This continuing education offering is written specifically for pharmacists and pharmacy technicians in New Jersey.

Transcription

1 Select CE This continuing education offering is written specifically for pharmacists and pharmacy technicians in New Jersey. Select CE is accredited by the Accreditation Council for Pharmacy Education as a provider of continuing pharmacy education. Program Title: Target Audience: Medical Marijuana in New Jersey Pharmacists and Pharmacy Technicians in New Jersey Release Date: November 4, 2010 Expiration Date: November 3, 2012 ACPE Program No.: H03-P knowledge-based activity or H03-T knowledge-based activity Accreditations: This continuing education activity is approved by approved by ACPE for 1.0 contact hour, or 0.10 C.E.U. s, for pharmacists and pharmacy technicians in all 50 states under our trade name Select CE. Media: Enduring print material, and at Fee Information: $15.00 Estimated Time to Complete the Activity: 60 minutes Procedures: To receive a Statement of Credit, read this program, complete the post-test questions and evaluation on the Answer Sheet, and either: i) mail the Answer Sheet and the program fee of $15.00 to us. You will receive a Statement of Credit mailed to you within 2 weeks. Checks or money orders are encouraged. Mail to: Select CE, P.O. Box 21186, Columbus, Ohio Refunds are not provided. or ii) use our online test-taking website Follow the instructions on the website, using any major credit card to pay the $15 program fee. Upon passing the test, you will receive immediate confirmation via , and your official Statement of Credit will be sent via U.S. mail within 5 days but in most cases within 2 days. Refunds are not provided, unless you mistakenly make too many online payments or some such other online snafu. A minimum score of 70% is required to earn a Statement of Credit.

2 Faculty: Patricia A. Nussle, R.Ph., J.D., is the founder of Pharmacy Jurisprudence and Select CE. She is also a healthcare attorney who has written and published continuing education programs in pharmacy law and nursing law for over 200,000 healthcare professionals since Disclosure of Commercialism, Unlabeled Uses, Bias, Conflicts of Interest: Prior to the delivery of the content, we will disclose any commercial support, and we do so here: No commercial support was requested or accepted for developing or presenting this program. All development, printing and mailing costs come solely from your program fees. No unlabeled uses of drugs are discussed in this program. Faculty Patricia A. Nussle, Pharmacy Jurisprudence and Select CE have no real, apparent, or potential conflicts of interest or financial relationships to disclose. Patricia A. Nussle is the owner of Pharmacy Jurisprudence and Select CE, and she warrants that she presents this information fairly and without bias. Objective: At the conclusion of this program, pharmacists should be able to recognize at least 5 attributes of New Jersey s Compassionate Use Medical Marijuana Act (the Act ) and the rules proposed by the New Jersey Department of Health and Senior Services to effectuate the Act. Objective: At the conclusion of this program, pharmacy technicians should be able to recognize at least 5 attributes of New Jersey s Compassionate Use Medical Marijuana Act (the Act ) and the rules proposed by the New Jersey Department of Health and Senior Services to effectuate the Act. Important Note: Colleagues, this is a continuing education program. It is not legal advice. Do not rely on this CPE program as legal authority. If you do have a legal problem or question, please consult an attorney experienced in pharmacy law matters to discuss your specific situation. Questions: Please call us at (614) We are not always in the office, so ing may be quicker at info@selectce.org. Did You Know - Our company was born in 2001, out of our need for law CPE programs because we were living out of state and were unable to find Ohio-approved law CE programs. Since then, we have become one of the largest law CPE providers in Ohio, and have expanded our offerings to include nursing law CE programs in Ohio, and we are ACPEaccredited for pharmacists and technicians in all states as well. - Because we do not take pharma or other monies, we too have real jobs like you. And, we close our offices for several extended periods each year so that we can live out our passion, which is: - Helping the desperately poor to help themselves through health and education clinics in developing countries. In 2003 and 2004, your fees helped set up a lead-screening clinic in a remote village in Peru. In 2005, your fees helped deliver fistula surgery to women in Africa, in 2006 your fees helped build an elementary school in Ethiopia, and in 2007 and 2009 your fees helped provide wells for clean water in Malawi, Africa. Thank You! We truly enjoy serving you! 2

