Collusion between state physician health programs (PHPs) and commercial drug testing labs using non-FDA approved drug and alcohol tests

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I recently offered 25,000 dollars in prizes to anyone who could disprove that Dr. Luis Sanchez committed multiple felonies based on documents that provide direct evidence of a chargeable crime.  No additional evidence is needed.  So far no one has been knocking at my door and nary a call from anyone.

How can we interpret this?   Are the prizes not worthy of the time involved in such an endeavor?  No, I think there is something for everyone including 2oo volumes of the Classics in Medicine. A  current listing on Amazon is listing 187 volumes for almost $5000 and in addition to this I am offering dozens of 1970s skateboards, 2 vintage Schwinn Krate bikes, autographs from polio vaccine pioneers Sabin and Salk, multiple signed and one-of-a-kind items related to Boston politician James Michael Curley, a menu, cocktail menu, matchbook and other very rare items from Boston’s Cocoanut Grove which was the site of the  deadliest nightclub fire in history in 1942, signed lithographs and prints from Warhol and Keith Haring and a signed poster from Adam Ant.  So the prizes are not chopped liver and burnt toast.  The prizes are worthy so in a time or work/benefit analysis the benefits are high. What about the time or work involved?  Would the work and time it takes to disprove this claim make it not worth the effort like trying to prove some logic or mathematical theorem? The James Randi Educational Foundation offered 1 million dollars to anyone who could prove that homeopathy works but no one has claimed it yet.  Why?  Because homeopathy does not work.  My challenge is fairly simple as the documents are a quick read and the claims direct and specific.  All one has to do is read the documents in search of acts that might be considered crimes and use a legal reference to see if they correspond to criminal code. If your examination of the documents finds everything is on the up-and-up or just one or two acts commensurate with felonies then the prizes are yours.  A simple task that should take less than an hour or two.  So why is no one knocking at my door?  No one is knocking for the same reason the million dollar homeopathy reward hasn’t been claimed.  The reason no one is knocking at my door is because Luis Sanchez did in fact commit multiple felonies.  I could double the prizes, give you everything I own and offer my very soul but there would still be no one knocking.

So the question for us is this, how is it possible that an individual contracted by a state agency could commit felony crimes that are documented by direct evidence and not be called on it?   The crimes include flagrant forensic fraud no different from Annie Dookhan who faked, forged and fabricated some 60,00 samples at the Massachusetts crime lab.  Fabricating evidence is fabricating evidence so how is it possible that this fabrication of evidence has not been identified and addressed by anyone?  First of all there is no direct oversight or independent oversight to state physician health programs (PHPs).  Not one agency exists that can accept a complaint, investigate it and punish offenders.  Second, there is an inability or unwillingness to investigate or punish the offenders for various reasons.  PHPs have portrayed themselves as allies to law enforcement and have requested they defer to them any issues related to physicians.   When crimes are reported to local and state police and other law-enforcement agencies they are deemed the illusory product of a diseased mind. States Attorneys General legally represent occupation board. Policy dictates they side with medical boards so individual doctors are rebuffed if they ask for help. The FBI will not investigate.  I was told unless the AGO requested it or a public outcry ensued they would not address any issues regarding physician health programs including laboratory fraud and diagnosis rigging. This inability or unwillingness to meaningfully investigate the offenders is a pervasive problem and represent a total systems failure. No one is minding the minders and no one wants to mind the minders. The agencies that could and should investigate crimes are taking a “not-my-problem” stance.  The medical boards have agreed to absolute deference to PHPs and additionally have individuals or groups within the board who are able to block, deflect and otherwise dismiss information implicating the state PHP. All of the documents seen below were provided to Physician Health and Compliance Board counsel Deb Stoller beginning in 20111 but she apparently kept all the documents to herself.  Her ethical obligation when being provided with evidence of forensic fraud and other crimes was to notify the proper authorities.  She did not. She suppressed all of the information with direct evidence of crimes, an act that is much more grave and vile than Dookhan as the documents show collusion between the MA PHP and one of the drug testing labs used by almost all state PHPs.  The documents provide direct evidence of lab fraud and falsification of evidence that is clear and specific.  No alternative explanations exist.  Concealing this type of misconduct just allows it to continue and what is seen here is not rare.  I have heard from many many doctors who claim they were given bogus tests at this very same lab.   Sadly I have heard of many suicides related to these very same tests.  Faced with the “not my problem” stance of agencies that could and should do something but did not these doctors became hopeless and helpless and killed themselves out of despair. Their locus of control was completely lost and their was no lifeline.  Selective application of the law is the root of government corruption and destroys the moral authority of the government. It inevitably leads to collapse and chaos.  The Massachusetts Board of Registration in Medicine has ignored these documents for five years and assert that the PHP has not committed any crimes because they have not been charged with any crimes.  Nonsense and logical fallacy.  The PHP did commit crimes and so too did Board attorney Deb Stoller when she was given direct evidence of them–misprision of a felony in multiples.

Ignoring misconduct not only allows it to continue it allows it to spread.   The plan is to spread these same non-FDA approved of unknown validity and easily manipulated with no accountability to other populations  including students and kids.  It was also recently suggested that the organization Luis Sanchez is past president of, the Federation of State Physician Health Programs (FSPHP)  be put in charge of national public policy for not just doctors but for everyone.

The simple fact is that doctors are being subject to diagnostic rigging and forensic fraud and nobody cares. This is by design and fueled by the anti-doctor sentiment spread by these same groups with propaganda meant to spread the bogus dangers of a hidden cadre of drug addled and besotted doctors.  It doesn’t exist but the stature of doctors in the public eye has suffered because of the mythology they created.  Don’t get me wrong as any doctor with a substance abuse problem or addiction should be removed from practice and not be able to practice until safe to do so. But that is not what is happening here.

The majority of doctors being monitored by state physician health programs do not have a problem.  They have loosened the diagnostic criteria so that essentially anyone referred to them is given a diagnosis and treated.  Why? Because it is a money maker.  All costs are out-of-pocket and no insurance is involved.  The “PHP-approved” assessment centers all charge around $ 4500 for an “assessment” which inevitably leads to a 3-month inpatient stay for treatment to the tune of about $80,000.   This is then followed by a five-year monitoring contract with random drug and alcohol testing 1-3 x per week.  That is a total of 260 to 780 tests and the laboratory developed tests are not cheap. You do the math.  The drug and alcohol assessment and testing industry makes a pretty penny off this operation and they want to bring it to you-It is in fact a Trojan horse.

So by ignoring this type of misconduct it will only get worse.  People tend not to get concerned unless it impacts them.  This will.  Someday you or a family member may be in this same situation.  It boggles my mind that doctors can be given diagnoses when they do not meet the criteria for the given diagnosis and this is confirmed by outside independent experts.  This occurs because those giving the diagnosis have no accountability. They have removed themselves.  But in actual fact this is political abuse of psychiatry. It is egregious.

Diagnosing someone with a disease they do not have should be a never event. The perpetrators should not only have their licenses removed but they should be punished for the crime.   Forensic fraud should also be a never-event but as seen below it is done without fear of sanction-by fax no less.  Giving false diagnoses and fabrication of drug and alcohol tests are actions that should never be tolerated.  Not even once.  How can this be happening in the United States of America?   Unless people speak up this will only escalate.  Below is a detailed analysis of the multiple crimes used for the $25,000 challenge.  Give it a read and try to disprove the claim that Luis Sanchez committed multiple felonies. If you can you win all the prizes. If you can’t then I ask that you be outraged and do something about it as you or someone you love may be next.  Ignoring this type of misconduct is not going to make anything better.




