Prescription Drug Abuse Backgrounder for DGC Mike Metatawabin Political/Media Campaign on NAN Prescription Drug Abuse State of Emergency

To: DGC Mike Metatawabin From: Leesa Wabasse, Health Policy Analyst Date: February 11, 2011 cc: NAN Executive Council; David Fletcher, Executive Director; Amy Harris, Director of Communications; and Health Policy and Planning Department staff

ISSUE SUMMARY

In November 2009, the Nishnawbe Aski Nation (NAN) Chiefs declared a Prescription Drug Abuse State of Emergency as a result of the prescription drug abuse crisis in NAN First Nations. The NAN Executive Council has been mandated to secure government commitment to address the epidemic in the NAN First Nations.

BACKGROUND

Prescription Drug Abuse is a current issue that is affecting Nishnawbe Aski Nation (NAN) communities and encompasses areas such as health, social, law enforcement, legal, child welfare and education. This problem is undermining the physical, mental, spiritual and emotional well‐being of NAN First Nation members and communities.

Prescription Drug Abuse has been recognized as a NAN‐wide problem through resolutions 06/54 (NAN‐Wide Strategy to Address Drug & Solvent Abuse); 08/40 (Key Assumptions for Prescription Drug Abuse Strategy); 09/09 (NAN Prescription Drug Abuse Task Force); and have endorsed the Chiefs’ Forum on Social Issues, Answering the Call for Help: Reducing Prescription Drug Abuse in Our Communities, ‘Mamow Na‐Ta‐Wii‐He‐ Tih‐Sowin: Healing Together declaration.

DGC MIKE METATAWABIN CORRESPONDENCE:

1) December 14, 2009 correspondence from DGC Metatawabin to: Dr. Valerie Gideon, Regional Director, FNIH‐OR; Leigh Jessen, A/Regional Director, INAC Region; , Minister of Health and Long‐Term Care Deputy Grand Chief Mike Metatawabin PDA Backgrounder

(MOHLTC) and; Minster , Minister of Community and Safety and Correctional Services (MCSCS).

The December 14th, 2009 correspondence was a follow‐up to the Prescription Drug Abuse State of Emergency that was declared by the NAN Chiefs in November 2009 (Resolution 09/92).

The letter advocated for discussions specific to:  enhanced community‐based programming, including trained workers NNADAP, Mental Health, Addiction Specialists and others as determined by the First Nations;  resources for security and;  Land‐based programming.

2) Dr. Valerie Gideon, Regional Director, FNIH‐OR letter of response (December 18, 2009) proposed the following:

Identify multidisciplinary professional support team members to assist communities in developing their strategies.

NOTE: FNIH‐OR contracted three individuals to collect data from four (4) NAN communities in the Sioux Lookout Zone to demonstrate there is a problem with prescription drug abuse. The Community Wellness Team was established unilaterally by FNIH‐OR and did not involve NAN in the process. Reports by the Community Wellness Teams have not been shared with NAN and/or obtained directly from the First Nations.

Review and finalize an “Addressing Prescription Drug Abuse and Misuse at the Community Level” tool.

NOTE: This document was finalized in January 2010; available on the Ontario Prescription Drug abuse website that is hosted by K‐Net.

Contact K‐Net to develop a website and consider options for a toll‐free information line.

NOTE: The Ontario Prescription Drug Abuse website was launched in March 2010; to date, no toll‐free information line has been set up.

Coordinate multi‐agency meetings to discuss how to establish a continuum of support services for individuals and communities.

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NOTE: FNIH‐OR coordinated multi‐agency meetings with SLFNHA/Meno‐Ya‐Win (and others?); NAN made numerous requests to be invited to the multi‐agency meetings with no success.

Develop an evaluation framework to assist communities in tracking progress on community‐based strategies and;

NOTE: Status not known.

To participate, as required, in the Chiefs of Ontario coordinated approach to the development of the Ontario First Nations Prescription Drug Abuse Strategy.

