In an age of artificial intelligence, they are creating artificial stupidity.”
Thomas Sowell
“This finding does not affect the probity of Dr. Sullivan’s opinions as to the therapeutic effect of the subject medications, their contraindication with other prescribed medications, or the justification of their prescription.”
from youarewithinthenorms.com
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., SPIRIT OF REV. IN THE SPIRIT OF WALTER R. CLEMENT BS., MS, MBA. HARVEY JENKINS, MD, PH.D., IN THE SPIRIT OF C.T. VIVIAN, JELANI ZIMBABWE CLEMENT, BS., M.B.A., IN THE SPIRIT OF THE HON. PATRICE LUMUMBA, IN THE SPIRIT OF ERLIN CLEMENT SR., EVELYN J. CLEMENT, WALTER F. WRENN III., MD., JULIE KILLINGSWORTH, RENEE BLARE, RPH, DR. TERENCE SASAKI, MD 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., IN THE SPIRIT OF LEROY BAYLOR, JAY K. JOSHI MD., MBA, AISHA GARDNER, 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
THE CONGRESS MUST INVESTIGATE AND DEFUND THE UNITED STATES DRUG ENFORCEMENT AGENCY (DEA) AMERICA IS BETTER THAN THIS!!!
Charles Ogletree Esq; Harvard Law Professor:
…..from The Presumption of Guilt, the arrest of Henry Louis Gates Jr., …” I examine the race and class dimensions of the Gates arrest by looking at how other successful, prosperous, and noteworthy African American men (who are by no means alone in experiencing problems of racial profiling) have grappled with a wide range of encounters not only with police but with countless everyday citizens and found themselves being judged by the color of their skin rather than the content of their character.“…..
This collection of excerpts strongly criticizes the DEA and its use of expert witnesses, with a particular focus on Donald Sullivan and Timothy Munzing. These authors argue that their testimony is speculative, lacks scientific basis, and contributes to racial bias and “medical apartheid” within the drug enforcement system.
Drawing on a DEA judge’s observations and the American Medical Association’s perspective, the source contends that the DEA’s approach to pain management and prescription monitoring is flawed, leading to patient suffering and hindering legitimate medical practice, especially for practitioners of color. (see Briefing Documents End Notes)
There has been a deliberate conscious decision by the DEA-DOJ, the Federal Courts, and doctors such as Andrew Kolodny, Donald Sulivan, Timothy King, to deny people in pain access to medications like narcotic analgesics, benzodiazepines, a final solution, leading to their extermination, “letting them die off,” in what can be seen as govermental sanctioned medical genocide…; norman j clement,rph, dds
THE ANAND-CLEMENT RULE OF ARTIFICIAL STUPIDITY (THE AC RULE) [ AI (alg*)= AS ] AND INTIMATE KNOWLEDGE OF DESIGN: ABUSE IN LAW ENFORCEMENT
INTRODUCTION
THE PROBITY
DONALD SULLIVAN’S LONG HISTORY OF PROFESSIONAL, ACADEMIC FRAUD, JUDICIAL PERJURY AND MIS-REPRESENTATION
The year is 2010, the case docket 09-48, Columbus, Ohio. The United States Drug Enforcement Agency vs East Main Street Pharmacy (‘‘Respondent’’), of Columbus, Ohio, Harold Eugene Fletcher, PharmD from the record it reads,
The Government called Donald Sullivan, R.Ph., and Ph.D., as its expert witness. Dr. Sullivan, who holds active pharmacist licenses in Ohio and Florida, obtained a B.S. in Pharmacy from The Ohio State University, as well as both an M.S. and Ph.D. in Pharmaceutical Administration, also from The Ohio State University.
These sources present a strong critique of the DEA and its practices, particularly focusing on the role and perceived credibility of expert witnesses, such as Donald Sullivan, in cases against pharmacies.
The text examines instances where Sullivan’s testimony, based on factors like patient travel distance, is questioned by DEA judges and argued to be speculative rather than grounded in fact or science.
