It's important to have your say in the consultation on New Zealand's proposed Medicinal Cannabis Scheme. Here's a helpful guide to making a submission on the most pivotal issue: Specialist sign-off should not be required for patients to access more affordable medical cannabis through their GP.
Government has committed to establishing a Medicinal Cannabis Scheme and its objective is clear: "to improve access to quality medicinal cannabis products". But will these products be as accessible as other medications if a specialist recommendation is required on top of a general practitioners' prescription? Absolutely not.
Categorising medical cannabis
Under the proposed medicinal cannabis regime, from next year, medicinal cannabis products will fall into two main categories:
Medicinal cannabis products that are controlled drugs approved by the Ministry of Health (presently, this only includes Sativex™)
Unapproved medicinal cannabis products that are controlled drugs that meet the quality standards (i.e. GMP).
So, this means all other medical cannabis products (except for Sativex™) will be categorised as 'unapproved medicines'. This includes all of the products that will be made in New Zealand, for the foreseeable future.
These locally-made products will be significantly more affordable than bio-similar imported alternatives, and manufactured to the same high quality standards.
Specialist prescribing rules
One of the key proposals being considered by the Ministry of Health is to require general practitioners to gain a specialist’s approval to prescribe medicinal cannabis products, except for Sativex (on-label) which is classified as an ‘approved' medicine.
This means nearly all patients would need to consult a specialist before a medical cannabis prescription is issued – and this has the potential to significantly impede access.
While doctors can prescribe a wide range of products, such as opioids and benzodiazepines, the proposed regulations state that general practitioners are not empowered to prescribe medical cannabis products on their own. Patients would also need to gain a recommendation from a specialist.
Understandably, concerns have been raised by Royal New Zealand College of General Practitioners, with medical director Dr Richard Medlicott stating, “The idea we need to kowtow to our hospital-based colleagues is ridiculous, GPs are perfectly capable of educating themselves [about medical cannabis].”
Visiting medical cannabis expert, Professor Mike Barnes, has said "Specialist sign-off is simply not needed nor wanted. It hasn't worked elsewhere, and it won't work in New Zealand. I strongly believe GPs should be allowed to prescribe without specialist approval, just as they do with other medicines."
Professor Barnes went on to say, "Your Government and Health Minister are clearly driven by improved patient access to medicinal cannabis, so I strongly caution them against including such a proposal in the final regulations. It would seriously impede patient access to medicinal cannabis."
Having your say on the regulations
The Ministry of Health would like your views on this and how it might impact you. The public consultation closes on 7 August 2019.
For patients: the regulator needs to hear how this will impact your ability to access quality medicinal cannabis products.
For clinicians: the regulator need to know how this proposal will impact your practice and patients, your capacity to cope with patient inquiries and its likely impact on making medicinal cannabis products more accessible legally, as the Government intends.
Requiring a second specialist recommendation is wrong
The requirement for patients to have approval from a specialist GP and a second specialist is unnecessary and distressing to already distressed patients.
CBD is remarkably effective for chronic pain and emotional distress. It may not help when conditions are severe. MoH guidelines, enforced as regulations, require these already distressed patients to seek the signature of another specialist.
Everyone has a specialist GP, most patients do not have another specialist
This proposal assumes that other specialists know more about THC than specialist GPs – wrong. Medicinal cannabis training sessions are almost exclusively GPs, not other specialists.
Public hospital specialists difficult to access, less likely to sign.
Private specialists are expensive and often have a waiting time to be seen.
Pain and rheumatology often cite peer pressure or lack of research to refuse to recommend. Orthopaedic surgeons treating painful conditions will say they know nothing about Sativex and refuse to recommend.
Sick patients are often embarrassed or feel dismissed by specialists.
Specialist GPs routinely prescribe drugs potentially more harmful than THC eg anti-coagulants, opioids, antipsychotics without needing recommendation from another specialist. Controls on THC are disproportionate to the potential harms – no one has died from THC overdose.
Peter Moody’s interview in NZ Doctor (03/07/19) with regard to other medication mentions 'the illogicality of “specialist-only” medications being a designation that excluded GPs.’
Why is a controlled drug pad needed for THC products?
Cost of Sativex is a huge barrier. We don’t need the specialist recommendation as another barrier.
Many chronic pain patients do not have a specialist, having given up on a system that offers high-risk interventions, strong drugs or ineffective non-medical approaches. How do they obtain a recommendation?
The New Zealand medicinal cannabis industry needs the support of specialist GPs to prescribe the full range of medicinal cannabis product, for appropriate patients and appropriate conditions. Industry cannot grow from CBD products alone.
Make your submission
We suggest you start by reading the Short Guide to the Consultation Document (coming soon), which highlights the areas of interest for different audiences. Then read the sections of the Medicinal Cannabis Scheme Public Consultation Document relevant to your interests.
You can download a copy here:
Word version: Medicinal Cannabis Scheme consultation (Word, 715 KB)
PDF version: Medicinal Cannabis Scheme consultation (PDF, 1.2 MB)
You can then provide feedback by using the Ministry of Health's online tool. This is their preferred way to get feedback.
For more information about the consultation process, check out our full guide here.