3 Medical Marijuana in New Jersey History In January 2010, the New Jersey Compassionate Use Medical Marijuana Act (the Act ) was passed into law in New Jersey. 1 The Act, which will be more fully described below, sets forth the broad parameters of law. The details of the law and how to implement the law were given to the commissioner of the Department of Health and Senior Services (the Department or DHSS ). Until the commissioner of the Department issues its proposed rules, and the public has an opportunity to comment on the proposed rules, the law itself is essentially ineffective. This is typically how laws (passed by legislatures) and rules or regulations (promulgated by state agencies) work in tandem in most states, including New Jersey. The legislators decide the big picture and leave it to an appropriate state agency with expertise and staff to figure out the details. The law cannot be implemented until the state agency completes the rules. In this situation, the Act specifically directed the commissioner of DHSS to: promulgate rules and regulations to effectuate the purposes of this act. The regulations shall establish: the application and renewal form, process and fee schedule; and the manner in which the department will consider petitions from the public to add debilitating medical conditions to those included in this act. On October 6, 2010, the Department of Health and Senior Services released its draft rules outlining the registration and application process for patients, primary caregivers, physicians, cultivators and dispensaries. 2 Question 1: New Jersey s Compassionate Use Medical Marijuana Act: a) was passed into law in January 2010; b) cannot be implemented until the Department of Health and Senior Services (DHSS or Department) promulgates rules to effectuate the purposes of the law; c) both of the above are true. These administrative rules are draft rules, meaning the rules are not final and do not become binding on citizens in New Jersey until several more steps are completed, including publication in the New Jersey Register, which the Department planned to do on November 1, After publication in the New Jersey Register, concerned citizens generally have a minimum of 30 days and usually 60 days to submit comments, information or arguments concerning any portion of the rules. Mid-October 2010 However, on October 15, 2010, the Department met with a vocal group of about 200 angry stakeholders. The stakeholders, who were advocates, patients, and potential program applicants, expressed concern that the medical marijuana program is nearly inoperable as it is proposed due to the strictness of the proposed rules. The stakeholders called on the sponsor of the Act, Senator Scutari, to demand the Department withdraw or modify its proposed regulations. "The regulations are making it impossible to implement the medical marijuana statute that was signed into law," agreed Senator Nicholas Scutari (D-22). 3 The state's proposed regulations announced Oct. 6 would go into effect in January 2011, allowing two growers (called cultivators in the proposed regulations) and four clinics (called dispensaries in the proposed regulations) to produce and distribute the medical marijuana. The 2 cultivators and 4 dispensaries, collectively known as alternative treatment centers under the proposed regulations, would be chosen in February 2011 and the first medical marijuana would then be available in the summer of

4 Gov. Chris Christie, a former federal prosecutor, has said he does not want to deny sick patients access to marijuana, but he has insisted that New Jersey's regulations be strict. He has said he does not want New Jersey to be like California, whose medical marijuana law is generally seen as lax. 4 The Objective of this Continuing Education Program Here we see two sides of a controlled substance issue (marijuana s active ingredients, the tetrahydrocannabinols, are currently classified as a Schedule I controlled substance 5 ) that will no doubt affect pharmacists and pharmacy technicians in New Jersey. Other states such as Oregon have re-classified marijuana to a Schedule II controlled substance, which recognizes the profession of pharmacy and our existing drug distribution safeguards for tracking and monitoring drugs of abuse. 6 This does not mean that medical marijuana is available by prescription in Oregon, because there are currently no FDA-approved forms of it. Only time will tell if, when and how medical marijuana will be legally available to any patient in New Jersey. In the meantime, the purpose of this continuing program is to give you, the practicing pharmacist or pharmacy technician, information about: a) New Jersey s Compassionate Use Medical Marijuana Act (the Act ); and b) the rules proposed by the New Jersey Department of Health and Senior Services to effectuate the Act. New Jersey Compassionate Use Medical Marijuana Act In January 2010, the New Jersey Compassionate Use Medical Marijuana Act (the Act ) was passed by the New Jersey legislators by comfortable margins (48-14 in the General Assembly and in the State Senate), and signed into law by then-governor Jon Corzine. Question 2: New Jersey s Compassionate Use Medical Marijuana Act was passed into law: a) by a slim margin; b) with the signature of then-governor Jon Corzine; c) without any governor s signature. Question 3: Among the reasons the Act was passed by the legislature include: a) medical research shows the beneficial use of the drug in alleviating pain; b) the desire to arrest anyone possessing the drug; c) the desire to put New Jersey out of compliance with current federal law. Why? In passing this law, the legislature made several key findings about the use of marijuana, and made clear its reasons for passing the law: 7 2. The Legislature finds and declares that: a. Modern medical research has discovered a beneficial use for marijuana in treating or alleviating the pain or other symptoms associated with certain debilitating medical conditions, as found by the National Academy of Sciences' Institute of Medicine in March b. According to the U.S. Sentencing Commission and the Federal Bureau of Investigation, 99 out of every 100 marijuana arrests in the country are made under state law, rather than under federal law. Consequently, changing state law will have the practical effect of protecting from arrest the vast maj ority of seriously ill people who have a medical need to use marijuana