NOTE: The Ontario Prescription Drug Abuse Strategy was completed in November 2010. All PTOs and Independent First Nations in Ontario received funding to consult First Nations on the draft COO PDA Strategy.

In addition to the above, Dr. Valerie Gideon, FNIH‐OR coordinated conference calls and two face‐to‐face meetings with INAC, Ministry of Health and Long‐Term Care (MOHLTC) and the Ministry of Aboriginal Affairs between January 2010 to November 2011.

With the exception of FNIH‐OR and INAC committing to cost‐share (50%) a NAN Prescription Drug Abuse Coordinator position for a total of $100,000, no other significant milestones were achieved and/or major commitments/decisions made.

NOTE: During meetings, MOHLTC representatives repeatedly stated that they do not have jurisdiction on‐reserve. It should also be noted that MOHLTC was largely focused on Bill 101: Narcotics Safety and Awareness Act which received Royal Assent in November 2010. The five (5) key elements of the Narcotics Strategy are as follows:

 Proposed narcotics tracking system (and supporting legislation)  Partnering with the health care sector to educate on appropriate prescribing  Partnering with the health care sector to educate on appropriate dispensing  Educate to prevent excess use of prescription narcotics  Addictions Treatment

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3) Response from INAC, MOHLTC and MCSCS on NAN Prescription Drug Abuse State of Emergency correspondence:

No formal response received from INAC and MOHLTC.

Minister Bartolucci, MCSCS response stated that the issues raised fell under the jurisdiction of MOHLTC despite the prescription drug abuse issue crossing many sectors, including on‐reserve Policing. NOTE: MCSCS provides 48% of funding for the NAPS agreement and 52% is funded by the Federal government.

4) December 14, 2009 correspondence from DGC Metatawabin to: Royal College of Physicians and Surgeons of Canada; Ontario College of Pharmacists and; Ontario Medical Association.

The correspondence recommended policies to be developed to:  Reduce accessibility to Opioid prescription drugs for non‐medical use by completing a thorough screening process;  to establish treatment plans;  to educate on the risks/benefits;  periodic reviews to determine other treatment methods that would benefit patients;  referrals to chronic pain/addiction specialists and;  to implement a tracking system such as triple scripting to identify double doctoring and; to increase physician, pharmacist, and patient accountability.

In addition to the above, assistance and expertise was sought in developing best practices and policies that are aimed at improving the health of NAN First Nation members, as well as cooperation in bringing together relevant sectors to work collectively in addressing the prescription drug abuse epidemic.

5) March 19, 2010 Letter of response from Dr. Rocco Gerace, Registrar, College of Physicians and Surgeons of Ontario (CPSO):

Acknowledged NAN Prescription Drug Abuse State of Emergency and agreed that the complexity of the issue requires the collaboration of many stakeholders.

Invited NAN to forward complaints and/or concerns of individual doctors regarding professional misconduct or incompetence.

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Dr. Gerace acknowledged :  some CPSO members could benefit from greater education and guidance on the appropriate use of opioid drugs for the treatment of chronic non‐ malignant pain;  there may be some reluctance by some physicians to prescribe opioids due to its status as a narcotic and;  physicians may not appropriately manage drug‐seeking individuals and/or those engaging in double doctoring.

Provided information on the National Opioid Use Guideline Group (NOUGG), which was formed in November 2007 in response to:

 Physicians and other stakeholders seeing guidance regarding safe and effective use of opioids;  A growing concern about opioid misuse creating patient and public safety issues and;  The lack of systematically developed national guidelines on opidid use for chronic non‐cancer pain.

NOTE: The NOUGG was comprised of a research team and national panel that included pain specialists, family physicians, addiction experts and pharmacists. The Canadian Guideline for Safe and Effective Use of Opioids for Chronic Non‐ Cancer Pain was completed on April 30, 2010; the guideline is a tool to promote the appropriate use of opioid drugs across Canada.

