As of June 2018, approximately 331,000 Canadians were registered clients of a licensed medical cannabis producer. Despite this large number, only 9,700 were registered clients in Québec. By comparison, during the same period, the number rose to 143,000 in Ontario1. This difference might be explained in part by the close supervision of the Collège des médecins du Québec (Collège) over the use of cannabis for therapeutic purposes.

With the legalization of cannabis for recreational purposes at its doorstep, the Collège issued new directives for Québec physicians in September 2018. These directives replaced the previous directives from 2014, seen by many as rather conservative, and imposed a shift in medical standards that could have a significant impact on the way medical cannabis is seen in Québec.

A study of both directives points to a change in the approach advocated by the Collège regarding the use of cannabis for medical purposes.

2014 directives for prescribing dried cannabis for medical purposes

In response to the previous Marihuana for Medical Purposes Regulations, which allowed the prescription of cannabis, i.e. an unapproved product, by practitioners, the Collège des médecins circumscribed its use.

Notably, the Directives for prescribing dried cannabis for medical purposes [French only] from April 2014:

  • Criticized the absence of approval normally required for marketing a prescription drug;
  • Qualified the therapeutic use of cannabis for treatment not recognized under the Code of Ethics of Physicians, which essentially restricted its use to medical research;
  • Favoured the use of other forms of cannabinoids;
  • Established a strict medical verification protocol for patients before inclusion in a research project involving cannabis;
  • Prohibited physicians from providing cannabis to patients directly;
  • Prohibited physicians from becoming cannabis producers.

As a result, since 2014, the Collège has recommended limiting the prescription of cannabis to patients participating in a research project. The Collège des médecins's approach was based on caution and lack of scientific consensus on the product's effects. The Collège did not seem to consider cannabis as a recognized treatment or medical solution.

2018 directives for prescribing cannabis for medical purposes

As the legalization of cannabis for recreational purposes approached, and considering the scientific data now available, the Collège has chosen to revise its position on the use of cannabis in the medical field and its prescription by physicians in Québec.

The new Directives for prescribing cannabis for medical purposes [French only] from September 2018:

  • Allow cannabis to be prescribed for medical purposes outside of a research project;
  • Provide for the use of cannabis only in medically necessary cases;
  • Require physicians to weigh the therapeutic benefits of a therapeutic cannabis prescription against the potential adverse effects;
  • Provide for the therapeutic use of cannabis only as a subsidiary solution to the usual treatments;
  • Establish warnings for certain groups of people at risk (people under 25, people at risk of addiction or cardiovascular disease, etc.);
  • Provide the need for a complete, in-person medical assessment before providing a prescription;
  • Impose on physicians a duty to inform regarding the patient's responsibility for the use and storage of the product;
  • Impose a progressive dosage treatment;
  • Require physicians to disclose their financial interests in a cannabis business.

In summary, the new directives' approach now recognizes cannabis as a potential treatment. While cannabis remains only an alternative to traditional treatments and cautions remain in place, we notice a significant change in the Collège's position on the therapeutic use of cannabis in Québec.

This shift is due in part to the emergence of new scientific data on the use of cannabis for medical purposes and the anticipated rise in insurers' requests to physicians to justify the reimbursement of cannabis administered for medical reasons. According to the College, the change is a pragmatic consequence to the challenge of controlling the expanding use of cannabis. Still, the College maintains that the new directives remain some of the most prudent and conservative in Canada, in part due to the lack of research funding available to demonstrate a scientific basis for cannabis use.

It remains to be seen whether producers, patients, insurers, health professionals and the other players in the therapeutic cannabis market in Québec will feel any repercussions of these changes following the legalization of cannabis for adult use on October 17, 2018.

Footnote

1 Health Canada, « Market Data », Online.

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