5 c. Although federal law currently prohibits the use of marijuana, the laws of Alaska, California, Colorado, Hawaii, Maine, Nevada, Oregon, Vermont, Washington and Montana permit the use of marijuana for medical purposes, and in Arizona doctors are permitted to prescribe marijuana. New Jersey joins this effort for the health and welfare of its citizens. d. States are not required to enforce federal law or prosecute people for engaging in activities prohibited by federal law; therefore, compliance with this act does not put the State of New Jersey in violation of federal law. e. Compassion dictates that a distinction be made between medical and non-medical uses of marijuana. Hence, the purpose of this act is to protect from arrest, prosecution, property forfeiture, and criminal and other penalties, those patients suffering from debilitating medical conditions, and their physicians and primary caregivers, if such patients engage in the medical use of marijuana. Key Elements of the Act The key elements are summarized for you below, with underlining added for ease of reading and italics indicating exact language used in the Act: 8 A) a qualifying patient must have a registry identification card to possess and use medical marijuana; B) a qualifying patient means a person who has been diagnosed by a physician as having a debilitating medical condition and a written certification of that diagnosis; C) a written certification" means the qualifying patient's medical records, or a statement signed by a physician with whom the patient has a bona fide physician-patient relationship, stating that in the physician's professional opinion, after having completed a full assessment of the qualifying patient's medical history and current medical condition, the qualifying patient has a debilitating medical condition for which recognized drugs or treatments are not or would not be effective and the potential benefits of the medical use of marijuana would likely outweigh the health risks for the qualifying patient; D) "Debilitating medical condition" means: Question 4: Under the Act, a qualifying patient must: a) be diagnosed by a physician as having a debilitating medical condition and a written certification of that diagnosis; b) have tried and failed to gain relief from all other controlled substances; c) be in hospice care. (1) cancer, glaucoma, positive status for human immunodeficiency virus, acquired immune deficiency syndrome, or the treatment of these conditions; (2) a chronic or debilitating disease or medical condition or its treatment that produces one or more of the following: cachexia or wasting syndrome; severe or chronic pain; severe nausea; seizures, including, but not limited to, those characteristic of epilepsy; severe and persistent muscle spasms, including, but not limited to, those characteristic of multiple sclerosis or Crohn's disease; or (3) any other medical condition or its treatment that is approved by the department by regulation. E) "Bona fide physician-patient relationship" means a physician has completed a full assessment of the patient's medical history and current medical condition, including a personal physical examination

