CANNABIS COE ADVOCACY BLOG

  • 29 Oct 2018 7:42 PM | Marion (Administrator)

    For the full policy memo submitted October 29, 2018 click HERE

    Today, the Cannabis Control Commission (CCC) held two public listening sessions to hear comments related to the transition of the medical cannabis program from the Department of Health (DPH) to the CCC.  Here was the testimony submitted by C3RN: 

    Cannabis Community Care and Research Network (C3RN) Medical Cannabis Policy Recommendations Regarding the program transition from the DPH to the CCC. 

    Submitted to the Massachusetts Cannabis Control Commission

    October 29, 2018

    The Massachusetts Cannabis Control Commission (CCC) is currently accepting public comments related to the transition of the medical cannabis program from the Department of Public Health (DPH) to the CCC. The following recommendations were prepared by the Cannabis Community Care and Research Network (C3RN), a Massachusetts-based cannabis research, education, and advocacy company.

    Increased Access for Medical Patients

    Remove/reduce barriers to access for medical Cannabis such as the $50 patient registration fee and double pediatric certification. Increase education of medical professionals. Increase patient privacy protection. Increase access of current patients.

    Cannabis Research and Open Data

    Form a multi-disciplinary research working group that allows its data to be shared with small businesses and academia. Publish detailed reports regularly from state-derived data. Promote both private and public sector funding of medical Cannabis research.

    Cannabis as a Harm Reduction Alternative to Opioids

    Research existing programs using medical Cannabis to alleviate symptoms of opioid substance abuse disorder. Develop a pilot program in MA. Educate public, medical professionals, and police officers on reduction of harm techniques.

    Letter from C3RN Director of Education

    The importance of protecting and promoting the medical Cannabis community in MA cannot be overstated - we are at a critical point in MA Cannabis trajectory. As a cannabinoid pharmacology expert and a medical patient, Miyabe Shields, PhD, believes we need to be very careful in how these laws will come to guide society.

    Increase Access for Medical Patients

    Remove the Patient Fee: Remove the $50 patient card fee

    Make Patient Registration Immediate: Remove inefficient waiting times for the card, including issuing a temp card, then the permanent card (Alternative path: allow physicians to issue one-month certification that may be used with a printout of DPH registration to access dispensaries).

    Make Physician, Nurse, and Caregiver cannabis recommendation licensing easier and more streamlined. Develop a educational campaign to increase awareness of the medical cannabis program among the medical community.

    Allow reciprocity from other states for medical card holders to access medical in MA as well as MA residents accessing medical cannabis in other legal states.

    Temporary Licensing: As medical tourism in MA is a big market, mostly from out of state, consider a medical tourism card for 2-3 month temporary certification

    Pediatric Certification: Under DPH regulations, pediatric patients require two clinicians to certify a single patient, only two are licensed to certify in Massachusetts. As this is a high barrier to entry, consider dropping to one pediatrician with parental consent.

    Cannabis Delivery: Allow RMDs to keep the same delivery model for medical patients and expand to include healthcare institutions, assisted living facilities, and other relevant healthcare outlets in addition to home delivery.

    Caregiver Model: Under the current regulations a caregiver is only allowed to have one patient.

    We recommend that caregivers be allowed to supply medicine for multiple patients to a minimum of 10 patients to facilitate more patients and ensure no disruption in the regulatory transition. This would bridge the gap between the institutional caregiver model and the single caregiver model as institutions are hesitant to accept that role.

    All medical card holders should be allowed hardship on plant counts. Due to the difficulty and barriers to growing in the New England climate. Caregivers and patients should be allowed to grow as many plants as necessary in order to maintain a 60 day supply.

    Law enforcement needs to understand that once a medical card is shown there should be no need for prosecution if the patient has more than 6 plants.

    Many patients need much higher amount of plants depending on their ailment and means of administration of the medicine. For instance someone that juices the fresh plant needs many more plants to maintain a sufficient supply than someone who only ingests cannabis for say symptomatic conditions.

