Medical cannabis policy review
Just prior to the legalization of non-medical cannabis in Canada, 58.3% (7/12) of the identified provincial/territorial nursing regulatory bodies had policies or statements related to cannabis. This included practice statements and guidelines, position papers, and frequently asked questions (FAQs) that addressed nursing practice issues related to cannabis. The majority of regulatory bodies with policies on medical cannabis addressed nurses’ role related to the administration of medical cannabis, including information about possession, distribution, and administration within specified locations (i.e., hospitals). Not all regulatory bodies, however, made a distinction between nurses assisting with administration versus directly administering medical cannabis to authorized patients. In addition, nurses were cautioned to check with their employers’ policies prior to engaging in care related to medical cannabis. In many cases, cannabis was mentioned within the regulatory bodies’ documents related to controlled substances, in which it was delineated as a substance that NPs were not allowed to authorize. The only exception, at the time of the study, was Ontario, which had a policy that allowed NPs to authorize medical cannabis to eligible patients, and Nova Scotia, which allowed pharmaceutical forms of cannabis to be prescribed by NPs.
Practice consultant interviews
In Canada, there are a total of 12 nursing regulatory bodies representing 11 provinces and 3 territories. A total of 8 participants from 7 nursing regulatory bodies responded and agreed to be interviewed regarding their regulations, policies and standards, as well as the practice issues they were currently experiencing, related to medical cannabis. There was representation from both Western (n = 3) and Eastern Canada (n = 3), as well as Northern Canada (n = 1). Of the 7 regulatory bodies represented, 5 had policy statements on medical cannabis (71.4%). Practice consultants from the remaining five regulatory bodies either indicated that participating in a research study was not considered the purview of a regulatory body (n = 4) or no response was received despite two follow-up invitations (n = 1).
Out of the 7 regulatory bodies included in this study, none reported at the time of the study developing regulations that permitted NPs to authorize medical cannabis within their region. With regards to the administration of medical cannabis, there was a great deal of confusion and trepidation among practice consultants regarding the ACMPR and the role of registered nurses. Several consultants spoke of the “ambiguity” of the language in the federal regulations regarding whether registered and licensed practical nurses could assist patients in self-administration versus directly administer cannabis to patients unable to do so themselves. Others interpreted the federal regulations as not authorizing nurses to directly administer medical cannabis to patients. In addition, several consultants raised concerns regarding the specificity of the ACMPR in limiting nursing practice related to medical cannabis to hospital settings only, excluding nurses working in community settings: “Our direction now is that nurses can only directly administer [medical cannabis] in a hospital or a long-term care setting and cannot directly administer in a home setting.” All consultants, however, spoke of the need for nurses to be competent and have the necessary knowledge, skills and training to provide safe care related to medical cannabis. To this end, some of the regulatory bodies referred nurses interested in incorporating medical cannabis into their practice to general medication administration standards. Further, registered nurses were encouraged to consult their employers regarding any pertinent policies related to medical cannabis.
According to the consultants interviewed, the 2017 CNPS document was influential in how their regulatory body approached the issue of medical cannabis. Several of the colleges consulted with the CNPS in crafting their response to nurses inquiring about the inclusion of medical cannabis in their clinical practice. Nurses were also encouraged to individually consult with CNPS about their practice concerns related to cannabis. The ambiguity in the federal regulations led several of the regulatory bodies to encourage the CNPS to advocate for changes to the federal regulations regarding nurses’ scope of practice in relation to medical cannabis.
We’ve advocated to CNPS that because community nursing is really the heart and soul of how we can care for our community, this is what’s actually the barrier for us in making sure that our nurses are protected and able to care for patients appropriately.
Future plans regarding medical cannabis regulations
The majority of practice consultants indicated their regulatory bodies were waiting for the legalization of non-medical cannabis before moving forward with any changes to their current nursing regulations and standards related to medical cannabis.
It’s under review and I know that there will be changes to federal legislation, but we don’t know what that is so we don’t really know what the implications could be to our practice standards yet.