Fraud is distinguished from negligence, ignorance, and error by virtue of the fact that it is intentional. Fraudulent intent is established by examining the documentation of decisions and behaviors of those involved.

Innocent parties don’t normally alter documents or conceal information.

Innocent parties don’t normally “update” donor ID numbers  or  lab reports to “reflect that chain of custody be maintained as requested in the document below faxed from Physician Health Services, Inc. (PHS) to United States Drug Testing Laboratories (USDTL) on July 19th, 2011.

The lab report PHS is referring to is seen below which is positive for the alcohol biomarker phosphatidylethanol at a level of 365.4 ng/ml   (cutoff level for a positive test is 20 ng/ml.

Note both the chain of custody and Donor ID # are listed as 461430 and there is no collection date, collectors name or location listed.   The specimen was received on  July 8, 2011 and reported on July 14, 2011 according to the document.     On July 19th, 2011 Mary Howard requests that a collection date of July 1st, 2011 be added and that the Donor ID #  be changed from  461430 to #1310.

What is the significance of this?    My unique identifier for  for random drug and alcohol testing is #1310 and I had this same test drawn on July 1st, 2011.

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The document are from the USDTL “Litigation Packet” received December 3, 2011 which can  be seen here:   USDTL-LitigationPacket12:2011

USDTL “updated” the test. The document below shows they added my ID # and a collection date of July 1, 2011.

It is the responsibility of the Medical Review Officer (MRO) to make the final determination as to whether or not the positive result reported by the laboratory is reported to anyone else.

The previous Medical Director of the Massachusetts PHP, Physicians Health Services, Inc. (PHS) for fourteen years, Dr. Luis Sanchez, is also a past President of the FSPHP although PHS did not enter into formal partnership with the FSPHP until 2013. The Director of Program Operations at PHS, Linda R. Bresnahan, MS, is the current Secretary of the FSPHP.

PHS, inc. exclusive use of out of state treatment programs has been challenged. In the past PHS, Inc. has adamantly refused to allow physicians to be evaluated in State despite it being one of the medical hubs of the country. Physicians in Massachusetts who are referred for evaluation in Kansas, Georgia, Alabama, and West Virginia as PHS has convinced the Board that only these facilities are ‘experienced in the assessment and treatment of health care professionals.” In actual fact the medical directors of all of these preferred facilities are also ASAM physicians with the vast majority being in 12-step “recovery” themselves and a close colleague if not friend of the medical director of the state PHP.

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“A body of men holding themselves accountable to nobody ought not to be trusted by anybody.”

― Thomas Paine 

Our minds tell us, and history confirms, that the great threat to freedom is the concentration of power. Government is necessary to preserve our freedom, it is an instrument through which we can exercise our freedom; yet by concentrating power in political hands, it is also a threat to freedom. Even though the men who wield this power initially be of good will and even though they be not corrupted by the power they exercise, the power will both attract and form men of a different stamp.”  

—Milton Friedman


Dr. Luis Sanchez, M.D. served as the Medical Director of Physician Health Services, Inc. (PHS) for 15-years.  Massachusetts state Physician Health Program (PHP) for 15-years.  He retired in March 2013 and Dr. Steven Adelman . Sanchez also served as President of the national organization for state PHPS, the  Federation of State Physician Health Programs (FSPHP).Screen Shot 2015-07-28 at 6.44.29 AM

The “PHP-blueprint” is being promoted as a “new paradigm”  with a success rate twice that of other treatment programs (80%).  With numbers this high, the argument goes, why bother with anything else?  The attached slides are from a presentation Sanchez gave at a legal issues conference.  His presents the ACGME definition of professionalism that includes competencies in altruism, accountability, excellence, duty, honor and integrity, and respect for others.    Sanchez also addressed these topics in an article he wrote for the Journal of the American Medical Association (JAMA) entitled  Disruptive Behaviors Among Physicians.  In thiis article he discusses a “medical culture of safety” with “clear expectation and standards.” Sanchez affirms the importance of values and codes-of-conduct in the practice of medicine, and calls on physician leaders  to “commit to professional behavior.”

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PHS Director of Operations Linda R. Bresnahan has also been involved in leadership positions at the FSPHP including acting a Executive Secretary and Interim Executive Director.

PHPs recommend referral of physicians if there are any concerns such as getting behind on medical records.  As PHS Associate DirectorJudith Eaton explains “when something so necessary is not getting done, it is prudent to explore what else might be going on.”  If the PHP feels that doctor needs an assessment they will send that doctor to a “PHP-approved” facility “experienced in the assessment and treatment of health care professionals.” The physician must comply with any and all recommendations of the assessment center.  To assure this the physician must sign a monitoring contract with the PHP (usually five years). USDTL is one of the labs PHPs have contracted with for forensic drug and alcohol testing.

USDTL drug testing laboratory claims to advance the”Gold Standard in Forensic Toxicology.”  “Integrity: Results that you can trust, based on solid science” is listed as a corporate value. “Unlike other laboratories, our drug and alcohol testing begins and ends with strict chain of custody.” “When people’s lives are on the line, we don’t skip steps.”  Joseph Jones, Vice President of Laboratory Operations explains the importance of chain-of-custody in this USDTL video presentation.


Forensic Drug and Alcohol Tests: The Need For Integrity and Accountability of the Sample

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“Forensic” drug-testing differs from “clinical” drug-testing in how the results are used. “Clinical” tests are used for medical purposes in diagnosing and treating a patient.

A “forensic” test is used for  non-medical purposes.  It is not used for patient care, but for detecting licit and illicit substances in those who should not be using them. Pre-employment and employee assistance and professional monitoring programs are examples.Screen Shot 2014-05-08 at 2.17.18 AM

Forensic testing is held to a higher standards because the consequences of a positive result can be grave and far reaching. A positive forensic test can result in loss of rights of the individual being tested and his or her loved ones. Mistakes are unacceptable.

The Federation of State Medical Boards Policy on Physician Impairment supports this position stating “chain-of-custody forensic testing is critical” (page 14) and the “use of a Medical Review Officer (MRO) for screening samples and confirming sample results” (page 21).

Any and all drug testing requires chain-of-custody. The custody-and-control form is given the status of a legal document because it has the ability to invalidate a test that lacks complete information.  Chain-of-custody provides assures specimen integrity. It provides accountability. 

Screen Shot 2014-11-06 at 7.25.46 PM The job of the MRO is to ensure that the drug testing process is followed to the letter and reviews the Custody and Control form for accuracy.  The MRO also rules out any other possible explanations for a positive test (such as legitimately prescribed medications).  Only then is the test reported as positive.

The legal issues involved in forensic testing mandate MRO review. According to The Medical Review Officer Manual for Federal Workplace Drug Testing ProgramsScreen Shot 2013-12-19 at 12.20.46 PM

the sole responsibility of the MRO is to”ensure that his or her involvement in the review and interpretation of results is consistent with the regulations and will be forensically and scientifically supportable.”

“Fatal flaws” such as lack of chain-of-custody form, missing tamper proof seal, missing signatures, or a mismatch of the sample ID and chain of custody ID invalidate the test.   It is not reported.  Tight chain-of-custody and MRO review is critical for the accountability and integrity of the sample.

The Medical Review Officer Certification Council  provides a certification process for MROs. TheyScreen Shot 2014-04-30 at 12.47.25 PMalso  follow their own Code of Ethics.   In accordance with these standards PHS has an MRO to review all positive tests.  As added assurance the FSPHP guidelines state that all positive tests must be approved by the Medical Director.