6) January 4, 2011 correspondence from DGC Metatawabin to Dr. Valerie Gideon, Regional Director, Health Canada FNIH‐OR:

Re: NAN Chiefs’ resolution 10/63 Health Canada Non‐Insured Health Benefits Suboxone Approval demanding that the NIHB program approve the use of Suboxone for the medical detoxification of NAN members that request the medication.

The letter argued: 1) Methadone is not available in remote NAN First Nations and that NAN First Nations have expressed an interest in using Suboxone to better support individuals who wish to overcome their addiction to Opiate drugs; 2) that NAN sees the drug, Suboxone in stabilizing First Nation members/communities in a more humane way.

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Requested for Nursing Stations to be adequately stocked with ancillary drugs, i.e., Clonidine, Trazadone, NSAIDS and Gravol for individuals undergoing voluntary or involuntary withdrawal; requested ancillary drugs to be available in a timely manner, i.e., immediate access versus waiting a set number of days for the shipment of medication to reach communities.

Requested FNIH‐OR to advocate for Suboxone to be placed on the Health Canada Non‐Insured Health Benefits (NIHB) Drug Formulary.

Recommended FNIH‐OR to develop emergency plans in the event a mass number of individuals undergo withdrawal as a result of increased security efforts in NAN communities.

7) Dr. Valerie Gideon, Regional Director, FNIH‐OR letter of response (January 11, 2011):

Response: requests for Suboxone are reviewed on a case‐by‐case basis by the Drug Exception Centre; NIHB Regional Pharmacist working with NIHB HQ to develop Suboxone criteria.

Highlighted that key points for Suboxone to be considered in program development include the following:  Suboxone cannot be stocked in Nursing Stations. All Suboxone treatment must be dispensed as a patient‐specific prescription;  The dose of Suboxone during Opiate withdrawal must be monitored and adjusted daily; necessitates daily access to physician services for client assessment; not within the Registered Nurses’ scope of practice to perform assessments.  Detoxification with Suboxone must be planned in order to ensure sufficient time for coverage approval and shipping time from the pharmacy.

Confirmed that ancillary drugs such as Clonidine, Gravol and NSAIDS are all “must stock” items in Nursing Stations; the Nurse‐in‐Charge responsible for inventory management should be notified if a Nursing Station depletes its stock of medications.

Confirmed that Trazodone is not currently on the Nursing Station formulary, however, Physicians can request the addition of this medication as a stock item, and that the FNIH Ontario Region Pharmacy and Therapeutics Committee reviews such requests.

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NOTE: Trazodone is used for treating depression, insomnia and anxiety. There is a 40% Nursing Shortage in the Sioux Lookout Zone.

Indicated willingness and support for First Nations leadership to develop emergency plans in the event mass withdrawal occurs in communities. Initial steps to be taken by FNIH‐OR would be to ensure ancillary medications are stocked in Sioux Lookout so that Nursing Station stock can be quickly replenished should a mass withdrawal situation occur in a community.

NOTES: Unlike Methadone and Suboxone, ancillary drugs do not block the Opioid receptors in the brain to stop drug cravings and/or drug seeking behavior among individuals with an addiction to Opioids.

Ancillary drugs currently being used for Opioid Withdrawal:

Target Symptoms Drug Nausea and vomiting ‐ Dimenhydrinate (Gravol ®) Diaarrhea ‐ Loperamide (Immodium ®) Myalgias [muscle pain/aches] ‐ Acetaminophen (Tylenol ®) ‐ Naproxen (Naprosyn ®) Anxiety, Dysphoria [state of feeling ‐ Hydroxyzine (Atarax ®) unwell or unhappy; emotional and mental discomfort; restlessness]; Lacrimation [tears]; Rhinorrhea [runny nose]. Insomnia, Anxiety and Depression ‐ Trazodone Hypertension [High Blood Pressure] ‐ Clonodine

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8) November 29, 2010 letter from DGC Metatawabin to Minister Leona Aglukkaq, Health Canada requesting a meeting to discuss prescription drug abuse, youth suicide and related mental health needs.

