMMP.
Testimonial provided by Elizabeth Porter to the Oregon Cannabis Connection. Posted by special permission.