NJ CRC: Prepare for Institutional Caregivers Now
I am glad to hear that the New Jersey Cannabis Regulatory Commission's "Permitting and Licensing Committee" is leading policy discussions on implementing Institutional Caregivers.
However, I disagree with the committee's finding that legal issues need to be resolved before further steps are taken.
Institutional Caregiver policy development and stakeholder engagement should currently be in process in anticipation of the resolution of legal concerns.
The federal Justice Department and its component agencies have been barred from interfering in state-legal medical marijuana programs under a congressional appropriations rider that’s been annually renewed for a decade. There are no legal issues that will not be overcome to permit Institutional Caregivers in healthcare facilities.
Institutional Caregivers will be allowed to come into healthcare facilities and administer to patients the medicinal cannabis that has been recommended for them by licensed physicians, and purchased from Alternative Treatment Centers in New Jersey.
This will be the law in New Jersey. For healthcare facilities to forbid implementation of Institutional Caregivers will place them out of compliance with the law, needlessly jeopardizing the health and safety of patients who are in their care.
Policy development among healthcare facilities should be on-going. These policies must include documentation of medicinal cannabis that is administered to the patient, along with the inclusion on the Patient Care Plan of the patient’s status in the Medicinal Cannabis Program (MCP).
How can a facility be allowed to deprive a patient of a duly approved medicine they are already using? Healthcare facilities should be more concerned about the legal consequences of doing harm to patients by forbidding access to medication that has stabilized their conditions. Any other concerns about cannabis can be dealt with by having patients sign “Hold Harmless” agreements.
Moreover, the use of cannabis in healthcare facilities is an established fact in the U.S.
In 2021, California passed Ryan’s Law, which allows terminally ill patients who have a valid medical cannabis card, to use medical cannabis in a healthcare facility, even though cannabis is an illegal Schedule 1 controlled substance under federal law.
The population of patients in New Jersey’s MCP is continually diminishing. This is partly because some of the sickest patients in the state--those currently in healthcare facilities-- are not allowed access to medical cannabis.
Institutional Caregivers will greatly expand the number of patients served, expand the success of this program, and improve patient care.
Thank you for your attention to this issue.
Executive Director, Coalition for Medical Marijuana--New Jersey, Inc.
219 Woodside Ave., Trenton, NJ 08618
ohamkrw@aol.com