The letter to Minister Aglukkaq included copies and information on the following resolutions:

1) NAN Prescription Drug Abuse State of Emergency 09/92 declared by the NAN Chiefs in November 2009. The immediate government commitments NAN Chiefs were seeking were: enhanced community‐based programming, including trained workers, improved security and land‐based programming.

2) Sioux Lookout Zone Chiefs Resolution 09/11 adopting Strategies to End Prescription Drug Addiction in the Sioux Lookout Zone First Nations: establishment of a treatment centre in the Sioux Lookout Zone First Nations and enhanced training of community‐based staff to ensure there are sufficient resources to fulfill their job duties.

3) Eabametoong First Nation Band Council Resolution 2010/2011‐66 declaring a State of Emergency after experiencing 3 murders, 73 drug‐related incidents, 61 assaults, 47 arson cases with 35 structural fires since January 2010 and requirement for extra financial and human resources.

4) Resolution 07/88 Support for the establishment of a regional treatment centre to include detoxification, treatment, maintenance and aftercare programming in Constance Lake First Nation.

5) Resolution 09/82 Support for development of the Keewaytinook Okimakanak Stormer Lake Development Complex‐Comprehensive Treatment Program.

6) Shibogoma Chiefs Resolution 2007‐08/32 for Family and Child Treatment Centre.

The letter highlighted that the abuse of highly addictive narcotic prescription drugs, such as OxyContin remains a serious concern, particularly as it relates to the harmful effects on the physical body and unborn child, the risk for Hepatitis C and HIV/AIDs, family violence, risk for suicide and the potential for death by overdose when combined with alcohol.

The letter stated that NAN First Nations have been reporting addiction rates of 50 – 90% in communities; the epidemic has created an added strain on NAN First Nations across many sectors, such as increased homicides and other crime‐related incidents

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and, that a NAN high school has an Opioid addiction rate of 42%, which is more than double the provincial rates of addiction for grades 7 to 12.

The letter noted that Methadone treatment programming is not available in any of the 29 NAN remote First Nations, but is being used by road accessible First Nations; advocated that First Nations, who are witnessing a large number of people going through painful withdrawal symptoms have expressed an interest in using Suboxone for short‐term detoxification and; requested approval for Suboxone for community physicians.

The letter emphasized: mainstream addiction services are not available or culturally‐ appropriate for NAN members and there are long wait times for NAN First Nation members wishing to access Treatment Services; there is a lack of Treatment Centres specializing in Opioid addiction; as well as the requirement for clients with a dependency to Opioids to undergo detoxification prior to entering treatment.

The Health Canada Minister was advised that First Nations are dealing with an epidemic of Opiate‐based Prescription Drug addiction during a Physician and Nursing shortage; an ongoing suicide epidemic that has been plaguing the NAN territory since the late 80s and; other serious mental health issues, such as the ongoing effects of Residential Schools.

Lastly, the Health Canada Minister was informed that heightened security efforts are underway in the NAN First Nation community through increased search and seizures and aviation security measures for contraband detection; the heightened security efforts creates a potential for a medical crises in the event a mass number of people undergo Opioid withdrawal at the same time.

9) Response from Minister Leona Aglukkaq – Health Canada

To date, no formal response has been received, however, in January 2011, A/Regional Director‐FNIH‐OR, Susan Russell advised NAN that Minister Aglukkaq was seriously considering the meeting request. A briefing on all agenda items was requested from NAN.

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10) January 21st, 2011 letter to Minister Leona Aglukkaq, Health Canada (January 21, 2011) regarding Public Health Strategy on Mental Health & Addictions.

This letter was further to correspondence sent on November 29, 2010 requesting a meeting to discuss prescription drug abuse, youth suicide and related mental health needs.

The letter underscored the fact that the opiate addiction rate is of a magnitude not seen anywhere else in Canada’s remote First Nations, and included a quote from the a Sioux Lookout Zone study that stated: “while impossible to determine the extent of Prescription Drug Abuse, anecdotally as many as 80% of the adult population uses prescription drugs illicitly in some communities”.