Regulation and the Medical Profession–The need for Integrity and Accountability in Physician Leadership and Health Care Policy.

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The  July 19th, 2011 fax from PHS seen below is in reference to the lab report from USDTL seen above.  In it PHS requests the report be “updated”to donor ID number “1310” and  to “reflect that the chain of custody was maintained.”

The lab report is a positive test for the alcohol biomarker (Phosphatidyl Ethanol) or PEth, an alcohol biomarker introduced by the Federation of State Physician Health programs and marketed by USDTL and other labs to detect  covert alcohol use..

There is no record of where, when or by whom it was collected.

Screen Shot 2014-11-06 at 11.17.32 PMBoth the donor ID # and chain of custody are listed as 461430.

The purpose of chain-of-custody is to document the location of  a specimen in real time.  “Updating” it is not an option.  It is prohibited.  Updating the “chain of custody to reflect that chain of custody was maintained”  is a clear indicator that it was not maintained.

ID #1310 is the unique identifier I was issued by PHS.  It is used as a unique identifier, just like a name or social security number, to link me to any sample collected for random drug and alcohol screening. #1310 identifies me as me in the chain-of-custody.    On July 1st, 2011 I had a blood test collected at Quest Diagnostics.

The sample was collected at Quest Diagnostics on July 1, 2011 but these documents were not obtained until December 3, 2011 and were included in the “litigation packet” which documents chain-of-custody and is generated on any and all forensic drug testing.   It provides proof that the test was done on who it was supposed to have been done and that all required procedure and protocol was followed. It protects the donor form being falsely accused of illicit substance use.  In most employee drug-testing programs the litigation-packet is provided on request immediately.  It is a transparent process.  This is not the case, however, at PHS.

I requested the litigation packet immediately after the positive test was reported on July 19, 2011.  PHS first refused, then tried to dissuade me.  They finally agreed but warned there would be “unintended consequences.    The entire litigation packet can be seen here:   Litigation Packet 12:3:2011

The positive sample has no chain-of-custody linked to me, no date, and no indication where it was collected or who collected it.   In addition there was no “external” chain of custody for the sample. The custody-and-control form was missing.

With multiple fatal flaws (6/6)  rendering it invalid, USDTL should have rejected it by their own written protocol.

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USDTL did not reject it. The document below shows that USDTL added my ID # 1310 and added a collection date of July 1, 2011–the day I submitted the sample.

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“REVISED REPORT PER CLIENTS REQUEST”  

And in doing so the lab that claims “integrity” and “strict chain of custody” readily, and with no apparent compunction” manufactured a chain-of-custody and added a unique identifier by faxed request.

The litigation packet was signed by Joseph Jones on December 3, 2011.   There was no record of where the sample was from July 1st to July 8, 2011. No external chain-of-custody or custody-and-control form was evident in the litigation packet.

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The V.P. for Laboratory operations for the lab that claims “strict chain of custody” and that “doesn’t skip steps” “when “peoples lives are on the line” verified a positive test as positive with no custody and control form, no external chain of custody and 6/6 fatal flaws.  What is so shocking is that  this was done without compunction or pause.  As a forensic test ordered by a monitoring program Jones knew full well it would result in significant consequences for someone.  He knew that someones “life was on the line,” knew it was wrong, and did it anyway.

A person of conscience would never do this.  It is unethical decision making  that goes against professional and societal norms.  A “moral disengagement” that represents a lack of empathy and a callous disregard for others.  I would not consider doing something like this for any price and here it appears to be standard operating procedure.

PHS reported the positive test to the Medical Board on July 19, 2011 Positive PEth July 19, 2011-1.  It was used as a stepping-stone to request an evaluation at one of three  “PHP-approved” facilities (Marworth, Hazelden and Bradford). The Medical Directors of all three facilities can be seen on this list list called “Like-Minded Docs.”  The MRO for PHS, Dr.Wayne Gavryck,  whose job was to review the chain-of-custody and validate its integrity before reporting it as positive is also on the list.  See this simplified schematic of how it works in Massachusetts.  It shows how this is a rigged game.

Expecting to be diagnosed with a non-existent problem and admitted for non-needed treatment I requested an evaluation at a non-12 step facility with no conflicts-of-interest.  Both PHS and the Medical Board refused this request in one of four violations of the Establishment Clause of the 1st amendment.

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I chose Hazelden.  The Medical Director was aware that I had just signed  a patent license agreement for an epinephrine auto-injector and he had a child with a peanut allergy.  We talked about the device and discussed the problems with current management.  I think it was because of this added personal interaction that he did not “tailor my diagnosis” as PHS most certainly requested.  Seeing me as a person rather than an object, I believe,  enabled his conscience to reject it. My discharge diagnosis found no history of alcohol issues but they could not explain the positive test. Unable to rule out that I drank in violation of my PHS contract they recommended I attend AA.

PHS mandated that I attend 3 12-step meetings per week and requested that I obtain names and phone numbers of fellow attendees so they could contact them to verify my attendance.  They also mandated that I discontinue my asthma inhalers (as the propellant contains small amounts of ethanol) that had been controlling my asthma and preventing serious attacks for the previous ten years.  I was threatened that if I had to use the inhalers or one day late on the increased payments I would be reported to the Board and lose my license.

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Sanchez states that my request for the “litigation packet” was processed on December 5, 2011 (two days after Jones signed off on it) and adds the “testing laboratory is willing to support the test results.”

In the interim I filed a complaint with the College of American Pathologists.  I also requested the missing external chain of custody documents from Quest.

I never received the chain of custody from Quest.  Instead I received a letter from Nina Tobin, Compliance Manager for Quest documenting all the errors but written to sound as if some sort of protocol was maintained.  Tobin claimed the specimen was inadvertently logged as a clinical specimen but sent on to USDTL a week later.  (See Quest Letter )

The Chief of Toxicology at MGH wrote a letter to the Board documenting all of the misconduct and irregularities stating that it was an “intentional act” perpetrated by PHS.  MLLv3finalJacob_Hafter_Esq_copy.

This letter, as well as the opinions of everyone outside of PHS was ignored. So too were any opinions of my two former Associate Directors at PHS.   The e-mail below dated October 10th, 2011 is to to Drs.John Knight and J. Wesley Boyd and I am referring to their article Ethical and Managerial Considerations Regarding State Physician Health Programs  that was about to be published. We had hoped that it would draw more attention to the problems with PHPs.

 

I was subsequently reported as “non-compliant” with AA meetings.    They could not give any details of where or when.  They then misrepresented a declaration of fact (I stated that I had started going to a specific meeting on a specific date) as an admission of guilt by saying I was referring to a different meeting.     10:23:12 PHS Letter to BORM-noncompliance.

My Chief at MGH, his Chief and others held a  conference with PHS and attempted to remove me from PHS and replace the monitoring contract with one of their own.  They refused.   When confronted with the fabricated test they dismissed it and focused on sending me to Kansas to one of the “disruptive physician” Psikhuskas where they are using polygraphs (despite the AMAs stance that it is junk science) and non-validated neuropsychological instruments that detect “character defects” to pathologize the normal.

I refused. Had I gone to Kansas I would have been given a false diagnosis and my career would be over. This is what they do.

Amy Daniels, the investigator for the College of American Pathologists contacted me in December of 2012 to see how things were going since USDTL “amended” the test.  Daniels told me that the College of American Pathologists confirmed my allegations and, as an Accrediting Agency for Forensic Toxicology mandated that USDTL correct it.  (Labs can lose accreditation if they do not comply with CAP  Standards for Forensic Drug Testing). This was done on October 4, 2012.