6 These key elements of the Act cannot be modified by any agency, and seem to indicate that New Jersey s legislature worked to balance the needs of patients against the needs of society to closely regulate a drug with high abuse potential. Facts pointing to this include: a clearly defined debilitating medical condition which can be expanded only by the Department. The bona fide physician-patient requirement should eliminate problems that arose from internet pharmacy stores and pill mills that appear overnight and disappear the next day one step ahead of the law. Once all requirements are met, a qualified patient must obtain a valid registry identification card, so that caregivers, health care professionals and law enforcement can be assured that the patient s medical marijuana possession and use is within the bounds of the law. Question 5: Under the Act, debilitating medical conditions include: Draft Rules Proposed by DHSS to Effectuate the Act We ve spent the previous portion of this program outlining the Act as passed by the New Jersey legislature. Now, we re turning attention to the controversial rules proposed by the Department of Health and Senior Services on October 7, 2010 to effectuate the purposes of the Act. 9 a) cancer and AIDS; b) severe and persistent muscle spasms; c) both of the above. Are New Jersey s Medical Marijuana Rules Like Other States Rules? We have designed a clinically sound program that is unique to New Jersey. It is a physician-driven program that provides access to qualified patients for whom conventional treatment has failed and who may benefit from medicinal marijuana as a symptom reliever. The program is also designed to ensure that patients receive ongoing medical care from a physician who is managing their chronic debilitating illness, says Health and Senior Services Commissioner Dr. Poonam Alaigh. 10 What Does the Draft Rule Propose To Do, and When? According to DHSS, under the draft rule physicians should be able to register electronically with the Department in late October After their credentials are verified, doctors will submit names of patients they are recommending for medicinal marijuana for debilitating medical conditions. Patients whose names have been submitted by their physician will be able to register beginning in November 2010 and will be issued photo identification cards by the end of Next, applications will be made available for entities interested in applying as Cultivators and Dispensaries. The applications are expected to be available November 1 and will be reviewed by a selection committee early in Cultivation and processing of medicinal marijuana is anticipated in March or April of 2011 and should be available to qualified patients by summer The draft rule proposes that Cultivators and Dispensaries be categorized as Alternative Treatment Centers (ATCs). Two (2) of the ATCs will be Cultivators and four (4) will be Dispensaries. All of the ATCs will be not-for-profit organizations. The ATCs would be located in each region of the State: north, central and south. The Dispensary ATCs will also have the ability to apply to the Department for one satellite location in their region. In addition, the 4 Dispensary ATCs will also have to provide educational materials and counsel patients on aspects of treatment including the risks and benefits of using medicinal marijuana. As a result of all of the work done by the Department and stakeholders, we are optimistic the program will provide for compassionate use of medicinal marijuana by qualified patients in a medical model, Commissioner Alaigh said

7 Why Are Some Stakeholders, and the Senator That Sponsored the Act, Opposed to the Department s Proposed Rules? According to some stakeholders, the Department did not effectuate the purposes of the Act as it is obligated to do by the Act, but instead imposed additional restrictions so cumbersome that the Department s actions contravened the Act itself. The full 97 pages of proposed rules can be found at In the following 6 pages, we summarize portions of these proposed rules that stakeholders have suggested are too restrictive, or contravene the Act. In response, the Department says its proposed rules are not restrictive, but are consistent with the intent of the law. 11 For Physicians and Patients In addition to the bona-fide physician patient relationship set forth in the Act, the rules propose that a physician: - must have been treating the patient for at least one year; or - must have seen the patient at least four times; or - assumes responsibility for providing management and care of the patient s debilitating medical condition after conducting a comprehensive medical history and physical examination, including a personal review of the patient s medical record maintained by other treating physicians reflecting the Question 6: patient s reaction and response to conventional medical therapies. 12 In addition, the treating physician must certify to the following: I have completed a comprehensive history and physical on this patient and have documented an assessment and treatment plan. This patient has not responded to conventional medical treatment as defined by evidence-based algorithms of care and may benefit from the use of medicinal marijuana. I have provided education to the patient on the lack of scientific consensus for the use of medical marijuana, its sedative properties, and the risk of addiction. The patient has provided informed consent. I will continue to follow this patient at a minimum every three months and reassess the patient s debilitating medical condition and responses to treatment options. 13 Diagnosis The proposed rules modify the definition of debilitating medical condition so that: Under the Department s proposed rules, a physician who prescribes medical marijuana must: a) certify that a patient has not responded to conventional medical treatment as defined by evidence-based algorithms; b) certify that he/she will follow the patient at least every 3 months, and will reassess the patient s responses to treatment options; c) do both of the above. - The diagnosis of seizure disorder, epilepsy, intractable skeletal muscular spasticity, or glaucoma no longer qualifies alone; in addition, the physician must certify that conventional medical treatments were exhausted first The diagnosis of HIV, AIDS, or cancer no longer qualifies alone; in addition, the patient must experience severe or chronic pain, severe nausea or vomiting, cachexia, or wasting syndrome. - A medical condition of cachexia or wasting syndrome; severe or chronic pain; severe nausea; seizures; severe and persistent muscle spasm no longer qualifies alone. These medical conditions must be linked to one of the qualifying diagnoses above Proposed New Rules: N.J.A.C. 8: Definitions 13 Proposed New Rule 8: Physician certification 14 Proposed New Rules: N.J.A.C. 8: Definitions 7

