GNYHA, DOH Work on Compassionate Care Act

GNYHA has convened a workgroup of member hospital legal, compliance, risk, clinical, and pharmacy staff over the past year to discuss the Compassionate Care Act, New York State’s medical marijuana program. GNYHA members have detailed best practices and challenges to allowing patients to self-administer medical marijuana during an inpatient care episode. GNYHA continues to work with the New York State Department of Health (DOH) on emergency regulations to establish facilities as caregivers (see comments GNYHA submitted on the emergency regulation). In particular, GNYHA recommended DOH streamline the requirements for facilities to become caregivers for certified patients and raised concerns about the disposal of unused medical marijuana product, which requires a facility to return unused product to the caregiver or law enforcement. GNYHA also hosted briefings with DOH’s Bureau of Narcotics Enforcement and registered organizations. GNYHA is working with DOH on a “Dear Administrator” letter to provide guidance on several concerns raised. GNYHA will also continue to solicit member feedback on regulations and operational issues as the program develops and expands.