    Health Insurance

    Consider encouraging Mass Health to do a small feasibility study to look at possible mechanisms for medical cannabis to be covered under state health insurance as an alternative to opiates as well as for medically disabled.

    Support continuing financial hardship programs and discounts under the medical program, including having special veterans focused discount programs for qualified disabled veterans.

    Ensuring equity in the MA Medical Cannabis

    Include Native Americans as one of the focus groups for the social equity program.

    Patient Privacy: Currently patient names are recorded on labels, receipts, and packaging causing risk for patients information to be identified. We recommend removing the name and replacing with a unique ID number on labels, receipts, and the medical card. Ensure this system and ID can be tracked by the police to protect patients.

    ADA Compliance: Medical patient applications forms, website and commission forms should be ADA compliant, and in multiple languages.

    Access for Patients: Strengthen the financial hardship program based on a sliding scale of income and disability status. Continue to promote discounts for veterans and other disabled or low-income populations.

    Develop a leadership rating for companies who focus on giving discounts to medical patients for those who qualify with different disabilities.

    Ensure disabled Veterans have discounted access to cannabis

    Equity for Medical Cannabis Businesses: It will be critical develop the same license structure and fees in the medical program that mirrors the new adult use program offer incentives for businesses to maintain the medical program. The licensing structure and fees should be non-vertical and allow for the same license types. Consider giving licensing priority for companies that want to implement BOTH medical and recreational, over licenses that only apply for recreational.

    Mirror the economic empowerment program for medical licenses

    Positive impact plan (taken from the adult use framework) should be included in the medical program as well

    Give priority status to Promote medical patient owned businesses and co-ops or micro-licenses for small cultivation or manufacturing for medical patients.

    Cannabis Research and Open Data

    Form a multi-disciplinary research working group to ensure transparency and openness in the new research license category. Consider involving patients, clinicians, cannabis industry, citizens, and community members to be part of research setting agenda.

    Consider a pediatric working group to look at both youth prevention as well as pediatric medical cannabis patients for autism, cancer, and other pediatric illnesses that are showing promising findings.

    Ensure access for small businesses and academics to actively participate in the research license category. Create expectations for licensees to not require large assets or buildings to participate to encourage small business and researchers to participate.

    Publish detailed and transparent research license guidelines and improve transparency around the research agenda, open data approach, and how stakeholders can meaningfully participate in advancing cannabis research.

    Promote collaboration among academia, industry, community, and patients to advance cannabis science and research through working groups, events and other outlets.

    Identify budgets/funding opportunities/mechanisms that promote public and private funding for cannabis research, particularly for independent academics, universities, schools, private research organizations to implement rigorous studies and trials

    Cannabis as a Harm Reduction Alternative to Address the Opioid Epidemic

    Massachusetts has one of the leading opioid epidemics in the United States, with alarming rates of overdoses and deaths. Over the last five years, several peer-reviewed studies have documented a reduction in the impact of the opioid epidemic in states with legal medical cannabis. Canada and Israel have integrated the use of cannabis as a treatment into clinical and treatment protocols. Pilot projects in the United States offering cannabis as an alternative treatment during recovery have been promising. Cannabis should not be viewed in isolation as a magic bullet to address opioid addiction and recovery. However, its use as a harm reduction tool, and substitute therapy warrants pilot testing in Massachusetts. The following are related recommendations:

    Form a working group of academics, healthcare providers, public health professionals, community members, and patients to review pilot programs ongoing around the US and internationally that are using cannabis as a harm reduction tool for those suffering from opioid addiction and in recovery. Example programs include:

    Illinois: A person prescribed an opioid can use that script in select cannabis dispensaries to get medical cannabis as an alternative. This program was signed into law in August 2018 (IL Senate Bill 336). The legislation enables doctors to prescribe medical cannabis for patients with conditions that would typically qualify for opioids such as Vicodin, Oxycontin or Percocet. (http://www.medicinemantechnologies.com/illinois-expands-medical-cannabis-with-opioid-alternative-pilot-program/). This bill “While Illinois established a medical cannabis program in 2014, its list of 40 debilitating conditions does not cover every ailment that might qualify for an opioid prescription. SB 336 closes that gap”

