thank you all for the opportunity to submit comments regarding these regulations.

my experience has largely been positive. i am happy to see that providers are now protected to have tighter regulations on prescribing opioids.

the largest difficulty my practices faces is action upon urine drug testing that is positive for marijuana (THC). this is because we encounter patients who will intermittently use marijuana in states where it is legally obtained, and because of rapid changes in state legality, are unsure of how to act with regards to continue viewing THC as an illegal substance / drug of abuse. we have also seen cases of physician reprimand by the board of medicine for inappropriate prescribing, where urine drug testing with positive THC testing has been cited as further evidence of physician neglect. any formal guidance form the board of medicine on how to view THC in the context of management of chronic nonmalignant pain with narcotics would be incredible helpful with this common dilemma.

additionally, we are seeing limited numbers of pharmacies that are carrying naloxone, and it seems as though the intra-nasal / atomized formulation of naloxone is the only affordable option for patients when it is recommended. how is the state addressing this mandate to increase access to this important therapy?

thanks for your consideration,

Patrick Turner, MD.