NORMAN J CLEMENT RPH., DDS, NORMAN L.CLEMENT PHARM-TECH, MALACHI F. MACKANDAL PHARMD, BELINDA BROWN-PARKER, IN THE SPIRIT OF JOSEPH SOLVO ESQ., IN THE SPIRIT OF REV. C.T. VIVIAN, JELANI ZIMBABWE CLEMENT, BS., MBA., IN THE SPIRIT OF ERLIN CLEMENT SR., WILLIE GUINYARD BS., JOSEPH WEBSTER MD., MBA, BEVERLY C. PRINCE MD., FACS., LEROY BAYLOR, JAY K. JOSHI MD., MBA, ADRIENNE EDMUNDSON, ESTER HYATT PH.D., WALTER L. SMITH BS., IN THE SPIRIT OF BRAHM FISHER ESQ., MICHELE ALEXANDER MD., CUDJOE WILDING BS, MARTIN NDJOU, BS., RPH., IN THE SPIRIT OF DEBRA LYNN SHEPHERD, BERES E. MUSCHETT, STRATEGIC ADVISORS
WALTER F. WRENN III., MD.,
RE: PART 1
Over the last several years Healthcare providers have been arrested, tried arid convicted of various charges while prescribing FDA-approved medication. Undercover agents have been sent into medical offices to see if their narrative will entrap the Healthcare provider. The charges brought against physicians seem to have a common theme.
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They prescribed highly addictive opiate medication.
- What evidence exists that the dose of opiate pain medication determines its addictive nature?
Opiates at any dose can be addictive. The pharmacological action of 5 mg of Oxycodone is the same as 30 mg of Oxycodone. Highly addictive is therefore a prosecutor’s term not a medical one. It has no medical equivalent. Another common theme is the health care provider distributed a controlled substance outside the scope of professional practice and not for legitimate medical purposes.
2. What does that mean?
When a patient is seen by a health care provider, they are asked questions examined and a course of action is determined based on the findings of the provider including medication being prescribed. Only the examiner can determine this.
3. What was prescribed that was outside the scope of professional practice and not for legitimate medical purposes?
This is a sentence in the CSA which is the only action that would disqualify a health care provider from prescribing a controlled medication. By invoking this statement, the prosecutor without offering any proof can then charge the Healthcare provider with insurance fraud. Another common theme is healthcare fraud and controlled substance offenses related to the illegal distribution of prescription medication.
The patient has insurance. The insurance company pays for the patient’s prescription. The provider has a valid DEA license.
4. The medication is FDA approved. Where has fraud occurred?
Again, a prosecutor’s technique is used to disqualify a health care provider their right to legally prescribe a controlled medication under the CSA. With the introduction of the 2016 CDC guidelines, a new theme was introduced by prosecutors. 90 MME as a threshold for prescribing opiate pain medication.
Almost all health care providers prescribing opiate pain medication for chronic pain prescribe medication that far exceeds 90 MME. If the 90 MME was a law or rule, which it is not, all health care providers treating chronic pain patients would be in violation. The CDC guidelines did not apply to chronic pain patients but were meant for primary care physicians who were initiating opiate pain medication for the first time.
The CDC tried to correct this misapplication of their guidelines on April 24, 2019, issue of the New England Journal of Medicine. The DOJ/DEA, state AGS insurance companies, and state medical boards never made the correction. At the July 16, 2021, meeting of the BCS committee to revise these guidelines, it was apparent that consensus on the 12 proposed changes could not be reached and that the 90 MME was a major issue.
TO BE CONTINUED
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