8 - However, new diagnoses not linked to symptoms do qualify under the proposed rule, and these are amyotrophic lateral sclerosis, multiple sclerosis, terminal cancer, muscular dystrophy, or inflammatory bowel disease, as well as a terminal illness, if the physician has determined a prognosis of less than 12 months of life. Question 7: - Any new debilitating medical condition is added after a review process by the Department which includes: a person s petition, a review by a panel selected by the Department, public comment, and 2 public annual reports by the Department regarding the person s petition. For Caregivers and Patients - A fee of $200 is required of each person requesting application or renewing an application to be a qualified patient or as a primary caregiver of a qualified patient. - A primary caregiver can only serve one qualified patient, and cannot be the patient s physician. - At the time of application to be a qualified patient, the patient must choose one Dispensary from which the patient will purchase his or her medical marijuana. For Cultivators - The number of Cultivators of medical marijuana is limited to two. Under the Department s proposed rules, debilitating medical conditions include: a) cancer; b) cancer, if the patient also suffers from severe or chronic pain, severe nausea or vomiting, cachexia or wasting syndrome; c) in addition to (b) above, cancer if the patient has less than 12 months to live. Question 8: Under the Department s proposed rules, Cultivators of medical marijuana: a) are limited to 2 in the state; b) will maintain records of each ingredient used in the growing process, including the date of receipt of each ingredient, the vendor s batch number and the grade of each batch of ingredient; c) both of the above. - Each Cultivator could produce no more than three strains of tetrahydrocannabinol, or THC, the active ingredient in marijuana, of less than 10 percent. Stakeholders claim that more than 10% THC is needed to bring pain and other relief to patients, and no other state has this limit. - Each Cultivator shall maintain records identifying the source of each ingredient used in the manufacture or processing of marijuana, including the source of each ingredient, the date of receipt of the ingredient, ingredient vendor s name and address, the name of the ingredient and the vendor s batch number, lot number, control number or other identifying symbol, if any, used by the vendor to identify the ingredient as well as the grade (such as U.S.P., N.F., reagent, technical or crude) and quantity of said ingredient. - Labeling requirements are extensive, and require pre-approval of the label by the Department. For Dispensaries - The number of Dispensaries is limited to four. - Each Dispensary can only fill medical marijuana prescriptions for patients who pre-select their particular Dispensary, as indicated on the patient s registry identification card. - Two (2) Dispensary employees shall weigh, log-in and sign-out quantities of packaged usable marijuana to perform dispensing. - Dispensaries cannot sell food, beverages, alcohol or tobacco. 8

9 - People on the grounds of the Dispensary cannot consume food or beverages. - Each Dispensary s limit is two (2) ounces of no more than 10% THC to each qualified patient per month. - Each Dispensary would keep pain management records, which will include a system for documenting a patient s selfassessment of pain and/or primary qualifying symptom using a pain rating scale, and if serving different patient populations shall make more than one pain scale available for patient use, as appropriate. - Each Dispensary will document a patient s self-assessment of pain or primary qualifying symptom upon commencement of the dispensing of medical marijuana to the patient and thereafter at three-month intervals. This record of a patient s self-assessment of pain shall be given to each patient for use and information in consulting with his or her physician as to the use of medical marijuana to address the patient s qualifying debilitating condition. - Each Dispensary shall provide log books to registered qualifying patients and registered primary caregivers who request them to keep track of the strains used and their effects. For Alternative Treatment Centers both Cultivators and Dispensaries The proposed rules for Alternative Treatment Centers require annual reports to the Department. The reports will include: 8: Alternative Treatment Center Reporting requirements: The facility shall collect and submit to the Department for each calendar year at least the following statistical data: - number of registered qualified patients and registered primary caregivers, - debilitating medical conditions of qualified patients, - number of registered qualified patients receiving residential home delivery, - patient demographic data, - program costs, and, - summary of patient surveys and evaluation of services, and - such other information as may be required by the Department. 15 Because of its security concern, the Department will require each of New Jersey s Cultivators and Dispensaries to equip both themselves and the Department with video surveillance: 8:64-9.7(b) Security. At minimum, each alternative treatment center shall: - Equip interior and exterior premises with electronic monitoring, video cameras, and panic buttons. A video surveillance system shall be installed and operated to clearly monitor all critical control activities of the ATC and shall be in working order and operating at all times. The ATC shall provide two monitors for remote viewing via telephone lines in state offices. This system shall be approved by the Department prior to permit issuance; - Limit entry into areas where marijuana is held to authorized personnel; - Consistently and systematically prevent loitering, that is, the presence of persons who are not on-duty personnel of the ATC and who are not ATC registrants engaging in authorized ATC-dispensary activity; and - Provide on-site parking. 16 Question 9: Under the Department s proposed rules, Dispensaries: a) must be a pharmacy; b) must document a patient s selfassessment of pain or primary qualifying symptom at the first fill and every month thereafter; c) must provide, upon request, log books to patients to keep track of the strains of medical marijuana used at page 26 9

