From: TheraPsil, Victoria, BC
Via Email: hcminister.ministresc@hc-sc.gc.ca
To: Honourable Minister of Health
Mark Holland Minister of Health, MP for Ajax,
House of Commons Ottawa, Ontario KIA OA6
Medical Access to Psilocybin
Dear Honourable Minister,
Congratulations on your new appointment as Minister of Health. This position is a great honour and comes with great responsibility. I wish you the best over your term.
On behalf of our members across Canada and the elected Board, I also want to take this opportunity to acknowledge that it has been three years since the decision to approve the compassionate use of psilocybin for medical purposes. Three years ago, thanks to the compassion and courage of the Honourable Patty Hajdu, Canada became one of the first countries in the world to facilitate legal access to psilocybin therapy for citizens in palliative care.
Since then, a limited number of Canadians with cancer and others suffering from depression and addiction have been able to legally access psilocybin-assisted psychotherapy through the Special Access Program (SAP), and 19 medical professionals were granted section 56 exemptions for training.
With all this progress over the past few years, the obvious question is – what’s next? The reality is that the world is watching Canada, and looking for us to set the bar on compassion, innovation, and patient-centered care in this rapidly emerging field. Together, we now have an opportunity to lead again.
While over 100 Canadians have been granted access to psilocybin, hundreds of other eligible Canadians have been waiting months for authorization. This includes 96 healthcare professionals and hundreds of patients who have struggled to utilize the SAP or have been denied Section 56 access. It appears that compassionate exemptions through section 56 have stopped altogether and that the SAP is too expensive and difficult for most patients to use, with the result that people are either going untreated or underground.
This is especially distressing given the all too real challenges facing Canadians seeking medical psilocybin. In many cases, people are seeking alternative and adjunct therapies to their options for palliative care, treatment-resistant mental health issues and addiction. We are fast approaching the implementation of amendments to our Medical Assistance in Dying (MAiD) legislation that will allow Canadians with mental health issues such as treatment-resistant depression access to MAiD while they are denied access to medical psilocybin.
Given the substantial research conducted at NYU, UCLA, and Johns Hopkins, where nearly 80% of patients with end-of-life distress saw a clinically significant reduction in symptoms, it only makes sense that we should give those with the right to die the right to try psilocybin. Janis Hughes, a stage 4 cancer patient who was forced to go underground due to the barriers to access posed by the SAP, put it this way “If I had not gone underground for treatment, I might well have exercised my right to MAiD by now.” You can see an article on Janis that came out today here.
How can we allow this to stand as we expand access to MAiD? How can we possibly deny vulnerable Canadians who are facing mental illness access to a potentially lifesaving medicine?
Minister, I have read the article in the CBC in which you courageously relate your struggles with mental illness and ask for more compassion in politics. Many of us have experienced significant mental health challenges, or know someone who has. It is precisely in the darkest moments when people are suffering or considering life or death that we must respond with compassion. Now, more than ever, we need compassionate regulated access. The patients we are helping are looking to use psilocybin to assist in their healing, and we trust that you will have compassion for them.
Regulated access is not only important but urgent because Canadians are already using psilocybin for therapeutic purposes. In most cases, these Canadians are accessing and possessing psilocybin in contravention of the CDSA. In all cases, these Canadians, even holders of subsection 56(1) exemptions, are accessing psilocybin from an illicit source.
A regulated system will provide for greater safety in quality-controlled psilocybin material used in clearly labelled psilocybin products. A regulated system will also place the discretion on access where it belongs – with the patient’s health care provider, rather than with the Minister of Health, whom we cannot guarantee will always have the same compassion as you. A regulated system will increase predictability in access to vital therapeutic options for specific mental health and other conditions.
Most importantly, a regulated medical system will correct a major issue we currently have, which is the artificially high price of psilocybin procured through the SAP and underground – a price that presents a significant financial barrier to access. The average price of the hundreds of SAP treatments we have supported is around $6000, not including the cost of getting a lawyer or TheraPsil involved. This is a stark contrast to the price of MAiD and many other medical treatments that are covered through our provincial health insurance. What sort of message does this convey to patients eligible for MAiD who are considering their options?
Please, Honourable Minister, we ask you to provide forward-thinking leadership. We ask you to compassionately support the Canadians who are using psilocybin and those seeking exemptions. The Special Access Program and Section 56 exemptions are not solutions, so we have drawn up a set of proposed regulations. The enclosed Access to Psilocybin for Medical Purposes Regulations (the “APMPR”) offer a tested, cost-effective scheme for regulating psilocybin.
We hope that you will take time to review these regulations and look into the judicial reviews of your department’s decisions on applications for access to psilocybin and the constitutional challenge of Canada’s psilocybin legislation currently before the courts (Hartle et al. v. HMTK). We will provide you with a detailed brief in the coming days and would welcome a meeting at your earliest convenience.
Thank you again, Honourable Minister.
Sincerely,
Spencer Hawkswell, CEO, and the TheraPsil team