PHS denied any knowledge of an amended test.  I also wrote an e-mail to Joseph Jones requesting the document but he did not reply.

I contacted CAP.   On December 11, 2012 Dr. Luis Sanchez wrote a letter stating  “Yesterday, December 10 2012, Physician Health Services (PHS) received a revision to a laboratory test result”

 “The amended report indicates that the external chain of custody protocol [for that sample] was not followed per standard protocol]”

Sanchez dismisses this test as irrelevant, rationalizing neither PHS nor the Board based any actions on the test and they would “continue to disregard” it.

The  logic is that it was my behavior that resulted in any consequences.  My “non-compliance” in October led to my suspension and the test had nothing to do with it.   The sole reason for reporting me to the Board in 2011 was the positive test.  There is no other pretext to use.  It is misattribution of blame as without the test, now invalidated, there would have been no AA meetings to say I was non-compliant with.

In response to a civil complaint PHS, Quest and USDTL all took the position that the results of the fraudulent testing had absolutely nothing to do with anything.

And in response to the allegations of forensic fraud the labs claimed there was no forensic fraud because this was not a “Forensic” test but a “clinical” test.     The argument was that “clinical” tests do not require chain-of-custody and it was his behavior not these tests that resulted in consequences.   

As a “clinical” test I knew it was considered Protected Health Information (PHI)  under the HIPAA-Privacy Rule.  A patient must give written consent for any outside entities to see it.  Obtaining lab tests previously required the consent of both the patient and the ordering provider.  What PHS and the labs were apparently unaware of was the changes to the HIPAA-Privacy rule giving patients increased rights to access their PHI.   The changes removed the ordering provider requirements.  A patient has a right to obtain lab test results directly from the labs and has 30 days to do it.  CAP agreed.   USDTL sent me all of the documents.  They can be seen below:

August 6, 2014 to Langan with health materials.

The documents sent by USDTL are notable for two things:

1.  The e-mail from me to Joseph Jones dated December 10, 2012.  It can be seen on page 22 of the USDTL documents.

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2. USDTL document confirming PHS knew the test was amended 67-days before they said they did.

The document shows PHS and Sanchez were aware of the invalidity of the test on October 4, 2012.   Instead of correcting things they initiated machinations to throw me under the bus.  They officially reported me to the Board for non-compliance on October 19, 2012.

The December 11, 2012 letter signed by Sanchez states “Yesterday, December 10, 2012, PHS received a “revised report” regarding the test.  The documents show he knew about it 67-days prior.

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Although USDTL complied with the HIPAA-Privacy Rule and CAP, Quest did not.   Quest Diagnostics refused to send me copies of their lab reports claiming it was confidential and protected information that required PHS consent.  Quest required I sign a consent form with multiple stipulations regarding PHS.  I refused and contacted the Department of Justice -Office of Civil Rights.  The DOJ-OCR agreed with me and I received the Quest documents

Remember a “clinical” test can only be ordered by a physician in the course of medical treatment.  It requires authorization from the patient to obtain a “clinical” specimen and it requires written authorization as to who sees it.  Referring physician was Mary Howard.

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And below is the fax from PHS to Quest from July 1, 2011 also requested by Mary Howard.  The signature on the front is not mine.  In addition I gave the blood at 9:30 and was in my clinic at MGH at 12:23 so it couldn’t be. The WC 461430 R are dated July 2, 2011.  This is a “clinical” not “forensic” sticker.  The “R” indicates a red top tube.  The other sticker is USDTL and indicates it was logged in on July 8, 2011.

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What does it all mean?    Blood left in a red top tube ferments. This is basic chemistry.  The PEth test needs to be refrigerated and shipped overnight to prevent this.  In addition it needs to be collected with a non-alcohol wipe in a tube that has an anti-coagulant or preservative so that it does not ferment.    It requires strict procedure and protocol.

When I gave my blood on July 1st, 2011 it was as a “forensic” test per my contractual agreement with PHS.

On July 2, 2011 it was changed to “clinical.”   Why?  because “forensic” protocol would have invalidated it.

The only conceivable reason for doing this was to bypass chain-of-custody procedures.  My unique identifier #1310 was removed and the clinical specimen number was used for chain-of-custody.    The R in 461430R indicates a red top tube.

By holding on to it for one week the blood fermented.    As it was July with an average temperature close to 90 they overshot their mark a bit.   My level of 365 is consistent with heavy alcohol use–end stage half-gallon a day type drinking.

Quest then forwarded it to USDTL with specific instructions to process it as a “clinical” sample.  USDTL complied and  processed it as a clinical specimen which was reported it to PHS on July 14, 2011.

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PHS then asked USDTL to add my forensic  ID # 1310 and add a collection date of July 1, 2011 so it would appear “forensic” protocol was followed.    The reason Jones signed the “litigation packet” on December 3, 2011 was because that was when the “litigation packet” was manufactured.  A “clinical” sample does not produce one.

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USDTL willingly complied with this request.

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PHS then reported this as a “forensic” test to the Medical Board on July 19, 2011 and requested a reevaluation.

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The distinction between “forensic” and “clinical” drug and alcohol testing is black and white. PHS is a monitoring program not a treatment provider. The fact that a monitoring agency with an MRO asked the lab to process and report it as a clinical sample and then used it forensically is an extreme outlier in terms of forensic fraud. The fact that they collected it forensically, removed the forensic components and let it sit in a warehouse for a week is  abhorrent.  The fact they then specifically requested it be processed as a clinical sample deepens the malice. The fact that they then reported it to the Board as a forensic sample and maintained it was forensic up until just recently makes it egregious. But the fact that the test was changed from “positive” to “invalid” on October 4th, 2012 and they then reported me to the Board on October 8th,  2012 for “noncompliance,” suppressed it and tried to send me to Kansas where I would be given a non-existent diagnosis to delegitimize me for damage control makes it wantonly egregious.  This is political abuse of psychiatry.

Accountability requires both the provision of information and justification of what was done.

For doctors it is very difficult to obtain the information. As seen here, they put up a gauntlet to prevent the provision of what is immediate in all other drug testing programs.  I now have all of the information. What it shows is clear. This was intentional.  It was no accident.  They knew what they were doing, knew it was wrong but did it anyway.

Accountability also requires that those who commit misconduct suffer consequences. The PHPs have also put up barriers to this.    With no regulation or oversight they have no apparent accountability.

My understanding is that it works this way.   The Medical Board, Medical Society and Departments of Public Health have no oversight.   The MMS has an ethics committee but all they can do is “educate” the person if they feel there was a violation.  The DPH won’t even look at it and the Board is complicit.

My understanding is that they have convinced law enforcement that this is a “parochial” issue that is best kept within the medical community.  They have also created the impression that they are “friends” of law enforcement.  I have heard from many doctors that they have tried to report misconduct, civil rights violations and crimes to the police, AGO, and other law enforcement agencies only to be turned back over to the PHP.     By saying the physician is “impaired” it delegitimizes and invalidates the truth.  “He’s just a sick doctor,  we’ll take care of him.”  That physician then suffers consequences effectively silencing the rest.

PHS uses the Board to enforce punitive measures and temporize.   The Board puts blind faith in PHS.  Blind faith that defies common sense ( mandating phone numbers at anonymous meetings)  and disregards the law (Establishment Clause violations that are clear and well established).    The Board also temporizes to cause damage.

In my case they required a psychiatric behavioral evaluation.  I was given the choice of Kansas and a few other Like-minded assessment centers.