10 More For Alternative Treatment Centers both Cultivators and Dispensaries Because pharmacists and pharmacies are the keeper of New Jersey s drug supply, including all controlled substances, a natural presumption would be for pharmacies to apply to become Dispensaries. However, the proposed rules would prohibit nearly all pharmacies from applying, because of the requirement that Dispensaries be not-for-profit organizations. Other proposed rules that would make it difficult for pharmacies and pharmacists to become a Dispensary include: - a $20,000 application fee, of which $18,000 is refundable if the application is denied; - the named applicant and each subcontractor or affiliate to the entity named in the application shall submit: - a list of the names, addresses, and dates of birth of the proposed ATC employees, principal officers, owners, and board members, including service on any other ATC board; - a list of all persons or business entities having five percent or more ownership in the ATC, whether direct or indirect and whether the interest is in profits, land or building, including owners of any business entity which owns all or part of the land or building; - the identities of all creditors holding a security interest in the premises, if any; - the by-laws and a list of the members of a medical advisory board, none of whom shall be employees, officers, or board members of the ATC, and consisting of at least three licensed health care professionals, at least one of whom is a physician, and at least two community members; - evidence of the principals, board members, owners, and employees to cooperate with a criminal history record background check pursuant to N.J.A.C. 8:64-7.2, including payment of all applicable fees associated with the criminal history record background check which shall be paid by the ATC or the individual; Question 10: Under the Department s proposed rules, Dispensaries: a) must install video surveillance equipment and provide 2 monitors to the Department; b) must document involvement of a New Jersey acute care hospital in its organization; c) both. - written verification of the approval of the community or governing body of the municipality in which the alternative treatment center is or will be located. 17 A selection committee of the Department will evaluate each application for Cultivators and Dispensaries using the following criteria: - Submission of mandatory organizational information; - Documented involvement of a New Jersey acute care general hospital in the ATC s organization; - Ability to meet overall health needs of qualified patients and safety of the public; and - Community support and participation. 18 Conclusion New Jersey s Compassionate Use Medical Marijuana Act (the Act ) was passed into law in New Jersey in January The proposed rules to implement the Act were released in October Patients, health care professionals, and others have expressed concern that the Act and the proposed rules are not consistent at page at page at page

11 We hope that by completing this CE program, you are aware of some key elements of both the Act and proposed rules. Select CE This continuing education offering is written specifically for pharmacists and pharmacy technicians in New Jersey. Return this ANSWER SHEET with the $15.00 Program Fee payable to: Select CE P.O. Box Columbus, Ohio NAME: ADDRESS: CITY, STATE and ZIP: ANSWERS: Medical Marijuana in New Jersey Expiration Date: November 3, 2012 Circle the answer for each question (questions are imbedded in the program). 1. a b c 6. a b c 2. a b c 7. a b c 3. a b c 8. a b c 4. a b c 9. a b c 5. a b c 10. a b c 13. Pharmacists: After completing this program, I am able to recognize 5 attributes of New Jersey s Compassionate Use Medical Marijuana Act ( Act ) and the rules proposed by the New Jersey Department of Health and Senior Services to effectuate the Act: Yes No 13. Technicians: After completing this program, I am able to recognize 5 attributes of New Jersey s Compassionate Use Medical Marijuana Act ( Act ) and the rules proposed by the New Jersey Department of Health and Senior Services to effectuate the Act: Yes No 14. This program was an effective way for me to learn: Yes No 15. I liked the program s format: Yes No 16. This program fostered my mental participation: Yes No 17. This was a user-friendly way for me to learn: Yes No 18. I could sense some commercialism in this program: Yes No If yes, please describe: 19. The faculty quality was: Great OK Needs to Improve 20. The learning material quality was: Great OK Needs to Improve 21. How long did it take to complete this program? 22. What other topics would you like to see? 23. Comments welcome: 11

12 Pharmacy Jurisprudence, L.L.C. also doing business outside Ohio as Select CE P.O. Box Columbus, Ohio Pharmacists, Look Inside! Contains Pharmacy-law CE programs. We have more CE programs at Questions? Call us at (614)