Furthermore, the sources connect these actions to broader issues of racial bias and “White Privilege” within the legal system and drug policy, suggesting a disproportionate targeting of minority practitioners.
“Ours may become the first civilization destroyed, not by the power of our enemies, but by the ignorance of our teachers and the dangerous nonsense they are teaching our children. In an age of artificial intelligence, they are creating artificial stupidity.”
Thomas Sowell
Between 1997 and 2006, Dr. Sullivan was an Associate Professor of Pharmacy Practice at Ohio Northern University. Thereafter, Dr. Sullivan was appointed to the rank of Full Professor and has served as Chairman of the Department of Pharmacy at Ohio Northern University for the past four years. (1)
During graduate school, Dr. Sullivan worked as a Registered Pharmacist at both retail and mail-order pharmacies.
He testified that he has worked at ‘‘several different independents in the central Ohio area’’ and that he currently works part-time as a pharmacist for North Central Mental Health. Dr. Sullivan was offered and accepted as an ‘‘expert witness” on standard pharmacy.
Before this Court, Professor Dr. Sullivan testified that under both Ohio and Federal law,
there ‘‘is corresponding responsibility between the physician and the pharmacist.’’ He further explained that ‘‘a lot of pharmacists think that just because the physician wrote it, I have to fill it.’’ However, Dr. Sullivan stated that there is nothing in Ohio law that says you have to fill any prescription.’’ He then explained that ‘‘one of the first things we try to get the students and pharmacist to understand is that under Ohio law, and federal law 50 percent of the responsibility falls on the pharmacy, the pharmacist, 50 percent falls on the physician. Don’t just fill it because the doctor wrote it.’’
DISCUSSION
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In this discussion, when clicking here, below, Attorney Ronald Chapman highlights concerns about misuse, misalignment, errors, and structural risks associated with AI systems, such as those used by Palantir.
Dr. Palantir’s AI algorithms aim to distill the vast array of human behavior into a manageable dataset.
Chapman points out in this discussion that human imagination, care, choice, and context are not easily quantified. Human life journeys are stories, not spreadsheets of data.
CLICK HERE TO LISTEN TO RONALD CHAPMAN ON FACTS AND FALLACIES PODCAST
EXPOSING THE FRAUDULENT WORK OF DR. DONALD R. SULLIVAN
Similarly, in his report, Dr. Sullivan, after discussing the CSA’s prescription requirement (21 CFR 1306.04(a)), explained that:
The State of Ohio has a similar language in its laws and regulations. Ohio Law states that the pharmacist who fills any prescription has a corresponding responsibility with the physician to ensure that the prescription has been issued for a Legitimate Medical Purpose.
The responsibility to ensure that a prescription is for a legitimate medical purpose in the usual course of a prescriber’s professional practice is equal for both the physician and pharmacist. (Fifty percent of this responsibility is on the pharmacist and 50% is on the physician.)
The argument that ‘‘Just because a physician wrote the prescription, however, the DEA Judge wrote in her observations of Dr. Donald Sullivan in 2010:
While the Ohio courts may have interpreted State law as described above, as explained below, Dr. Sullivan’s testimony that Federal law allocates fifty percent of the responsibility to the physician and fifty percent to the pharmacist is not a correct statement of the law, which has been amply explained in numerous decisions of the Federal courts and this Agency.
To make clear, Federal law does not apportion the responsibility for dispensing unlawful prescriptions between a prescribing practitioner and a pharmacist.
Instead, Federal law imposes separate and independent duties on the prescriber and the pharmacist.
More specifically, the prescriber must act within the usual course of professional practice and have
a legitimate medical purpose to issue a controlled-substance prescription lawfully. 21 CFR 1306.04(a).
As the Supreme Court and numerous Federal courts have made plain, to prescribe a controlled substance lawfully, the physician must act ‘‘by a standard of medical practice generally recognized and accepted in the United States.’’