After petitioning for  multiple qualified psychiatrists that were summarily rejected months later for no reason one of the Board Attorneys suggested  Dr. Patricia Recupero, M.D., J.D. who is Board Certified in Forensic Psychiatry and Addiction Psychiatry.   The Board had used her in the past but not recently.  Seeing that she had been used by the Board for fit-for-duty evaluations in the past the Board accepted my petition.

Dr. Recupero wrote an 87-page report. She concluded I was safe to practice medicine without supervision, that I had never had an alcohol use, abuse or dependence problem, and that PHS request for phone numbers was inappropriate. She also documented PHS misconduct throughout my contract and concluded it was PHS actions, not mine, that led to my suspension.   What she describes is consistent with criminal harassment.  She documents the falsification of neuropsychological tests and confirms the forensic fraud.  What did the Board do?  Ignored their very own recommended and approved evaluator.

One measure of integrity is truthfulness to words and deeds.  These people claim professionalism, ethics and integrity.  The documents show otherwise.  The careers and lives of doctors are in these peoples hands.

Similar fraud is occurring across the country.  This is an example of the institutional injustice that is killing physicians.  Finding themselves entrapped with no way out, helpless and hopeless they are feeling themselves bereft of any shade of  justice and killing themselves.  These are nothing more than bullies and accountability is essential.  The “disruptive physician” moral panic has harmed the Medical Profession.

Dr. Clive Body in his book  Corporate Psychopaths   writes that “Unethical leaders create unethical followers, which in turn create unethical companies and society suffers as a result.”  And according to Dr. Robert Hare in  Without Conscience  “If we can’t spot them, we are doomed to be their victims, both as individuals and as a society. ”

Wes Boyd notes that valid complaints from physicians are often dismissed as “bellyaching” by the PHPs.  Complacent that these are just good guys helping doctors and protecting the public the complaints are dismissed, tabled, deflected or otherwise ignored.  Bellyaching??   Is this bellyaching.

It is my opinion that what you see here is indefensible  Procedurally, Ethically, and Legally.

Procedurally it goes beyond negligence and represents fraud.  It violates every procedural guideline, regulation and standard of care including their very own.

Ethically it violates everything from the Hippocratic Oath to  AMA Medical Ethics to the MRO Code of Conduct.

And where was PHS MRO Wayne Gavryck? By my count he violated at least 4 of the 6 Codes of Ethical Conduct.

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What was done here violates the most fundamental ethical principles of Medicine -Autonomy, Beneficence, Nonmaleficence and justice.

Intentionally falsifying a laboratory or diagnostic test to refer for an evaluation or support a diagnosis or give unwarranted “treatment” is unconscionable.  Abuse under the utility of  medical coloration is especially egregious.

The information provided herein should negate any “peer-review” protection or immunity afforded PHS as it is undeniably and egregiously in “bad faith.” Moreover, the ordering a “clinical” test is outside PHS scope, practice, and function of PHS. According to M.G.L. c. 111, § 203 (c):

An individual or institution, including a licensed or public hospital, physician credentialing verification service operated by a society or organization of medical professionals for the purpose of providing credentialing information to health care entities, or licensed nursing home reporting, providing information, opinion, counsel or services to a medical peer review committee, or participation in the procedures required by this section, shall not be liable in a suit for damages by reason of having furnished such information, opinion, counsel or services or by reason of such participation, provided, that such individual or institution acted in good faith and with a reasonable belief that said actions were warranted in connection with or in furtherance of the function of said committee or the procedures required by this section.

Dr. Luis Sanchez and Dr. Wayne Gavryck need to be held to the same professional standards as the rest of us.

If you can support either of them procedurally, ethically, or legally, any one of them, then I will turn in my medical license with a bow on it.  If they did not commit negligent fraud by standards of care and procedural guidelines, egregious moral disengagement in violation of ALL ethical codes for the medical profession and society and break the law then disprove me.  Just one will do.

But you can’t do this then I ask that you speak up and take a stand. Either defend them or help me hold them accountable.  If a crime is committed it needs to be addressed.  Ignoring encourages more of the same.

And if this cannot be supported procedurally, ethically or legally then I want to know what is going to be done about it?

How low does the moral compass have to go before someone takes action?

Doctors are dying across the country because of people just like this.  They have set up a scaffold that removes the usual checks and balances and removed accountability.   It is this institutional justice that is driving many doctors to suicide.

So the evidence is above.  Either defend them or help me draw unwanted attention to this culture of bullying and abuse. So I am asking you to contemplate if  what you see here is ethically, procedurally or legally sound.   If you can show just one of these then I stand corrected. But if you cannot justify this on any level then I want you to help me expose this criminal enterprise. Either defend it or fight it. Silence and obfuscation are not acceptable.

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Mandating Drug-Testing of Unknown Validity while removing the procedural safeguards of forensic drug testing: The plan to introduce junk-science lab tests into the healthcare system and randomly drug test students in schools

screen-shot-2016-12-04-at-11-38-32-pmAs a physician-patient relationship renders drug testing “clinical” rather than “forensic” the consequences become “treatment” rather than “discipline.”  And that is the real reason behind all of this.    A positive “forensic” test in most employee random drug screening programs today will result in an “assessment” for substance abuse.  Most EAPs allow a choice in where that assessment takes place.  The model this system is based on, Physician Health Programs. do not allow choice as evaluations are mandated to “PHP-approved” assessment centers; a rigged game.A positive “clinical” test will result in the same thing under the ASAM White Paper proposal.  But the assessment will be at an ASAM facility and if a Substance Use Disorder (SUD) is confirmed it will result in mandated abstinence of all substances (including alcohol) and lifelong spirituality involving 12-step recovery   And by using the healthcare system as a loophole and calling this testing “clinical” rather than “forensic” the ASAM will have successfully introduced widespread testing of a variety of Laboratory Developed Tests (LDTs) of unknown validity while removing  the safeguards provided by forensic testing including chain-of-custody and MRO review.

Source: Mandating Drug-Testing of Unknown Validity while removing the procedural safeguards of forensic drug testing: The plan to Introduce Laboratory Developed Tests into Mainstream Healthcare

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The drug and alcohol testing and treatment industry plan to use the medical profession as a urine collection agency to bypass procedural protections: The ASAM White Paper on Drug Testing and the “Future of American Drug Policy.”

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Before the  2012 Drug and Alcohol Testing Industry Association (DATIA) annual conference, Dr. Robert Dupont delivered a speech entitled “Drug Testing and the Future of American Drug Policy.”    He describes a “New Paradigm” for substance abuse treatment that enforces “zero tolerance for alcohol and drug use”  enforced by monitoring with frequent random drug and alcohol tests in which any positive test is  “met with swift, certain” consequences.” The paradigm is based on the current Physician Health Programs blueprint.  Dupont states:

“…physician health programs , have set the standard for effective use of drug testing. These pioneering state programs provide services to health care professionals with substance use disorders. The programs are run by physicians, some of whom in recovery themselves. PHPs feature relatively brief but highly focused treatment followed by active lifelong participation in the 12-step fellowships of Alcoholics Anonymous and Narcotics Anonymous. The key to the success of the PHP system of care management is the enforcement of the standard of zero tolerance for any alcohol or other drug use by intensive long-term random testing for both alcohol and drugs with swift and certain consequences for even a single use of alcohol or any other drugs of abuse. PHPs use drug panels of 20 or more drugs. The PHPs commonly use EtG and EtS tests to detect recent alcohol use. Similar comprehensive programs have been developed for commercial pilots and attorneys. These innovative programs of care management produce unprecedented long-term, outcomes.”