Other statistics provided:  Injecting drugs has increased Hepatitis C infections (4‐fold increase) and increases risk of HIV infection. NOTE: this stat is specific to the Sioux Lookout Zone.  Narcotic exposure during pregnancy increased from 8.4% in the first six months of 2009, to a high of 17.2% in the first six months of 2010. Of the neonates experiencing narcotic withdrawal, 66% of affected infants were exposed to daily maternal use of OxyContin. NOTE: these stats are specific to the Sioux Lookout Zone.  427 NAN First Nation members lost to suicide in the past two decades.

Requested funding to begin developing a strategy to contain, intervene and prevent the ongoing destruction among First Nation members in the NAN territory based on the mandate from NAN Chiefs’ resolution 10/64 Public Health Strategy on Mental Health & Addictions.

Advocated for new Treatment Centres, as well as the adapting and updating of existing Treatment Centres that are within the NAN territory.

Advocated for community detoxification and counseling programs and emphasized that intervention closest to the home community will better meet the needs of clients and families.

Included NAN Chiefs’ resolution 10/63 NIHB Suboxone Approval, as well as correspondence between DGC Metatawabin and former FNIH‐OR Regional Director, Dr. Valerie Gideon.

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11) Response from Minister Leona Aglukkaq – Health Canada

No formal response received.

12) Grand Chief Stan Beardy lobby for Dennis Franklin High School Students

On February 3, 2011, letters were written to: Minister Leona Aglukkaq, Health Canada, Minister Deb Matthews, Ministry of Health and Long Term Care (MOHLTC), and Premier Dalton McGuinty for funding of the Opioid Detoxification proposal for Dennis Franklin Cromarty High School Students (DFC).

Contents of the letter: ‐ The proposal by DFC was in response to an addiction rate of 42% among students. ‐ The proposal outlined a medically‐supervised 14‐day Suboxone Detoxification project; Health Canada approved Suboxone drug costs, Aftercare, Transportation and Evaluation. ‐ Informed Premier Dalton McGuinty and Minister Deb Matthews that Dr. Valerie Gideon, former Regional Director for FNIH‐OR indicated that “Provincial services of the Physican and Nursing Practitioners are outside of the mandate of programs that I currently manage” and requested the North West Local Health Integration Network (LHIN) CEO Laura Kokocinski to consider funding the Physician and Nursing components of the proposal. ‐ Informed the government representatives that the DFC Principal was verbally advised on February 1, 2011 that funding from the LHIN is unavailable despite having led Health Canada to believe that the LHIN would co‐fund the proposal; the lack of funding from LHIN was placing the federal funding approvals in jeopardy. ‐ Requested assistance and support from Minister Aglukkaq, Premier Dalton McGuinty and Deb Matthews in compelling the LHIN to reconsider their decision. ‐ The letter also argued for the proposal to be funded directly from MOHLTC since the Province has retained its authority for public health and physicians. ‐ The letter to Minister Aglukkaq requested immediate consideration to approval funding for the DFC proposal.

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13) Response from Premier Dalton McGuinty, Minister Deb Matthews and Minister Leona Aglukkaq – Health Canada

In a March 3rd letter to Grand Chief Stan Beardy, Premier Dalton McGuinty stated that Minister Matthews, MOHLTC would provide a response and that MOHLTC was working with the North West Local Health Integration Network on the issue.

The Premier affirmed commitment in working with Aboriginal communities in the delivery of better health care, education, economic opportunities and justice for Aboriginal people in Ontario; Minister Chris Bentley, Ministry of Aboriginal Affairs and Minister Matthews, MOHLTC copied on correspondence.

No formal response received from Ministers Mathews and Aglukkaq.

14) April 21, 2011 Letter to Minister Deb Matthews, MOHLTC and Minister Broten, Ministry of Children and Youth Services (MCYS) and ADM Deborah Richardson, Ministry of Aboriginal Affairs (MAA) re: NAN Prescription Drug Abuse State of Emergency

Letter to request joint meeting regarding the NAN Prescription Drug Abuse State of Emergency.

