Tuesday, April 3, 2018

CMMNJ's Regulatory and Legislative Recommendations

Regulatory and Legislative Recommendations for the
New Jersey Medicinal Marijuana Program (MMP)

Regulatory Recommendations:

1. Allow any New Jersey licensed physician with prescription privileges to recommend medical marijuana;
2. Make the Physician Registry voluntary, to serve as a patient resource, not as a requirement for physician participation in the MMP;
3. Add to the MMP the 43 petitions that were recommended be approved by the Department of Health (DOH) Review Panel;
4. Allow additional qualifying conditions to be decided in the privacy of the prescriber-patient relationship;
5. Mandate education on the Endocannabinoid System for all healthcare professionals in NJ who have prescription privileges, based on anticipated expansion of qualifying conditions for marijuana therapy, and on anticipated legalization of adult use;
6. Have the DOH develop complete dosing and administration guidelines for standardized medical marijuana products (including information on expected effects, side effects, adverse effects, etc.); See: “Medicinal cannabis: Rational guidelines for dosing” https://pdfs.semanticscholar.org/582a/efb5bfa326fdba0affc23e343151e02aa903.pdf
7. Allow edible medical marijuana products for qualified patients in all state institutions to improve care and reduce healthcare costs--allow institutional physicians to recommend, and nurses to administer, medical marijuana after appropriate training and then conduct case studies on patients receiving treatment;
8. Reschedule/deschedule marijuana in NJ (Director of Division of Consumer Affairs, Office of Attorney General);
9. Eliminate fee for caregiver ID card;
10. Evaluate effectiveness of mandated policies and procedures for the administration of medical marijuana at schools and facilities for the developmentally disabled throughout NJ, modify the policies as necessary, and extend these policies to include colleges and universities in NJ;
11. Eliminate the requirement for psychiatric clearance for minors and require only one MD to recommend medical marijuana for minors;
12. Cancel the 7% tax on medical marijuana which is in violation of the New Jersey Division of Taxation’s Technical Bulletin issued 2/16/10 that notes, “Effective October 1, 2005, all drugs for human use, including prescribed drugs and over-the-counter drugs are exempt from sales and use tax.”  http://www.state.nj.us/treasury/taxation/pdf/pubs/tb/tb63.pdf
13. Establish medical marijuana discounts for veterans.

Legislative Recommendations:

1. Increase the 2 ounce limit per patient per month (medical cannabis use is individualized for patient and medical condition, so there should be no upper limit to what a patient can have—dosage should be based on patient need and method(s) of administration);
2. Restore home cultivation of 6 (six) plants for qualified patients with a NJ MMP ID card (which was approved by the NJ Senate on 2/23/09);
3. Allow any licensed healthcare professional with prescription privileges to recommend medical marijuana, including Advanced Practice Nurses, Dentists, and Veterinarians;
4. Recognize out-of-state ID cards now that 30 states have medical marijuana programs including NY, PA, DE, etc.;
5. Allow patients to obtain medical marijuana from out-of-state, if necessary, while NJ increases supply to meet increased demand;
6. Decriminalize marijuana as soon as possible to protect potential medical patients from arrest and criminal charges for the possession and use of small amounts of marijuana;
7. Do not allow adult use (legalization) legislation to infringe on any current rights of medical marijuana patients;
8. Allow for the use of cannabis as a first line treatment rather than a treatment of last resort--amend CUMMA C.24:6I-3 Definition of “Debilitating medical condition” (1) delete “if resistant to conventional medical treatment”;
9. Pass into law S997 which requires registered qualifying patient's authorized use of medical marijuana to be considered equivalent to use of any other prescribed medication--this prohibits restrictions on patients receiving organ transplants based on marijuana use;
10. Include explicit employee workplace protections--pass into law A1838 which establishes protection from adverse employment action for authorized medical marijuana patients;
11. Pass A1856 "Children's Caregivers Act" which revises requirements for primary caregivers for medical marijuana patients who are minors;
12. Permit any edible form of marijuana for any age and establish dosage units for all forms (repeal prohibition on edibles for adults—only minors are currently allowed edibles);
13. Require initial and ongoing training for all state, county and local Law Enforcement Officers on the medical marijuana program (OAG Guidelines posted on the DOH website is not adequate training);
14. Adopt “Patient Focused Certification” in order to bring national standards to every aspect of the MMP (testing, etc.) through Quality Assurance audits using the industry’s best technical experts, (currently used in DE & MD): https://safeaccess2.org/patientfocusedcertification//

Ken Wolski, RN, MPA
Executive Director
Coalition for Medical Marijuana--New Jersey, Inc.
219 Woodside Ave., Trenton, NJ 08618
609.394.2137 www.cmmnj.org

February 23, 2018

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