Physician Health Programs use a doctor’s medical license as “leverage” in what they call “contingency management.”   What this means is that a doctor who is being monitored by a PHP must comply with any and all demands of the PHP under threat of being reported to the state Medical Board and immediate suspension of  licensure. Dupont wants to extend this model to other populations including our elderly, our pregnant mothers, college and high school students and schoolchildren.

The 2013 American Society of Addiction Medicine White Paper on Drug Testing describes the organizational structure of the “New Paradigm” and this includes utilizing the medical profession as a urine collection agency for their drug and alcohol testing and the loophole they plan to exploit is this:  When a doctor-patient relationship exists drug and alcohol testing is rendered “clinical” rather than “forensic”so the consequences of a positive test can legitimately be called  “treatment” rather than punishment.  Because addiction is currently defined as a disease, addicts must be “treated” (which in the United States is more often coercive than voluntary), and “cured” (which is defined as remaining abstinent). When the disease concept is not strictly reserved for medical conditions but is expanded to any and all drug and alcohol use.

The proposed system bypasses the strict chain-of-custody and Medical Review Officer requirements designed to ensure accuracy and minimize false-positives.  These strict protocols are used by essentially all employee assistance programs (EAPs) in workplace drug testing programs.    Forensic drug testing is tightly regulated because the results of a positive test can be grave and far reaching and erroneous results are unacceptable.

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THE ASAM PAPER DESCRIBES MANDATED DRUG-TESTING FOR PATIENTS IN A NUMBER OF SPECIALTIES INCLUDING ADOLESCENT MEDICINE, PSYCHIATRY, OBSTETRICS, AND GERIATRICS.  CONTINGENCY MANAGEMENT WILL INVOLVE “THE POTENTIAL FOR LOSS OF CURRENT OR DESIRED EMPLOYMENT, OR THREATENED LOSS OF OR RESTRICTIONS ON A PROFESSIONAL OR COMMERCIAL LICENSE, OR LEGAL AND FORENSIC NECESSITY.”
 “THIS WHITE PAPER ENCOURAGES WIDER AND “SMARTER” USE OF DRUG TESTING WITHIN THE PRACTICE OF MEDICINE AND, BEYOND THAT,BROADLY WITHIN AMERICAN SOCIETY. SMARTER DRUG TESTING MEANS INCREASED USE OF RANDOM TESTING* RATHER THAN THE MORE COMMON SCHEDULED TESTING,* AND IT MEANS TESTING NOT ONLY URINE BUT ALSO OTHER MATRICES SUCH AS BLOOD, ORAL FLUID (SALIVA), HAIR, NAILS, SWEAT AND BREATH WHEN THOSE MATRICES MATCH THE INTENDED ASSESSMENT PROCESS. IN ADDITION, SMARTER TESTING MEANS TESTING BASED UPON CLINICAL INDICATION FOR A BROAD AND ROTATING PANEL OF DRUGS RATHER THAN ONLY TESTING FOR THE TRADITIONAL FIVE-DRUG PANEL.”

Federal workplace drug testing is done in accordance with mandatory guidelines. This testing is regulated using FDA approved tests with established sensitivity, specificity and cutoff levels.  FDA approval requires rigorous research and proven validity.    The FDA requires valid scientific evidence (with both clinical and analytical validation).

The  Federation of State Physician Health Programs (FSPHP), the group currently in managerial control of state physician health programs in 47-states,  has introduced non-FDA drug testing via a loophole that removes all accountability.  The EtG, EtS, and PEth tests were introduced as  Laboratory Developed Tests (LDTs) with little to no evidence base through pathway  developed for “clinical” tests of low market potential that would not otherwise be developed due to the prohibitive cost of the FDA approval process.  An LDT  does not even require testing in humans (“in vivo”) or even proof that the test is testing what it claims to be testing (validity) for.  It is an honor system and without FDA oversight a lab can can claim anything they want about these tests with no accountability. They do not have to provide any proof of what they claim or justify what they claim.     After partnering with labs to develop these tests, the FSPHP then convinced the Federation of State Medical Boards they were valid and accurate tests that were necessary to detect a bogus cadre of drunk and drugged doctors able to hide their impairment and who were protected by a “code of silence.”    This bogus danger was then used to convince state Medical Boards to use these unvalidated tests on doctors in state physician health programs.

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(Source: ASAM Physician Health News March 2015)ASAM Physician Health News March 2015)

The ASAM white paper contains the following quote minimizing the critical role of the MRO in drug testing.   They feel clinical testing is good enough.

Unlike forensic drug testing where the test results must be able to meet rules of evidence in administrative, civil or criminal proceedings, clinical drug testing* is part of a patient examination performed by a clinician with whom the patient is in a therapeutic relationship. The testing is used for the purposes of diagnosis, treatment, and the promotion of long-term recovery. Clinical drug test results must meet the established standards of medical practice and benefit the therapeutic relationship, rather than meeting the formal legal requirements of forensic testing. Drug testing in medicine employs the same sound procedures, safeguards, and systems of information management that are used for all other health-related laboratory tests, tests on which life-and death medical decisions are commonly made.

Changing Public Policy and Regulatory Authority to Increase Power and avoid Accountability

 The Federation of State Physician Health Programs has been able to construct this scaffold with no meaningful opposition and below the public radar. They have done this by removing accountability at multiple levels.  By preventing access to information and erecting a system without oversight no consequences exist to deter misconduct and abuse.  The same tactics and strategies will be used as they expand this to other populations.

The Federation of State Physician Health Programs trumpets the the 12-step chronic relapsing brain disease model of addiction as defined by A.A. because it supports the drug and alcohol assessment, testing and treatment industries goals of more and more testing and treatment. For example  a 2011 FSMB Policy on Physician Impairment identifies, defines and essentially legitimizes “potential impairment” and “relapse without use.”

A PHP Should be empowered to conduct an intervention based on clinical reasons suggestive of potential impairment.  Unlike the Board which must build a case capable of withstanding
legal challenge, a PHP can quickly intervene based on reasonable concern."

“Empowered” to conduct an “Intervention” for reasons “suggestive” of “potential” impairment means a doctor can be pulled out of practice for anything.  It essentially gives them carte blanche authority. Due process and fundamental freedoms of choice are removed.

in 2011 The ASAM issued a Public Policy Statement on coordination between PHPs, regulatory agencies, and treatment providers recommending  that  only “PHP approved” treatment centers be used in the assessment and treatment of doctors.  A recent audit of the  North Carolina PHP found financial conflicts of interest and no  documented criteria for selecting the out of state treatment centers they used.  The common denominator the audit missed was that the 19  “PHP-approved” centers were all ASAM facilities whose medical directors can be seen on this list.

The FSMB House of Delegates adopted an updated Policy on Physician Impairment at their 2011 annual meeting distinguishing “impairment” and “illness”  stating that Regulatory Agencies should recognize the PHP as their expert in all matters relating to licensed professionals with “potentially impairing illness.”

According to the FSPHP, physician illness and impairment exist on a continuum with illness typically predating impairment, often by many years.”

The policy extends PHP authority to cover physical illnesses affecting cognitive, motor, or perceptive skills, disruptive physician behavior, and “process addiction” (compulsive gambling, compulsive spending, video gaming, and “workaholism”). It also defines “relapse without use” as “behavior without chemical use that is suggestive of impending relapse.”

G. Douglas Talbott defines  “relapse without use”  as  “emotional behavioral abnormalities” that often precede relapse or “in A A language –stinking thinking.”  AA language has entered the Medical Profession and no one seems to have even noticed.

The FSPHP political apparatus exerts a monopoly of force. It selects who will be monitored and dictates every aspect of what that entails.  It is a, in fact, a  rigged game.