    Consider developing a pilot program to integrate with needle-exchange cannabis alternatives

    Grant terminal patients permanent access to medical marijuana

    Train police and other first responders on how cannabis and CBD can be a harm reduction tool during overdose and other recovery situations

    Take a similar approach to what was used with Narcan (https://www.samhsa.gov/capt/tools-learning-resources/massachusetts-prevention-targets-opioid-overdose)

    • working with doctors and families to improve awareness of opioid painkillers’ dangerous interactions with other drugs or alcohol;
    • working with and training users and family members to call 911 when an overdose occurs and conduct rescue breathing until help arrives;
    • training police officers to understand that the use of nasal Narcan, an emergency medication that reverses the physical effects of an opioid overdose, can save lives;
    • educating incarcerated former users about overdose prevention and effective response to overdose;
    • and advocating for public policies to reduce barriers to overdose prevention, such as Good Samaritan Laws that protect people reporting an opioid overdose from criminal prosecution for drug possession.

    Implement the 2016 CDC Recommended that all substance recovery programs should not test for cannabis. This should enforced and patients not tested for cannabis as preventing them from being in recovery programs. http://nationalpainreport.com/cdc-says-dont-test-opioid-users-for-marijuana-8829873.html

    Consider programs such as High Sobriety -- in California and NYC. (https://highsobriety.com/supporting-research/)

    Consider working with incarcerated populations as they are much more likely in MA to have an overdose.

    • Those who are incarcerated get taken off their MAT treatment
    • There is usually no OUD treatment while they are incarcerated
    • Rate of relapse is very high because the addiction is not addressed
    • Rate of overdose is also high because they often do not take their tolerance change into consideration

    _____________

    Monday October 29, 2018

    MA Cannabis Control Commission

    101 Federal Street, 13th Floor

    Boston, MA 02110

    IMPORTANCE OF LEGAL PROTECTION OF MEDICAL CANNABIS IN MA

    Medical intent creates safer usage guidelines, and promotes research and education

    To Whom It May Concern:

    My name is Christina Miyabe Shields and I am the Director of Education for C3RN. I received my PhD in Pharmaceutical Sciences from The Center for Drug Discovery at Northeastern University where I studied the system in the brain/body that interacts with Cannabis at a molecular level. I believe the state of MA is at a critical point in its Cannabis legislature that will decide the future direction of Cannabis research and education, which will subsequently drive the entire population of Cannabis consumers in the Commonwealth.

    Decades of prohibition have made it difficult to separate medical and adult recreational use, but I personally define medical use as a controlled, therapeutically minimal use in order to reduce or eliminate negative symptoms versus recreational use as adding the positive effects of Cannabis to enhance an experience. The intent behind the two types of usage are actually completely opposite one another and this fundamental difference creates two very different populations of adult Cannabis consumers.

    While I have no objection to recreational Cannabis in MA, I do not believe it should ever replace medical Cannabis. If medical Cannabis patients turn to recreational Cannabis because it has lower barriers to entry, the entire population of Cannabis consumers will suffer. The recreational market will not prioritize research and education for medical usage and, therefore, these patients will receive a lower quality of care. Furthermore, these patients will view the intent of their usage differently as recreational users as opposed to medical patients. In my opinion, a medical patient who is using Cannabis recreationally is at the highest risk to develop a substance use disorder as they do not accurately understand the reasons of their use and have decreased accessibility to necessary supports found in the medical Cannabis community.

    It is essential that policymakers prioritize reducing the barriers to entry for medical Cannabis and protecting patients rights at this pivotal time.

    Sincerely,

    Christina Miyabe Shields, PhD

    Director of Education, C3RN

    TO GET THE LATEST IN CANNABIS SCIENCE, EDUCATION, AND RESEARCH IN YOUR INBOX -- BECOME A C3RN MEMBER TODAY! 

  • 26 Oct 2018 9:51 PM | Marion (Administrator)

    Native Americans Need Your Help Too!