CHAPMAN ON THE SIGNIFICANT UNDERSTANDING OF RUAN
Ronald W. Chapman II, Esq., LL.M., is a master of communication and persuasion, blending classical training in philosophy, rhetoric, and behavioral economics with modern expertise in law and strategy.
With a law degree and a Master of Laws (LL.M.) from Loyola University Chicago, Chapman has built a distinguished career as a federal criminal defense attorney, achieving an extraordinary 139 acquittals on federal counts in high-stakes cases.
The DEA Judge further notes:
” By contrast, a ‘‘pharmacist is not required to practice medicine.’’ United States v. Hayes, 595 F.2d 258, 261 (5th. Cir 1979). ‘‘What is required of [a pharmacist] is the responsibility not to fill an order that purports to be a prescription but is not a prescription within the meaning of the statute because he knows [or has reason to know] that the issuing practitioner issued it outside the scope of medical practice.’’
However, Dr. Sullivan’s statements that: (1) A pharmacist is not required to fill any prescription, and (2) it is not an excuse that because a doctor wrote the prescription, it can be legally filled, are consistent with Federal law.
According to Dr. Sullivan, as part of the prospective drug utilization review, a pharmacist is required to check a patient’s profile for the following: ‘‘(a) over-utilization or under- utilization[;] (b) therapeutic duplication[;] (c) drug-disease state contraindications[;] (d) drug-drug interactions[;] (e) incorrect drug dose or duration of treatment[;] (f) drug-allergy interaction[;] (g) abuse/ misuse[;] (h) inappropriate duration of treatment[; and] (i) documented good/nutritional supplements- drug interactions.’’
DONALD SULLIVAN’S LONG HISTORY OF PROFESSIONAL, ACADEMIC FRAUD AND JUDICIAL PERJURY CONTINUES
The year is 2020, the case docket 09-42, Tampa, Florida, the United States Drug Enforcement Agency vs Pronto Pharmacy LLC., Norman J Clement RPh, DDS, from the record it reads,
DEA Judge Mark D. Dowd writes:
“I question the sufficiency of the factual foundation for Dr. Sullivan’s expert opinion that the above prescriptions were an apparent attempt to mask scores of improper opioid prescriptions. The relevant medical records were not reviewed, the prescriber’s justification for the prescriptions was not considered by Dr. Sullivan, nor was the patient’s input as to the subject prescriptions considered. I find Dr. Sullivan’s subject opinion, on the basis of this record, to be improperly speculative and unjustified as an expert opinion.”
“This finding does not affect the probity of Dr. Sullivan’s opinions as to the therapeutic effect of the subject medications, their contraindication with other prescribed medications, or the justification of their prescription.”
CUDJOE WILDING BS. POLITICAL SCIENCE, STRATEGIC ADVISOR, articulates:
Here we are in the year 2020, and the overwhelming effects of “White Privilege” are still being levied unjustly and on the side of the privileged group.(8)
The above statements made by Administrative Law DEA Judge Mark Dowd are clearly reflective of his unbalanced application of the facts as they pertain to Dr. Sullivan’s questionable and problematic efforts. Judge Dowd himself indicates that Dr. Sullivan’s claim to be an expert in the subject matter is not supportable.
However, Judge Dowd failed to give any just consideration to the pharmaceutical practices and procedures of a real expert with well over 40 years of experience.
………“This finding does not affect the probity of Dr. Sullivan’s opinions as to the therapeutic effect of the subject medications, their contraindication with other prescribed medications, or the justification of their prescription.”………..
DEA Judge Dowd clearly indicates Dr. Sullivan’s subpar attempt to discredit Dr. Clement was carried out with honesty and strong moral principles.