The Need for Regulation, Oversight, and Accountability

Accountability is necessary to prevent corruption and requires both the provision of information and justification for actions. What was done and why?   Accountability also necessitates consequences-the ability of outside actors to punish and sanction those who commit the misconduct.  Without these constraints corruption is inevitable.

In  2012 Drs. John Knight and Wes Boyd recommended the medical community outside of PHPS provide oversight and demand accountability.  In  Ethical and Managerial Considerations Regarding State Physician Health Programs  they noted the financial conflicts of interest between PHPs and their “approved  centers,  coercion and abuse and even possible violations of the Nuremberg Code of Medical Ethics yet their paper generated little interest in the medical community.  The North Carolina PHP audit  revealed financial conflicts-of-interest and no oversight by the state medical society or board and that abuse of doctors could occur undetected due to the complete absence of accountability.  State Auditor Beth Woods told  the British Medical Journal in a recently  published article that the state program had holes in it “big enough to drive a truck through.”

In  Ethical and Managerial Considerations Regarding State Physician Health Programs Knight and Boyd state:  “Because PHP practices are unknown to most physicians before becoming a client of the PHP, many PHPs operate outside the scrutiny of the medical community at large. Physicians referred to PHPs are often compromised to some degree, have very little power, and are, therefore, not in a position to voice what might be legitimate objections to a PHP’s practices.”  And when objections do occur many take the side of the PHP, complacent in their belief that these are just altruistic and competent doctors just helping sick colleagues and protecting the public and valid complaints are deemed nothing more than “bellyaching.  In reality the ethical and criminal misconduct occurring in PHPs rivals that of Dr. Farid Fata,  the Detroit Oncologist who intentionally misdiagnosed patients with cancer so he could make money off unnecessary chemotherapy treatment.  Dr. Fata’s egregious betrayal of trust and unconscionably vile acts resulted in an appropriate response.

Screen Shot 2015-04-13 at 9.53.44 AMThe exact same misconduct is being perpetrated by PHPs but being overlooked, justified or otherwise ignored.  Dr. Fata intentionally misdiagnosed patients with cancer who did not have cancer so he could give them chemotherapy to make money.   PHPs are intentionally misdiagnosing substance abuse and behavioral disorders in physicians who do not have them in order to give them unneeded treatment and force them into monitoring contracts for profit and control.

This  undermines the very integrity of the profession.  It is particularly vile when the betrayal of trust involves doing the opposite of what was entrusted.   Abuse of positions of power, trust and influence in the field of medicine need to be both prevented, recognized and addressed.    Oversight, regulation and accountability are essential  if this is going to be accomplished.  There are no exceptions.   Policies and procedures must be enforced in a consistent manner.

The medical boards, medical societies, and departments of health have given the state PHPs carte blanche control and absolute power.  They refuse to even investigate accusations and they have convinced law enforcement that this is a parochial matter best handled by within the medical profession. As a result, valid complaints of crimes are not taken seriously.  This refusal to investigate  or even acknowledge valid and factual complaints of professional misconduct has not only prevented the exposure of  wrongdoing and corruption but deepened it.    The Federation of State Physician Health Programs and “Like-minded docs” must be recognized for what they are.  Front-groupsscreen-shot-2016-10-04-at-3-49-21-pm for the drug and alcohol assessment, testing and treatment industry.   This is glaringly obvious and you don’t have to look that deep to figure it out.  And these are the very same groups being proposed as advocacy bodies for addiction treatment and public policy change.  It is not that hard to figure out what they will be advocating for –more diagnoses, more testing and more treatment.

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The American philosopher Eric Hoffer noted:

“The only way to predict the future is to have power to shape the future. Those in possession of absolute power can not only prophesy and make their prophecies come true, but they can also lie and make their lies come true.” 

The “PHP-blueprint”  is built on the very foundation Hoffer describe and unless you want mandated randomized  non-FDA approved drug and alcohol testing with “swift and certain” consequences at future visits with your doctor you will need to speak up.

This occurred in the medical profession rapidly and with little notice and that is exactly what will happen here.

 “Every time we turn our heads the other way when we see the law flouted, when we tolerate what we know to be wrong, when we close our eyes and ears to the corrupt because we are too busy or too frightened, when we fail to speak up and speak out, we strike a blow against freedom and decency and justice.” 

Robert F. Kennedy

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The Proposed Expansion of “physician health programs” (PHPs)and the urgent need for a critical analysis of irrational and illegitimate authority

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Physician Health Programs  (PHPs) claimed “gold standard” for addiction treatment. “80% success rate” being used to promote “new paradigm” to other populations. 

1. National Physician Health Program Blueprint Study Publications List

2.  Setting the Standard for Recovery: Physicians’ Health Programs

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PHPs are essentially Employee Assistance Programs (EAPs)  for doctors.  The vast majority of people know little or nothing about Physician Health Programs (PHPs).

Physician Health Programs (PHPs) are being called  the “gold-standard” for EAPs.    Claims of unparalleled success are being used to promote PHPs to other populations as a “replicable model of recovery.”

Drs. Robert Dupont and Gregory Skipper are promoting PHPs as “A New Paradigm for Long-Term Recovery”  claiming an 80% success rate in doctors.

An article entitled “What Might Have Saved Philip Seymour Hoffman,” claims PHPs “ought to be considered models for our citizenry” and the “best evidence-based addiction treatment system we have going.”   The author repeats the 80% success rate for doctors and claims Philip Seymour Hoffman might still be alive if he had been treated using the PHP model.

The basis for these claims is a 2009 study published in the Journal of Substance Abuse Treatment entitled  Setting the Standard for Recovery: Physicians’ Health Programs and authored by Robert Dupont,  A. Thomas McLellan,  William White, Lisa Merlo and Mark Gold.

This  study is the cornerstone of the “PHP-blueprint.” It is the very  foundation on which everything else is based, a Magnum opus used to lay claim to supremacy that has been endlessly repeated and rehashed in a plethora of self-promotion and treatment community blandishment.

To date there has been no academic analysis of the “PHP-Blueprint.”    There has been no Cochrane type analysis or critical review.    There has been no opposition to its findings or conclusions which are paraded as fact and truth without challenge or question and there is a general lack of concern from those both within and outside the medical profession.


The Expansion of Physician Health Programs (PHPs) to Other Populations

1.  Although these programs claim to help doctors they may actually be harming many and contributing to suicide.

2.  The plan is to greatly expand these programs to other populations and you could be next.

In 2012 Robert Dupont delivered the keynote speech at the Drug and Alcohol Testing Industry Association annual conference and described a “new paradigm” for addiction and substance abuse treatment and proposed expansion of this paradigm to other populations including workplace, healthcare, and schools.

It is therefore critical that the “PHP-blueprint” be examined using critical reasoning and evidence base.   All of this needs to be assessed in terms of legitimacy and intent.

Lack of Evidence-Base and Conflicts of Interest

A  cursory  analysis of the study on which this success rate is based reveals very little evidence base.

The claim of 80% success rate in physicians is based on Setting the Standard for Recovery: Physicians’ Health Programs is unfounded.  The study is a poorly designed using a single data set (a sample of 904 physician patients consecutively admitted to 16 state PHP’s).

It  is non-randomized and non-blinded rendering the evidence for effectiveness of the PHP treatment model over any other treatment model (including no treatment) poor from a scientific perspective.  The study contains multiple flaws in both reasoning (type I and type II errors) and statistical analysis that render its conclusions invalid.

In addition the impact of undeclared but substantial financial conflicts-of-interest (including funding by drug testing and addiction treatment industries) and personal ideological biases (including personal 12-step recovery from addictions) in the authors of this study also needs to be considered.

