Pennsylvania's Department of Health (DOH) has issued a draft of its Medical Marijuana Program temporary regulations for physicians.
Physicians will have the option (participation is voluntary) to apply to be a recommending practitioner in the commonwealth's Medical Marijuana Program. Recommending practitioners can then issue patient certifications in the program if certain conditions are met, including that the patient is likely to receive therapeutic or palliative medical benefit from the use of medical marijuana.
A draft of the proposed regulations is available here.
Here are four noteworthy provisions of the proposed regulations you may wish to consider if commenting:
Practitioner registry: Any practitioner that participates in the Medical Marijuana Program will have certain information – such as name, business address, professional email address, and telephone numbers – made public via an online registry. Practitioner information such as name, business, address, and medical license number, will also be included on the patient certification form.
Form of medical marijuana: The practitioner can opt to have the physician or pharmacist at the dispensary determine the form of medical marijuana.
Limitation on changing the form of medical marijuana within a 30-day period: A practitioner may not modify the form of medical marijuana (e.g. pills, topical creams, and oils) on a patient certification for a period of 30 days from the date the receipt is entered into the electronic tracking system by the dispensary unless the practitioner notifies DOH of the intent to modify the patient certification.
Training requirements: Completion of a 4-hour medical marijuana training course will be required for:
The course shall include, at a minimum, information on a practitioner's responsibilities; general information about medical marijuana under federal and state law; the latest scientific research; recommendations for medical marijuana use as it relates to pain management, palliative care, and other areas; and best practices for recommending form and dosage.
The Pennsylvania Medical Society (PAMED) offers a variety of resources on Pa.'s medical marijuana law, including:
PAMED members with questions can also contact our Knowledge Center at 855-PAMED4U (855-726-3348) or KnowledgeCenter@pamedsoc.org.