    Shared by AARON TOBY, Bourne MA on October 26, 2018

    Please take the SURVEY to fight the ban on Cannabis in Bourn, Massachusetts!

    The below is a public testimny to the Cannabis Control Commission in Massachusetts, dated July 2018. 

    (Massasoit smoking a peace pipe with Governor John Carver in Plymouth 1621)

    The Cannabis Control Commission could help the Indigenous People, Native Americans by including them in the Eligibility as Economic Empowerment Applicants in Cape Cod towns and the Islands or in any cities and towns that did not vote to opt out of the cannabis business.

    As the Commonwealth of Massachusetts through its Cannabis Control Commission reviews and approves license applications for a variety of applicants, it is worthy to note that the Commission has called for the ‘Inclusion of Under-Represented Groups’ to promote racial equity, as well as noting applications that provide a ‘Contribution to Social Equity Programs’ that can positively affect communities disproportionately impacted by high rates of arrest and incarceration for drug offenses.

    What also merits consideration is the strong historic ties between the original inhabitants of this land and the European immigrants that came in the seventeenth century, the setbacks suffered by the indigenous peoples after contact both historic and contemporary, in a way that brings mutual benefit to both communities today. The ancestors of modern Native Americans were greatly affected by the European colonization of the Americas, which began in 1492, and their population declined quickly due to introduced diseases, warfare and slavery. Native Americans pass down stories to preserve their history and heritage, because we don't have much of it left. As tribes were systemically exterminated, so too were their respective cultures. But we have our stories, and one about the term "redskins." Spencer Phips, a British politician and then Lieutenant Governor of the Massachusetts Bay Province, issued the call, ordering on behalf of British King George II for, "His Majesty's subjects to Embrace all opportunities of pursuing, captivating, killing and Destroying all and every of the aforesaid Indians." They paid well – 50 pounds for adult male scalps; 25 for adult female scalps; and 20 for scalps of boys and girls under age 12. These bloody scalps were known as "redskins."

    You may also recall the state flag of the Commonwealth of Massachusetts that depicts a typical Wampanoag man subjugated under an arm and saber that has been used continuously for several years. These effects are not merely historic; the city of Boston introduced a regulation so uniquely discriminatory towards Native Americans in 1675 that it created a ban on Indians entering Boston that remained until its repeal in 2004.

    Some national data that Commissioners should consider are among the following:

    • Native Americans are incarcerated at a rate 38% higher than the national average, according to the Bureau of Justice Statistics.
    • Native American youths are 30% more likely than whites to be referred to juvenile court than have charges dropped, according to National Council on Crime and Delinquency.
    • Native Americans are more likely to be killed by police than any other racial group, according to the Center on Juvenile and Criminal Justice.
    • Native American men are incarcerated at four times the rate of white men; Native American women are incarcerated at six times the rate of white women, according to a report compiled by the Lakota People’s Law Project.
    • Native Americans fall victim to violent crime at more than double the rate of all other US citizens, according to BJS reports. Eighty-eight percent of violent crime committed against Native American women is carried out by non-Native perpetrators.

    Compared to other racial/ethnic groups in the U.S., American Indians and Alaska Natives have the highest rates of alcohol, marijuana, cocaine, and hallucinogen use disorders and the second highest methamphetamine abuse rates after Native Hawaiians. Consequences of substance abuse in this population have been significant. For example, a more frequent association between alcohol use and suicide has been observed among Native Americans compared to the general U.S. population3,4. In addition, high rates of traumatic exposure have been identified among AI/ANs with alcohol use disorders5

    Regarding arrest and incarceration rates, respected media outlets have studied the phenomenon of legal inequity in Indian Country. In April 2015, The Wall Street Journal spoke with Ralph Erickson, a chief federal district court judge for North Dakota. Erickson, an outspoken proponent of sentencing reforms for Native American reservations, is spearheading the federal review, called the Tribal Issues Advisory Group, the panel is made up of 22 judges and law enforcement administrators, 11 of which are Native American.

    “No matter how long I have been sentencing in Indian Country, I find it gut-wrenching when I am asked by a family member of a person I have sentenced why Indians are sentenced to longer sentences than white people who commit the same crime,” Erickson confided to The Journal’s Dan Frosch.

