IAPC Letter to MCI Board of Governors

IAPC Letter to MCI Board of Governors

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Date: - 26th May, 2020

The Telemedicine Practice Guidelines were issued on the 25 March 2020 by the BOARD OF GOVERNORS In supersession of the Medical Council of India in partnership with the NITI Aayog. It includes a Prohibited List, the medicines included in which, an RMP providing consultation via telemedicine cannot prescribe. The list includes medicines under Schedule X of Drug and Cosmetic Act and Rules or any Narcotic drug and Psychotropic substance listed in the Narcotic Drugs and Psychotropic Substances, Act, 1985.The Indian Association of Palliative Care (IAPC) applauds this caution for general safety and completely supports these measures as these medicine have a high potential of abuse and could harm the patient or the society at large if used improperly.

However, there are patients for example, in advanced stages of cancer, who suffer with severe unremitting persistent pain that affects their every activity, and cause serious suffering. Essential Narcotic Drugs (ENDs)[1] are the only effective analgesics in these patients. Ends come under the NDPS Act and Rules[2].

To maintain safe and rational use of ENDs, the IAPC recommends that in-person evaluation be mandated for initiating the prescription of ENDs, while refills may be allowed through tele-consultation. We also request for permission to switch one END with another when deemed necessary, for continuing to treat the same pain condition effectively.

Please find the recommendation (highlighted in yellow) for modifying the List A drugs, under ‘Specific Restrictions ‘listed in the Table (Matrix of the permissible drug lists based on the type and mode of consultation), under section 3.7.4 of the Telemedicine Practice Guidelines in Appendix 1.

We request the Board of Governors to view this with consideration and ensure that the patients with persistent severe pain such as seen in cancer continue to have access and availability to these essential medicines[3].

Thanking You

Dr. Sushma Bhatnagar

IAPC, President

Prof & Head

Dept. of Onco-Anaesthesia &

Palliative Medicine

Dr. B.R.A IRCH, AIIMS

[1]Morphine Sulphate, Methadone, Fentanyl Citrate as per END listed in this order. http://cbn.nic.in/html/END05052015.pdf
[2]ENDs are controlled by the NDPS Rules amended in 2015 http://cbn.nic.in/html/NDPS3rdamend.pdf
[3]National List of Essential Medicines of Indiahttps://pharmaceuticals.gov.in/sites/default/files/NLEM.pdf