Yet, Judge Dowd gave absolutely no consideration to the thoughts of morality, honesty, and basic human decency that Dr. Clement has displayed in his pharmaceutical practices for over 40 years. (8)
THE ARROGANCE OF HUBRIS“HOW WHITE PRIVILEGE CONTROLS DRUG POLICY”
DEA Judge Mark D. Dowd writes:
Dr. Sullivan demonstrated a comprehensive understanding of pharmacy practice and the distinctions between pharmacy compounding and manufacturing.
However, there were several matters for which he had diminished credibility. For one, he was unaware that Florida had codified the standard of care for medical personnel.
Although I later determined the statute in question did not apply to pharmacists, it was somewhat surprising he was unaware of it, as he teaches Florida pharmacy law, More problematically, he quickly agreed that it was consistent with his understanding of the standard of care for pharmacists in Florida, which was somewhat surprising, as the standard of care for medical personnel is highly generalized, a prudent healthcare provider standard.
The standard of care for pharmacists in Florida, as outlined in the relevant Florida regulations, is particularly detailed in detailing responsibilities and duties.
He arguably conceded an alternate generalized standard of care for pharmacists in Florida, which is not consistent with Florida law or regulation.
DEA Judge Mark D. Dowd writes:
Secondly, he gave inconsistent testimony regarding unresolvable red flags. He described several red flags as unresolvable, that no explanation could warrant the filing of the subject prescription. Later, he conceded that those same red flags could be resolved.
At one point, he suggested no single red flag was unresolvable; instead, it was the combination of red flags that made them unresolvable. Because of these inconsistencies, in the absence of a reliable principle or method employed by Dr. Sullivan, I don’t think his conclusions about his claim that certain red flags were unresolvable are valid. For each of the red flags that he testified were “unresolvable,” I accept his alternate opinion that each of those red flags remained unresolved in this matter, a finding supported by the evidence.
DEA Judge Mark D. Dowd writes:
“An expert, however, must base his knowledge on more than ‘subjective belief or unsupported speculation.” Daubert, 509 U.S. at 590 (discussing Federal Rule of Evidence 702). Without additional supporting evidence, I am unable to rely on Dr. Sullivan’s opinion regarding this red flag. The same will be true for the other patients for whom he raised a similar red flag to this one. I will, however, accept his opinion that prescriptions for opioids and low-dose non-controlled drugs raise a red flag to the extent that a low-dose non-controlled medication “doesn’t make sense” alongside a high-dose opioid. In other words, I accept his testimony that low doses of non-controlled drugs are suspicious because they do not make medical sense when prescribed with high doses of opioids. Still, I do not accept his testimony that any doctor prescribed those non-controlled drugs with the intent to cover illegitimate treatment.”
In contrast, the American Medical Association wrote on June 16, 2020:
While the AMA understands that the apparent goal of the CDC Guideline was to reduce opioid prescribing, we believe the proper role of CDC is to improve pain care. It follows that a dedicated effort must be made to rectify the damage caused by the misapplication of the CDC Guideline.
Angela Green’s America’s War on Doctors Briefing Analysis
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END NOTES
- DEPARTMENT OF JUSTICE Drug Enforcement Administration [Docket No. 09–48]East Main Street Pharmacy; Affirmance of Suspension Order
On April 23, 2009, the Deputy Assistant Administrator, Office of Diversion Control, Drug Enforcement Administration, issued an Order to Show Cause to East Main Street Pharmacy (‘‘Respondent’’), of Columbus, Ohio. The Show Cause Order proposed the revocation of Respondent’s DEA Certificate of Registration, BE5902615, as a retail pharmacy, as well as the denial of any pending applications to renew or modify its registration, ‘‘for reason that [Respondent’s] continued registration is inconsistent with the public interest, as that term is used in
2. Drug Policy Alliance, public notice, Scandal Ridden DEA, Everything you Need to Know https://www.drugpolicy.org/sites/default/files/DEA_Scandals_Everything_You_Need_to_Know_Drug_Policy_Alliance.pdf
3. AMERICAN MEDICAL ASSOCIATION JUNE 16, 2020, https://searchlf.ama-assn.org/undefined/documentDownload?uri=%2Funstructured%2Fbinary%2Fletter%2FLETTERS%2F2020-6-16-Letter-to-Dowell-re-Opioid-Rx-Guideline.pdf
4. Drug Policy Alliance: Its time to Dismantle the DEA https://www.drugpolicy.org/DEA
6. IN THE MATTER OF Pronto Pharmacy, LLC 1461 West Busch Boulevard Tampa, Florida 33612
Certificate of Registration Number FP2302076, U.S. Department of Justice, Drug Enforcement Administration, Springfield. VA 22!52, August 23, 2019 ORDER TO SHOW CAUSE AND IMMEDIATE SUSPENSION OF REGISTRATION PURSUANT to Sections 303 and 304 of the Controlled Substances Act, Title 21. United States Code. Sections 823 and 824.