    Frosch accounts for this disparity by dissecting the process by which certain crimes are prosecuted on reservations. “Native Americans are typically prosecuted under federal law for serious offenses committed on reservations,” he explains. “State punishments for the same crimes tend to be lighter.”

    MASSACHUSETTS STATISTICS FOR NATIVE AMERICANS

    These challenging national statistics do not improve when compared with statistics right here in the Commonwealth of Massachusetts. The following data is from the 2000 Census, and yields some startling results. 

    Income. 

    z

    Note that unless otherwise noted, socio-demographic indicators are given for American Indian and Alaska Natives alone.

    ·      The per capita income for American Indian and Alaska Natives in 1999 ($15,889) was close to 40% below the state per capita income of $25,592.

    ·      The 1999 median household income for American Indian and Alaska Natives was $36,810 compared with $50,502 for all residents of Massachusetts.

    EDUCATION

    ·      American Indians and Alaska Natives have poorer educational attainment when compared with the Massachusetts population as a whole.  In Massachusetts in 2000, 28% of the American Indian and Alaska Native population had less than a high school diploma compared with 15% of the state population. 

    ·      Only 11% of the American Indian and Alaska Natives in Massachusetts had bachelor’s degrees compared with 20% of the state population.

    POVERTY

    ·      Twenty-one percent of American Indian and Alaska Natives live below the poverty level as compared with Massachusetts as a whole at 9.3%.

    ·      American Indian families were more than 3 times more likely to live below poverty than those at the state overall.

    HOMEOWNERSHIP

    ·       The home ownership rate for American Indian and Alaska Natives (alone) (38%) was about half the rate for all of Massachusetts residents (62%) in 2000.

    SUMMARY

    Presently, Native Americans are not included in the Eligibility as an Economic Empowerment Applicant even though they have the deepest and longest ties to the Commonwealth, and further one of the most negatively impacted ethnic groups by inordinately high rates of arrest and incarceration for drug offenses both nationwide and in Massachusetts.

    I am requesting the CCC to amend the regulations to include Native Americans in the Eligibility as Economic Empowerment Applicants in Cape Cod towns and the Islands or in any cities and towns that did not vote or choose to opt out of the cannabis business.

    Appendix

    Cannabis in Native American’s Culture and Religion, by M. Allister Greene in Cannabis Digest, July 9, 2018.

    Native American Tribe's Cannabis Consultant To Face Trial, by James Nord in Politics, May 19, 2017.

    Native American Tribes Consider Entering Marijuana Market, by Phil Dierking and Caty Weaver, August 27, 2017.

    Pot Casino? Native American Tribe Sparks Marijuana Business -- Tax Free, by Robert W. Wood in Forbes Magazine, June 6, 2017.

    Submitted by:  Aaron Tobey, Jr.

                            50 Monument Neck Rd.

                            Bourne, MA  02532

                            978-609-2352 (mobile)

    Date: July 11, 2018


  • 5 Oct 2018 12:57 PM | Mackenzie (Administrator)

    In the 2018 TIME’s Special Edition Magazine, “Marijuana Goes Main Street” touched on several key areas on legalizing cannabis. These topics varied from neuroscience to the booming cannabis market, but one topic was of most importance, “Why Pot Is a Civil Rights Issue.” This chapter opened with historical content stating, “The United States has the highest incarceration rate in the world,” let that sink in! Reading further into the article another, and even more devastating statistic,”The U.S. has 5 percent of the world’s population and 25 percent of the world’s prisoners.” These statistics are indeed novel, but not merely because of their sums, but rather, because of the civil rights injustice that provoked this mass incarceration. In the 1980’s, President Reagan and the United States Congress waged the War On Drugs boosting the incarceration rate by 790 percent in 2011. Breaking down the numbers further and proportionally adjusting the numbers by race, the numbers are painful. Even though Black and White Americans use cannabis at the same rate, Black Americans were arrested and incarcerated at almost 6.5 times the rate of White Americans during this period. The Washington Post presented data from the FBI and U.S. Crime census from 2000-2010 showing that 15-20 percent of all arrest of a Black American was for the possession of cannabis (White Americans was around 4-5%).

