“FROM COPS TO CLINICIANS” DEA’s CONTROL REGISTRATION “A SWORD OF DAMOCLES,” MOVING NARCOTIC REGISTRATION TO THE OFFICE OF THE UNITED STATES SURGEON GENERAL

from youarewithinthenorms.com

REPORTED BY

NORMAN J CLEMENT RPH., DDS, NORMAN L. CLEMENT PHARM-TECH, MALACHI F. MACKANDAL PHARMD, BELINDA BROWN-PARKER, IN THE SPIRIT OF JOSEPH SOLVO ESQ., INC.T. SPIRIT OF REV. C.T. VIVIAN, JELANI ZIMBABWE CLEMENT, BS., MBA., IN THE SPIRIT OF THE HON. PATRICE LUMUMBA, IN THE SPIRIT OF ERLIN CLEMENT SR., WALTER F. WRENN III., MD., JULIE KILLINGWORTH, LESLY POMPY MD., CHRISTOPHER RUSSO, MD., NANCY SEEFELDT, WILLIE GUINYARD BS., JOSEPH WEBSTER MD., MBA, BEVERLY C. PRINCE MD., FACS., NEIL ARNAND, MD., RICHARD KAUL, MD., LEROY BAYLOR, JAY K. JOSHI MD., TERENCE SASAKI, 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 NJOKU, BS., RPH., IN THE SPIRIT OF DEBRA LYNN SHEPHERD, BERES E. MUSCHETT, STRATEGIC ADVISORS

!!DEA…YOU LIE!!

The dea has Consistently-lied to the public

While the DEA has consistently emphasized and supported the prescriptive authority of an individual practitioner under the CSA to administer, dispense, and prescribe controlled substances for the legitimate treatment of pain within acceptable medical standards. This is outlined in the DEA’s policy statement published in the Federal Register (FR) on September 6, 2006, titled, Dispensing Controlled Substances for the Treatment of Pain, 71 FR 52716. {A copy is enclosed for your convenience.}”

This statement put out by DEA headquarter is one big lie!!!

Watch as Captain Christ demolishes every argument for the War on Drugs in this viral video.

CONTROL REGISTRATION A DEA SWORD OF DAMOCLES

As a Law Enforcement agency, DEA is not a position to authorize or dictate what a doctor prescribes to a patient. DEA cannot grant waivers of any kind when it comes to the practice of medicine because no such wavier exists.

As the United States’ component body charged with managing controlled substances and chemicals for scientific, medical research, and industrial applications, DEA regulates the flow of controlled substances, not the practice of medicine.

The changing prescribing practices of practitioners are derived by a shift to prescribe medicine consistent with guidance issued by the Centers for Disease Control and Prevention, along with guidance and recommendations of state boards of medicine.

Congress, therefore, did not even leave it to DEA to perform one of its core CSA functions—the scheduling of controlled substances— without healthcare agency oversight and evaluation.

CONTROL SUBSTANCE ACT

One of the most important principles underlying the CSA and its implementing regulations is that to be valid, every prescription for a controlled substance must be based on a determination by an individual practitioner that the dispensing of the controlled substance is for a legitimate medical purpose in the usual course of professional practice. United States v. Moore, 423 U.S.C. 122 (1975) and 21 CFR 1306.04(a). Federal regulations do not define the term legitimate medical purpose nor do they set forth the standards of medical practice. It is up to each 

DEA-registered practitioners are authorized by DEA to do so, to treat patients according to his or her professional medical judgment in accordance with a standard of medical practice that is generally recognized and accepted in the United States. 

While DEA is the agency responsible for enforcing the CSA, DEA does not act as the Federal equivalent of a state medical board overseeing the general practice of medicine and lacks the authority to issue guidelines that constitute advice relating to the general practice of medicine.

THE DEA-DOJ INTRUSION INTO MEDICAL CARE HAS RESULTED IN YOUR CREDIT CARD COMPANY OWNING YOUR MEDICAL DATA

On November 22, 2021 youarewithinthenorms.com published:

” Equifax just completed the acquisition of Appriss Insights,^[1] who is rebranding as Bamboo Health.^[2] 

a) How much data sharing goes on between the entities? 

Just as Appriss’ NarxCare score^[3] is a black box^[4], never subjected to peer review or outside scrutiny^[5], this reorganization seems designed to hide data sharing. 

Monitoring of controlled substance prescribing is a recent phenomenon that owes its appearance to the opioid epidemic. Doctors are now put in a position to be law enforcement, counterintuitive to their training. As medical students, physicians learn to conduct a history and physical. 