7. Deborah Dowell, MD, MPH June 16, 2020
Page 9
8. America’s War on Drugs has played a profound role in reinforcing racial hierarchies. Although Black Americans are no more likely than Whites to use illicit drugs, they are 6–10 times more likely to be incarcerated for drug offenses. Helena B. Hansen, an assistant professor in the Department of Psychiatry at New York University, examines the recent history of White opioids to show how a very different system for responding to the drug use of Whites has emerged, in which addiction is treated primarily as a biomedical disease. Meanwhile, more punitive systems that govern the drug use of people of color have remained intact. At this seminar, Dr. Hansen argues that public concern about White opioid deaths creates an opportunity to reorient U.S. drug policy toward public health for all—and make proven harm reduction strategies widely available.
Briefing Document: Critique of the DEA and Its Expert Witnesses
This briefing document summarizes key themes and important facts from the provided source, “Critiquing the DEA and Its Expert Witnesses.” The source presents a scathing critique of the Drug Enforcement Agency (DEA), its judicial processes, and the credibility of its expert witnesses, particularly focusing on Donald Sullivan. A central underlying theme is the accusation of systemic racism and “White Privilege” influencing DEA actions and outcomes.
I. Core Arguments Against the DEA and its Operations
The document argues for a fundamental re-evaluation and defunding of the DEA, asserting that “AMERICA IS BETTER THAN THIS!!!”
- Lack of Fact-Based, Scientific Approach: Retired Neonatologist Keith Kanarek MD states that the DEA and its expert witnesses “operate under think and feel rather than fact-based on a foundation of science.”
- Presumption of Guilt and Racial Profiling: Harvard Law Professor Charles Ogletree Esq.’s work on “The Presumption of Guilt” is referenced, drawing a parallel to the Gates arrest, where African American men are “judged by the color of their skin rather than the content of their character.” This sentiment is echoed by Elizabeth Green DDS, who states, “This unlawful practice of singling out black practitioners must stop. When will we be permitted to practice and provide for our families in the same way that white America does?”
- Call for Congressional Investigation and Defunding: The document repeatedly calls for Congress, particularly the House Judiciary Committee and the Congressional Black Caucus, to “INVESTIGATE AND DEFUND THE UNITED STATES DRUG ENFORCEMENT AGENCY (DEA)” and “PUT AN END TO MEDICAL APARTHEID IN THE UNITED STATES OF AMERICA AND STOP THE TARGETING OF BLACK PHARMACIST.”
- “The Gorilla Theory” / “Good Ole Boy Network”: Debra H. Granny-Nanny and Willie Guinyard articulate the concept of “White privilege” and the “good ole boy network” where “no matter what the scientific evidence says that supports a learned person of color, it’s not enough. White privilege supersedes it all.” Guinyard further elaborates on historical parallels, stating, “if you wanted to get ahead or get out of jail you had to have a: ‘good ole white boy to sponsor you’.”