    The stark difference in the number of arrest and incarcerations are not some unexplainable phenomena when considering the ugly racial past of the United States. This issue speaks more so to the transformation of old policies into a systematic form of racism- one that has not merely maimed the social character of Black Americans but also has heavily and further stigmatized persons of color and a peaceful medicine.

  • 7 May 2017 1:02 PM | C.

    If you haven't heard of the 27 Club, it's a large group of celebrities - mostly musicians - who passed away at the age of 27. 

    -------------------------------------------

    When I first learned about the 27 Club phenomenon, the thought that came to mind was, "Wow! I can't believe they made it that long!" I was 13 years old, and just beginning to understand that the growing burden of being trapped in my own mind could kill me. I guess it would be accurate to say that I was depressed, had social anxiety, anger issues and/or bipolar mood-regulation disorder tendencies, but it would also be accurate to say that I was undiagnosed, misunderstood, and forced to spend most of my energy conforming my behaviors to avoid bullying and other negative social interactions. The stress of constantly suppressing "weird" instinctual behaviors without accurately understanding their source put me in a loop of self-loathing. Why was everything I did wrong?

    During my early teenage years the exhausting routine of keeping up normal appearances kept me tiptoeing the line of sanity, and sometimes I would fall off. Billions of thoughts screamed at me, my skin restricted me and I felt as if I should peel it all off and be done with it. Now I know these episodes were caused by combinations of overstimulation and deviation from my routines, but at the time they just were bad days. This is when I learned my first major coping mechanism, and it was a bad one. The conscious pain of self-harm gave me something to focus my brain on while the frenzy of other thoughts died down. I would scratch, bite, burn, or cut myself on an area of my body that no one else could see, and on more than one occasion, when self-harm didn't work and the screaming was loud as ever, it crossed my mind that I would have to kill myself to end it.

    This feeling, that life is unbearably painful and there's no respite, is something you can't know unless you've experienced it. People who say that it's a weakness are people who simply haven't experienced the same type of unexplicable pain, and some of them could never experience it - even under the same exact conditions. This is because the differences in our brains causes differences in perceived emotions, and pain is one of the most evolutionarily important emotions. I am hypersensitive to "light-touch" like the feeling of clothing, tickling, and those spider-looking head massagers, but hyposensitive to acute pain like stabbing, cutting, and burning. 

    My life changed when I found Cannabis. I was able to self-regulate; I was able to start living. I will never forget what it felt like before I found my medicine.

    Teenage-me never thought I would make it to the 27 Club, let alone surpass it. Hell, even early-20's me doubted it. And living your life with no prospective outlook leads to reckless and self-destructive behaviors. Three years ago on my 24th birthday I was in a crazy manic phase. I fell two stories from a tree and landed on my head onto the concrete of Commonwealth Ave. The doctors said I was a medical anomaly for only slightly damaging my neck and spine. That's when I decided to get serious about my condition. I sought out many different professional opinions, and finally found an amazing psychologist to work with. He helped me to realize that even if I don't think any diagnosis completely fits, it doesn't matter in the least, because I have my medicine. 

    All I can say is, I'm extremely thankful that this happened now. Sure, it doesn't fix or replace any of the dark shadows in my story, but it does put them into context. And the struggle of self-understanding is very, very difficult for high functioning atypical young adults. We spend our lives fixing and editing behaviors until we can't recognize our own wants and desires from the wants and desires others are placing upon us. We fit in enough to hide our true selves away from the world, making us feel all the more alone. Our ability to camouflage only makes society enforce stricter rules and expectations upon us. The 27 Club serves as a reminder that successful assimilation into the neurotypical population doesn't necessarily mean happiness. It stood out in my mind like a huge traffic sign that I was constantly getting closer to, but never thought I'd pass. And now that I'm past it, I'm proud. Because for some of us, it's a huge accomplishment just to make it to 27.

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