Background information and statistics on the scope of the problem within NAN territory provided; highlighted challenges related to the ongoing NAN youth suicide crisis, Nursing Physician shortage, lack of Mental Health and Addictions services and facilities, and remoteness.

15) Response from Minister Matthews, Minister Broten and Deborah Richardson:

‐ No response received from Ministers Matthews and Broten.

‐ Deborah Richardson, MAA responded to indicate a joint meeting between Ministers was in the process of being arranged, offered to meet with NAN to explore opportunities on PDA, and made reference to the Trilateral First Nations Health Senior Officials Committee which has identified Mental Health and Addictions as an immediate priority.

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16) May 26th Correspondence to Sony Perron, NIHB Director General, Health Canada

The letter to Sony Perron, NIHB Director General was specific to Health Canada NIHB Suboxone Approval as per NAN Chiefs resolution 10/63; requested consideration for Pilot Project approval for the use of Suboxone in NAN First Nations, as well as NIHB approval for Subutex for prenatals.

NAN requested Health Canada to not await the evaluation and results of the DFC High School Suboxone Pilot Project prior to providing further approvals for Suboxone for First Nations that wish to proceed with community‐based and/or land‐based Opioid detoxification.

17) Response from Sony Perrron, NIHB Director General

No response.

18) Correspondence to Minister Deb Matthews, MOHLTC

July 19th letter re: July 26th meeting ‐ NAN statistics on PDA were provided; letter stated there has been minimal response from both levels of government on the NAN PDA State of Emergency declared by NAN Chiefs in November 2009; emphasized the urgent need for financial resources to address PDA in the NAN territory; urged the Minister to implement the Narcotics Strategy to stop the flow of illicit opiate drugs to NAN communities; extended support for the statement in Bill 101, “support for and reduce narcotics‐related addictions and narcotic‐related deaths” for work with prescribers of opiate drugs, especially OxyContin and partnerships with other regulatory bodies. NAN requested support to focus immediately on the 4th and 5th key elements of Bill 101 ‐ Narcotics Safety and Awareness Act specific to Education, Awareness and Addictions Treatment.

NAN submitted the Prescription Drug Abuse Task Force proposal (Resolution 09/09 and 11/20) and the NAN‐Grand Council Treaty #3 community‐based proposals.

August 5th, 2011 – Letter to Minster Matthews re: follow up to July 26th meeting and reiterated that the State of Emergency declaration by NAN Chiefs in November 2009 has resulted in minimal response from both levels of

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government, and that the epidemic is continuing to escalate with untimely deaths from overdoses, deaths related to poly substance abuse, i.e., opiates combined with alcohol, as well as suicides among NAN First Nation members with a known addiction to opiates.

The letter stated that the high opioid addiction rates within the NAN territory will no doubt create additional burdens on Ontario’s health care system with Hepatitis C, potential for increased HIV/AIDS, more infants requiring longer term hospitalization following birth due to opiate withdrawal and/or complications common among babies with fetal exposure to highly addictive drugs such as OxyContin.

NAN requested MOHLTC: ‐ To prioritize the Opioid Addiction Treatment needs of NAN First Nations, many of which are remote and geographically isolated, and have no access to Methadone Maintenance Treatment. ‐ For access to Suboxone through the Ontario Drug Benefits program for NAN First Nation members on Ontario Works and/or disability for community‐ based detoxification. ‐ To sit on the NAN PDA Task Force. ‐ To provide $200,000 start up funds of $200,000 for the NAN PDA Task Force.

August 29th, 2011 letter to Minister Matthews re: follow up to July 26th meeting and August 5th letter; second request for interim funding of $200,000 for the NAN PDA Task Force and MOHLTC was asked to respond to NAN’s invitation to the NAN PDA Task Force.

19) Response from Minister Deb Matthews, MOHLTC

Letter dated September 29th, 2011 from Diane McArthur, ADM indicated a response from MOHLTC could take up to a month. On November 15th, MOHLTC advised a response may take several weeks.

