June 22, 2021
Dear Members of the Joint Committee on Cannabis Policy,
As one of the senior cannabis physicians in the Commonwealth of Massachusetts, President of
the Association of Cannabis Specialists, Board Member of the Massachusetts Patient Advocacy
Alliance, and former VA physician I wish to convey some very specific concerns regarding
Senate Bill 70 and the corresponding House 179 (which was previously introduced as House Bill
4274).
Despite vocal advocacy by a few veterans, this bill is not in the interests of veterans or other
patients. Section One seeks to add additional “qualifying conditions” to a list established in the
current law that is superseded by the existing language “and other conditions as determined in
writing by a registered qualifying patient's registered healthcare professional”. As additional
conditions are already covered by the language of the original law and the reasonable practice of
medicine, seeking to add conditions undermines the crucial clinical judgement that is expected of
health professionals when treating those “other conditions”. The law already provides for
treatment of the conditions to be added under this bill, and thus adding them specifically risks
undermining the ability of healthcare professionals to exercise their medical judgement as
intended by the original language. We certain do not want to have every condition listed, and
doing so undermines the application of professionalism and clinical judgment.
Section Two is a larger problem. This seeks to conflate a financial determination of “disability”
by the Veteran’s Administration with a medical diagnosis, and assumes therefore that a simple
diagnosis is a stand-in for ongoing evaluation and treatment by a health care practitioner. A VA
determination of disability is a financial decision made by an administrator, not a clinician, that
solely has value for determining VA benefits. Disability is neither a diagnosis nor does it reflect
a patient’s care or ongoing treatment. Furthermore, any current illness is an ongoing process
subject to evolution and development worthy of care and guidance from medical professionals.
It is inappropriate to allow or disallow medical care (with cannabis) on the basis of an
administrative determination without reference to current and ongoing condition.
“…such a veteran shall not be required to receive a diagnosis from a registered healthcare
professional,” very succinctly demonstrates the intent of this bill to side-step proper
medical care. This is very much in the interest of the cannabis industry. It is very much not in
P.O. Box 1804 703-960-6500
Alexandria VA 22313 www.cannabis-specialists.org
the best interests of medical patients and puts them at risk of harm to their health from the very
system intended to help them.
While there is good evidence to support the use of cannabis for veterans, including those with
PTSD, there is also good evidence that doing so without medical guidance leads rapidly to
overuse and downstream consequences in the veteran population*. Veterans who use cannabis
with careful, medically guided attention to dose, frequency, and method of delivery, along with
adjunctive care like psychotherapy and conventional medications do better. Bypassing this care
is harmful to veterans.
Veterans, like all patients, deserve the best healthcare options. This bill undermines their care
and they deserve better. Please do not approve this bill.
Sincerely,
Jordan Tishler, M.D.
Harvard Medical School
Association of Cannabinoid Specialists
InhaleMD
*Loflin, M. J. E., Babson, K., Sottile, J., Norman, S. B., Gruber, S., & Bonn-Miller, M. O.
(2019). A cross-sectional examination of choice and behavior of veterans with access to free
medicinal cannabis. American Journal of Drug and Alcohol Abuse, 45(5), 506–513.
https://doi.org/10.1080/00952990.2019.1604722
P.O. Box 1804 703-960-6500
Alexandria VA 22313 www.cannabis-specialists.org
