One of the primary restrictions that ketamine clinics run into when retaining a Management Services Organization (MSO) are fee-splitting prohibitions. Fee splitting is a state law concept and can vary from state to state. In some instances, though, fee-splitting can also lead to issues under the federal healthcare fraud and abuse laws, as discussed below.
Ketamine telehealth just got a big lifeline. On April 12, 2022, the Department of Health and Human Services (HHS) renewed its determination that a public health emergency (PHE) exists due to COVID-19. Obviously, this has been a hugely controversial move even if the renewal is only good for 90 days. This 90 day extension is
This article was originally published on Bill of Health, the blog of Petrie-Flom Center at Harvard Law School, as part of a digital symposium, A Macro View of Microdosing. In light of the widespread cultural and business culture adoption of microdosing, private sector employers should reconsider the implications of a blanket prohibition on workplace use of controlled substances. What
On Friday, April 1, 2022 the Oregon Health Authority (OHA) released revised proposed Oregon Administrative Rules (OARs) for psilocybin services. These rules focus on psilocybin products, testing, and training programs. There will be public hearings on these rules on April 18 and April 21, 2021. In part one, we covered the rules related to psilocybin
On Friday, April 1, 2022 the Oregon Health Authority (OHA) released revised proposed Oregon Administrative Rules (OARs) for psilocybin services. These rules focus on psilocybin products, testing, and training programs. There will be public hearings on these rules on April 18 and April 21, 2021. In part one of this series, we covered the rules
On Friday, April 1, 2022 the Oregon Health Authority (OHA) released revised proposed Oregon Administrative Rules (OARs) for psilocybin products, testing, and training programs. This post will focus on the rules related to products. Readers of this blog will recall we reviewed an early draft of these administrative rules back in February. Unsurprisingly, the rules
Ketamine clinics are run by various provider types in the United States. In some states, mid-level practitioners (e.g., Nurse Practitioners and Physician Assistants) can practice independently. In other states, such providers can only work independently if they are supervised or overseen by a physician. However, the question then becomes whether any physician can run a
Over the past few years, access to mushrooms containing psilocybin has become much easier in Vancouver, British Columbia, Canada. There are now four dispensaries that sell psilocybin mushrooms in the city, including two locations downtown, one located on Commercial Drive, and one located on the Downtown Eastside. The prevalence of these dispensaries has made it
The outlook for psychedelics legalization in Washington State, and specifically psilocybin legalization, looks promising and continues to evolve at a rapid pace. The Spokane Bar Association recently held a seminar on emerging issues in the Washington psychedelic ecosystem. In October, Seattle became the largest in the United States to decriminalize psychedelics. As the second largest
Time for another Oregon psilocybin licensing update. In this post we will explain what the Licensing Subcommittee covered in its recent meeting on March 3, 2022. Licensing Subcommittee Schedule and Timelines The Licensing Subcommittee meets every month to develop licensing requirements for psilocybin businesses and professionals. So far, it has developed recommendations regarding informed consent