II. Critiques of DEA Expert Witness Donald Sullivan
A significant portion of the document focuses on discrediting Donald Sullivan, an expert witness frequently used by the DEA. He is accused of “PROFESSIONAL, ACADEMIC FRAUD AND JUDICIAL PERJURY” and being part of the DEA’s “CADRE OF JUNK SCIENCE-TIERS AND SUPER DEFRAUDERS OF THE AMERICAN TAXPAYER’S MONEY.”
- Contradictory and Speculative Testimony:Pharmacist Responsibility: In a 2010 case (DEA vs East Main Street Pharmacy), Dr. Sullivan testified that “50 percent of the responsibility falls on the pharmacy, the pharmacist, 50 percent falls on the physician.” However, the DEA Judge in that case explicitly stated that “Federal law does not apportion the responsibility… Rather, Federal law imposes separate and independent duties.”
- “Unresolvable Red Flags”: In the 2020 Pronto Pharmacy case, DEA Judge Mark D. Dowd notes Dr. Sullivan “gave inconsistent testimony regarding unresolvable red flags. He described several red flags as unresolvable… Later, he conceded that those same red flags could be resolved.” Judge Dowd ultimately rejected Sullivan’s conclusions on “unresolvable red flags” due to “inconsistencies, in the absence of a reliable principle or method.”
- Lack of Factual Foundation for Opinions: Judge Dowd “question[ed] the sufficiency of the factual foundation for Dr. Sullivan’s expert opinion that the above prescriptions were an apparent attempt to mask scores of improper opioid prescriptions,” noting that “The relevant medical records were not reviewed, the prescriber’s justification for the prescriptions was not considered by Dr. Sullivan, nor was the patient’s input as to the subject prescriptions considered.” He concludes, “I find Dr. Sullivan’s subject opinion, on the basis of this record, to be improperly speculative and unjustified as an expert opinion.”
- Lack of Knowledge of Florida Law: Judge Dowd points out Sullivan’s “diminished credibility” because “he was unaware that Florida had codified the standard of care for medical personnel,” despite teaching Florida pharmacy law. Sullivan also “arguably conceded an alternate generalized standard of care for pharmacists in Florida, which is not consistent with Florida law or regulation.”
- Failure to Review Patient and Prescriber Information: Critics, including Jack Folson RPh. and other commentators, highlight that Dr. Sullivan “never interviews the patients nor their prescribing physicians in his narrative of irrevocable flags” and relies on “Junk Science in their Courtroom testimonies.”
- Profiteering from Expert Witness Work: The document alleges that DEA “medical practitioner hustlers such as Donald Sullivan RPh., Phd., Timothy Munzing, MD., in Court Rooms who have been paid millions by the United States Federal Government.”
III. Criticisms of DEA Judge Mark D. Dowd
While Judge Dowd’s findings reveal inconsistencies and weaknesses in Sullivan’s testimony, the source criticizes Dowd for perceived bias and an “unbalanced application of the facts.”
- Disregarding His Own Findings on Sullivan’s Credibility: Cudjoe Wilding points out Judge Dowd’s statement that “This finding does not affect the probity of Dr. Sullivan’s opinions as to the therapeutic effect of the subject medications, their contraindication with other prescribed medications, or the justification of their prescription.” Wilding interprets this as Dowd asserting Sullivan’s “subpar attempt to discredit Dr. Clement was carried out with honesty and strong moral principles,” despite earlier questioning his expert opinion. Debra H. Granny-Nanny expresses disbelief, stating, “the fact that he bases his conclusion of law on Dr. Sullivan’s testimony that he found to be ‘improperly speculative and unjustified as an expert opinion … does not affect the probity of Dr. Sullivan’s opinions …’ exemplifies the glaring reality that no matter what the scientific evidence says that supports a learned person of color, it’s not enough. White privilege supersedes it all.”
- Dismissal of Patient Travel as a “Red Flag”: Judge Dowd rejected Sullivan’s claim that the 38-mile roundtrip distance from a patient’s home to the pharmacy was a “red flag,” stating it was “not overly suspicious on its face.” However, he accepted the 134-mile distance from the patient’s home to the doctor’s office as a red flag. The source suggests Dowd was “so busy trying to be a bigot, so busy trying to be a racist” that he “couldn’t be fair.”