The patient’s story is a centerpiece of the history, and there is a truth bias. Physicians are being asked to doubt what patients tell them and approach each encounter as someone who is “drug-seeking.” This harms the physician-patient relationship directly.

THE STUDY PROVES DR. NEIL ANAND, MD. EARLIER OBSERVATIONS OF DATA ANALYTICS WERE THE LYNCH PINS TO DEA’s CRIMINALITY

CITIZEN PETITION TO FDA

The Center for U.S. Policy (“Petitioner”) submits this Citizen Petition under the Federal Food, Drug, and Cosmetics Act (“FD&C Act”) to request the Commissioner of the U.S. Food and Drug Administration (“FDA”) to deem the Bamboo Health (“Bamboo”) NarxCare software a misbranded device and take administrative action to prevent serious, adverse health consequences and death.

Doctors Neil Anand, MD’s First Letter on “Narxcheck Scores as a Predictor of Unintentional Overdose Deaths”

From: Neil Anand <cardiacgasman@gmail.com>
Date: Thu, Sep 17, 2020 at 2:02 PM
Subject: Peer Review Request of Raw Data- Verification of statistics utilized to publish narxcheck score as a prediction of unintentional overdose death
To: cflansbaum@appriss.com

Mr. Flansbaum,

I am doing a peer review validity check of your retrospective study, NarxCheck Score as a Predictor of Unintentional Overdose Death.  Can you please send me the raw data for me to verify your data and results?  I have attached to this email Appriss publication referral to you for request of the raw data for independent analysis and study.  If I could also have the contact information for the individuals involved in the statistical calculations involved, I would appreciate it.

Sincerely,

Neil Anand M.D. 

I. ACTION REQUESTED

The Petitioner asks FDA to 

(1) deem Bamboo’s NarxCare software a misbranded device; 

(2) issue a Warning Letter to Bamboo; 

(3) commence mandatory recall procedures with respect to the NarxCare software; and 

(4) take any other prompt action the agency deems appropriate to prevent serious, adverse health consequences or death.

NarxCare is a clinical decision support (“CDS”) software product that meets the definition of a “device” under the FD&C Act. Yet, based on a search of FDA’s publicly available databases, it appears that the device’s manufacturer, Bamboo, is in violation of several provisions of the Act and its implementing regulations. Specifically, before introducing NarxCare into interstate commerce, Bamboo did not comply with the establishment registration, device listing, or premarket notification requirements set forth in Section 510 of the Act. 

“Therefore, FDA should deem NarxCare a misbranded device and take appropriate administrative action to prevent serious, adverse health consequences or death.

As explained herein, such administrative action is particularly important given that Bamboo’s software has fundamentally altered the practice of medicine in the U.S. to the detriment of patients with a legitimate need for controlled prescription medications and the health care providers who treat such patients.”

THE TIME FOR CHANGE IS UPON AMERICA

“…FROM COPS TO CLINICIANS…”

THEREFORE, We repeat this message to Our President, Congress, and Justice System. It is past time to move the mission of medical Control Substance Registration and licensing from Cops to the Clinician from Department of Justice to the Office of the United States Surgeon General in conjunction with FDA and, most importantly:

END 

The Nixon, Ford, Carter, Regan, Bush the First, Clinton, Bush the Second, Obama, Trump, Biden WAR ON DRUGS.

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FOR NOW, YOU ARE WITHIN

THE NORMS

REFERENCE;

1. (See exhibit 5-6F, Letter dated February 12, 2021, from: Thomas W. Prevoznik, DEA Deputy Assistant Administrator Diversion Control Division, to: Richard A. Lawhern, Ph.D. 3691 Nestling Lane Fort Mill, South Carolina 29708 lawhern@hotmail.com )

Thomas W. Prevoznik, DEA Deputy Assistant Administrator Diversion Control Division, LETTER To: KEVIN NICHOLSON, RPH. DATED NOVEMBER 04, 2019

 “The DEA lacks the authority to issue guidelines that constitute advice relating to the general practice of medicine. The DEA has not promulgated new regulations regarding the treatment of pain. Federal law and DEA regulations do not impose a specific quantitative minimum or maximum limit on the amount of 

2. (See exhibit 5-4D, letter dated November 04, 2019, from: Thomas W. Prevoznik, Deputy Assistant Administrator Diversion Control Division, to: Kevin N. Nicholson, R.Ph., J.D.Vice President, Public Policy and Regulatory Affairs National Association of Chain Drng Stores1776 Wilson Boulevard Suite 200 Arlington, Virginia 22209)

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