20) Correspondence to Minister Leona Aglukaaq, Health Canada (July 27, 2011)

The letter from Grand Chief Stan Beardy was a follow up to the cancellation of Minister Aglukaaq’s July 26th tour due to the forest fire situation and evacuations within the NAN territory. Grand Chief Stan Beardy requested a new date for the meeting be confirmed as soon as possible.

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(NOTE): The first meeting scheduled with Minister Aglukaaq was during the AFN Special Chiefs’ Assembly in December 2010 and was cancelled; the September 13th meeting between NAN and Minister Aglukaaq was confirmed and subsequently cancelled. No new meeting date has been confirmed.

21) Response from Minister Leona Aglukaaq, Health Canada to the July 26th letter

No response received to date.

22) August 2nd, 2011 letter to Sony Perrron, NIHB Director General

Re: follow up to May 26th, 2011 correspondence requesting Pilot Project approval for Suboxone in NAN First Nations and/or access to Suboxone through the NIHB program.

23) Response from Sony Perron, NIHB Director General

August 11th email response from Scott Doidge, A/Director General outlined the process for adding Suboxone to the NIHB Drug formulary; advised the NIHB program follows the advice of the Canadian Expert Drug Advisory Committee (CEDAC); CEDAC has recommended public drug plans in Canada provide Suboxone coverage only for patients for whom methadone is contraindicated, i.e., cardiac condition called QT and severe hypersensitivities; advised that NIHB will review requests for Suboxone on a case‐by‐case basis and take into consideration issues related to access to Methadone, i.e., long wait lists for Methadone Treatment, lack of authorized methadone prescribers, and/or pharmacies that will dispense methadone.

Scott Doidge advised NAN that Suboxone is approved by Health Canada for substitution treatment in opioid dependence in adults and that it is not approved for detoxification; NIHB has requested external expert advice to support coverage for Suboxone for Opioid detoxification; NIHB will continue reviewing requests for detoxification with Suboxone on a case‐by‐case basis, respecting current evidence that detoxification is effective in certain circumstances and should be immediately followed up by an addiction treatment program.

Information was provided on coverage for Subutex; Subutex is not currently marketed in Canada and is only available through Health Canada’s Special Access

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Program (SAP); once approved by SAP, NIHB will consider requests on a case‐by‐ case basis.

24) October 18th letter to Scott Doidge, A/NIHB Director General and Sony Perron, NIHB Director General

This letter was to follow up on the NIHB HQ requirement that students enrolled in Suboxone Treatment program at Dennis Franklin Cromarty High School sign a ‘Client Consent Form’ that prevents them from obtaining Narcotics, Opioids and Bendodiazepine drugs in the future; advised NIHB that NAN is opposed to students waiving their Treaty Right to access prescription medication for pain control through NIHB for the remainder of their lives; reminded NIHB that these treaty rights are protected under Section 35 of the Canadian Constitution; advised NIHB that the monitoring system is discriminatory and contravenes Section 25 of the Canadian Human Rights Act, which prohibits discrimination based on ‘disability and perceived disability…Disability includes a previous or existing dependence on alcohol or a drug’; informed NIHB that they may be forcing DFC students to sign the consent form under duress given the students’ physical, mental and emotional state prior to entering the program; requested Suboxone approval for students who relapsed following the completion of two previous detoxification in February and March 2011; NAN requested consideration for the availability of Suboxone based on remoteness and no access to Methadone treatment among a majority of NAN First Nations and/or a declaration of a State of Emergency related to the Opioid epidemic by a First Nation community; requested additional information on Health Canada’s SAP for obtaining Subutex and; NAN proposed an amendment to the Consent form to restrict access to narcotics for one‐year only and/or for the duration of their treatment program.

25) Response from Scott Doidge and Sony Perron, NIHB

No response received to date.

(NOTE): NIHB HQ approved Suboxone for DFC students requiring repeat treatment on October 18th, 2011.

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