IV. The American Medical Association (AMA) vs. DEA’s “Opioid War” Narrative
The AMA’s June 16, 2020 letter to the CDC is presented as a strong counter-argument to the DEA’s approach to the “Opioid War” and its “Prescription Red Flag Crusade.”
- Shift in Opioid Epidemic Focus: The AMA asserts that “The nation no longer has a prescription opioid-driven epidemic. However, we are now facing an unprecedented, multi-factorial, and much more dangerous overdose and the drug epidemic is driven by heroin and illicitly manufactured fentanyl, fentanyl analogs, and stimulants.” They advocate for moving beyond a “prescription opioid-myopic lens.”
- Critique of CDC Guideline Misapplication: The AMA highlights that the CDC Guideline has been “misapplied” to “deny access to legitimate pain care and non-consensually taper patients.” They urge the CDC to “specifically address this in the revised CDC Guideline.”
- Patient-Centric Approach to Pain Management: The AMA emphasizes individualized treatment decisions, acknowledging that “some patients benefit from opioid therapy—including at doses that some may consider “high.”” They call for “more compassionate patient care,” “comprehensive care delivered in a patient-centric approach,” and “removing the stigma that patients with pain experience on a regular basis.”
- Barriers to Non-Opioid Care: The AMA points out the “Catch-22” where physicians are told to use non-opioid options, but “payers and other make them financially or administratively unavailable.” They urge the CDC to help end practices like prior authorization, step therapy, and other limits on reimbursement for multidisciplinary care.
- Concerns about “Doctor Shopping” Accusations: The AMA expresses concern that “a careful approach to identifying the precise combination of pharmacologic options could be flagged on a prescription drug monitoring program as indications wrongly interpreted as so-called “doctor shopping” and cause the patient to be inappropriately questioned by a pharmacist.” They advocate for “physicians and pharmacists to work together rather than jumping to conclusions about a patient’s PDMP report.”
- Consideration of Social Determinants of Health: The AMA recommends that discussions about pain management “must account for the treatment options accessible to the patient based on their health condition, social determinants of health (e.g. transportation, employment, childcare responsibilities, race, gender, age) and insurance coverage.” This directly contradicts the DEA expert’s use of patient travel distance as a “red flag.”
V. Implications and Calls to Action
The document concludes with strong calls for immediate and systemic change, driven by concerns of racial injustice and a failing system.
- Increased Heroin Use as a Consequence of DEA Actions: Jack Folson RPh. argues that the “criminalization of pain management suffering has increased and has led, to an increase in Heroin use. Due to the dangers associated with heroin use this, more than anything else, in this case, is an immediate threat to public safety.” He concludes, “To put it plainly the actions by the DEA are causing the thing that they are trying to avoid.”
- Racial Bias in Drug Policy: The source references Helena B. Hansen’s work, which highlights that “Although Black Americans are no more likely than Whites to use illicit drugs, they are 6–10 times more likely to be incarcerated for drug offenses,” demonstrating a “very different system for responding to the drug use of Whites…in which addiction is treated primarily as a biomedical disease.”
- Erosion of Justice and Morality: Deb Hargrove describes “THE SYSTEM” as “so eroded that a total defunding would aid rebuilding the brick and mortar basics.” She states, “Not only is the moral fabric of this system decayed, but the soul of civilization has stepped back into the darkest depths of ‘humanity’.”
- Academic Fraud Allegations: The document reiterates calls for Donald Sullivan to be investigated and terminated by Ohio State University for “Professional and Academic Fraud charges.”
In summary, the document paints a picture of a DEA operating under flawed principles, relying on questionable expert testimony, and perpetuating racial injustice within the judicial system, ultimately causing more harm than good in the fight against drug abuse.