In the meantime, a few regulatory bodies were moving forward with education and practice initiatives. This included the development of a regulatory framework for the authorization of medical cannabis by NPs, and a “practice direction” outlining the standards that must be met in order for NPs to participate in the authorization of medical cannabis [
10].
Barriers to nurses’ engagement in care involving medical cannabis
Beyond the lack of clear federal regulations, several barriers were identified that prevented nurses from being more actively engaged in care related to medical cannabis. Foremost, the absence of practice guidelines regarding dose and administration was perceived to pose a significant challenge to NPs being able to authorize medical cannabis. Several consultants spoke about “prescriptions”, comparing medical cannabis to pharmaceutical medication, and how it violated standard medication administration principles:
With medical cannabis, there is no established best practice guidelines, there’s no dosage for a registered nurse or a nurse practitioner if they were writing it as a prescription, there’s no dosage and it hasn’t been approved by Health Canada.
Personal and structural barriers were also identified with regards to nurses’ clinical engagement with medical cannabis. Some nurses were perceived as holding values or beliefs that could lead to a moral dilemma in assisting patients using medical cannabis. As one consultant shared: “I think there are issues around biases and nurses wanting to or not wanting to be involved in administering cannabis, for personal reasons or viewpoints.” In addition, several consultants indicated that many healthcare organizations currently lack policies regarding the use of medical cannabis in their facilities, leaving nurses feeling confused and unsupported regarding how to address cannabis as part of their practice. Moreover, the occupational health and safety issues related to patients using inhaled forms of cannabis, especially in home care settings, and exposing nurses to second-hand smoke further complicated the potential role of nurses in distributing and administering cannabis.
Facilitators of nurses’ engagement with medical cannabis
Increasing nurses’ competency was perceived by many consultants as being integral to the inclusion of medical cannabis within nurses’ scope of practice:
If we had any practitioners that were going to be engaging with this [medical cannabis], we would establish parameters for some kind of education or training as an expectation of regulation that we would want people to undertake before they engage in that practice.
To achieve this competency, the consultants were supportive of the inclusion of cannabis within NP training programs as well as the development of continuing education for those nurses already in practice. In some regions, funding was available for nurses interested in pursuing medical cannabis education. Many of the consultants, however, were very clear that from the perspective of a regulatory body, each nurse had to self-determine what knowledge, skills, abilities, and competencies were required in order to safely provide medical cannabis care.
Given the aforementioned barriers and policy challenges, it was not surprising that having consistent and harmonized medical cannabis regulations and policies at the federal, provincial/territorial and institutional level were identified as being a key facilitator to supporting nurses’ engagement with medical cannabis at point of care. Such policies would ensure nurses were legally protected in handling, distributing and administering medical cannabis, or as one consultant framed it, “guard their practice.”
Several practice issues related to cannabis were raised by the consultants. Following legalization, there was a belief that nurses would need to be able to assess for problematic use within general and disease-specific populations (e.g., mental health). In turn, nurses would need to become more informed about harm reduction strategies specific to cannabis. Knowledge of the indications, contraindication and adverse effects, as well as appropriate storage and disposal, of medical cannabis was also described as being an essential part of future nursing care.
A final point raised by several consultants was the use of cannabis by nurses themselves. Consultants agreed that nurses must self-determine their own fitness to practice following the consumption of cannabis as part of their accountability as a nurse. Those practicing impaired would be subject to sanctions and those suspecting impairment would have a duty to report such behaviour. As one consultant shared:
There is an assumption that they have to be fit to practice … I think everyone realizes that they are held to being accountable for their own practice and their own decisions and their own fitness to practice in those choice. Those people that are making choices that might impact their fitness to practice will have to accept the consequence if that is being reported. We have to trust that people are going to do the right thing.
Several consultants, however, pointed out how “tough” determining fitness to practice is in relation to cannabis consumption, requiring not only blood or urine tests, but also measures of cognitive and behavioural functioning that are not easily measured. Another consultant pointed out the complexity of the fitness to practice concept in the context of medical cannabis use:
If they’re using it for a medical reason, have they actually become more fit to practice because it’s helped with that symptom that they’re having and now that that symptom is gone, they are more fit to practice and the cognitive side effect or other side effects are limited?