Moreover the misdiagnosis and over-diagnosis of addiction in physicians in this paradigm  incentivized by lucrative self-referral dollars for expensive 90-day treatment programs is a significant factor.

False Endpoints and High Mortality Rate

The mean age of the 904 physicians was 44.1 years. They report that 24 of 102 physicians were transferred and lost to follow “left care with no apparent referral.”

What happened to them? These are physicians with multiple identifiers (state license, DEA, UPIN, etc) not transient drifters.

More importantly what happened to those 48 who were reported to the Medical Board for noncompliance and had their licenses revoked–that would be the critical time when this population would be at most risk for completing a suicide. That would be when hope was lost and the coerced physician, knowing that the fight was over, would take that step.

The outcomes they used were the last reported status of the PHP participant enrolled in the program.   Measuring success of program completion in doctors compared to the general population is meaningless as the short-term outcomes are quite different in terms of the external consequences imposed.   The consequence of not completing a PHP is the invariably career ending.    So what happened to the 24 of who “left care with no apparent referral,” the 85 who “voluntarily stopped or retired,” and the 48 who “involuntarily stopped or license revoked.”

Whether you leave a PHP voluntarily, involuntarily, or with no apparent referral it is the end game and your career is over.  Comparing this to other populations where the consequences of failing to complete the program are not so final is inappropriate.     Claiming superiority over programs with a 40% success rate is unfounded because for most of those people the consequences are not so final and may mean nothing more than an increase in testing frequency.

The big question is what happened to the 157 physicians who left or stopped?  How many of them killed themselves. With an average age of 44 there were  6 reported suicides 22 deaths, and another 157 no longer doctors.  I would venture to say the number of suicides is a lot higher than they claim.  But using the last recorded PHP status as the final outcome obfuscates this.

Due to the severity of the consequences a 20% failure rate is quite concerning. This is of particular concern because many doctors (if not most) monitored by PHPs are not addicts.

As noted above, PHPs are essentially Employee Assistance Programs (EAPs)  for doctors. Most EAPs, however, were developed in the presence of trade unions and other organizations working on behalf of the best interests of the employee. This collaborative effort led to EAPs that were more or less “organizationally just” with procedural fairness and transparency.

Imposed 12-step ideology and use of non-FDA Approved Drug and Alcohol Testing

No such organizations exist for doctors.   Due to the absence of oversight and accountability  PHPs have been able to use non-FDA approved laboratory developed tests of unknown validity on doctors without any opposition.

The distinction between professional and private life as a fundamental value of our society  and the importance of this boundary was also upheld by these groups.

In the PHP paradigm no procedural fairness or transparency exists and the boundary between professional and private life has eroded.

PHPs impose 12-step ideology on all doctors referred to these programs.   State Medical Boards  enforce this in violation of the Establishment Clause of the 1st Amendment yet there is little recourse for doctors as they are threatened with non-compliance and loss of licensure.

Selling the PHP Paradigm

The use of 12-step  is most likely not ideologically driven but profit driven.

Abstinence based 12-step programs justify the use of frequent drug and alcohol testing with ongoing lifelong assessment and treatment.    As with drug-courts,  PHPs provide a lucrative model to the drug and alcohol testing, assessment and treatment industry.

The plan to expand this to other populations is outlined in the ASAM White Paper.

This concerns all of us.  The first step needs to be a critical appraisal of  Setting the Standard for Recovery: Physicians’ Health Programs,  the foundation of their claims of an 80% success rate and a conflict-of-interest analysis of its authors.  The legitimacy of the study and its claims needs to be questioned.

It does not take a Cochrane review to see that the emperor has no clothes.  This is not difficult. It is straightforward and simple.

As an illegitimate and irrational authority it is necessary that this opinion remain unchallenged. We need to challenge it.

Historical, political, economic and social analysis reveals that the “PHP-blueprint” is a false-construct built on circumnavigation and obfuscation.  An evidence-based scrutiny of the literature would reveal it to be invalid and of little probative value.

But if  nobody speaks up it is inevitable that they will expand the “PHP blueprint”  to other employee assistance programs and schools.

This is not just about doctors.  You too are at risk for coercion, control, conformity and forced adherence to a  lifetime of abstinence and 12-step indoctrination and if you do not speak up now it won’t be a risk but a certainty.

The “PHP-Blueprint”–A Trojan Horse for Profit and Wider Social Control

 

 

Screen Shot 2016-02-19 at 2.47.54 AM.png“In the small world of drug testing, these four—Angarola, Bensinger, DuPont and Willette—are affectionately referred to as the Gang of Four. Dr. John Morgan explains, “They are the ones responsible for a good deal of drug testing’s success, and some of the fear that goes along with it. Remember these names. These men are among the most competent and knowledgeable about drug testing—scientifically and politically. They are well-informed: they have to be. Their livelihoods depend upon their credibility. Unfortunately their expertise represents the greatest threat to the civil liberties we seek to protect. Know your enemy.” 1

Steal This Urine Test – Fighting Drug Hysteria In America – By Abbie Hoffman with Jonathan Silvers. 1986


A recent Huffington Post article written by Maia Szalavitz, The Rehab Industry Needs to Clean Up Its Act Here’s How, describes the need to radically rethink and reform American addiction treatment.. The article quotes Dr. Mark Willenbring who states

“What we simply need is a nice bulldozer, so that we could level the entire industry and start from scratch.”

Agreed, but the chances of this are slim to none if the “PHP-blueprint” becomes the “New Paradigm.”  To prevent this from happening it is critical to disprove the claims, recognize the threat, and address the matter directly and collectively.   We need political and social activism in the same spirit as Abbie Hoffman whose words from three decades ago are aptly accurate.  His prescient warnings remain unknown, forgotten, or irrelevant to us today but their accuracy is crystal clear.  Few people know the enemy.

Screen Shot 2016-02-19 at 2.45.36 AMOn April 23, 2015 Dr. Robert Dupont, MD addressed the House Subcommittee on Oversight and Investigations Combatting the Opioid Abuse Epidemic and proposed widespread application of a “New Paradigm” for substance abuse management based on the nation’s physician health program (PHP) model of care.

This model is being brandished as “gold standard for addiction treatment” to the drug and alcohol rehabilitation community and general public. The medical literature contains numerous articles claiming the high success rate of these programs4,6,9,10 and they are being promoted to set the “ standard for recovery” as a replicable model to be used for treating “other addicted populations.”11  In his speech before the House Subcommittee Dupont states critics call the expansion “utopian” but many would beg to differ. “Dystopian” would be more like it.

There has been an increasing scrutiny of these programs recently  not yet covered by mainstream media.  The link between the marked increase in physician suicide (which is much more than the oft quoted medical school class of 400 per year is directly related to the FSPHP takeover of PHPs).  A recent Medscape article   describes the coercion, control, secrecy and conflicts-of-interest between the PHPs and their “PHP-approved” assessment and treatment centers.  The simple fact is the majority of doctors referred to these programs do not have a substance use disorder or psychiatric problem but are given one nevertheless. This removes their locus of control and puts the PHP in complete power.  Their fate is in the hands of the PHP.

The assessment and treatment facilities used by PHPs do not take insurance and require payment up front. It is all out of pocket because if insurance was involved the fraud would have been discovered long ago. The PHPs have no accountability.  There is no oversight by medical boards or medical societies and answerability and justification for actions are absent.  And as we are hearing the rehabilitation industry itself is unregulated.  So too are the junk-science lab tests used in PHP programs as these non-FDA lab tests and the corrupt labs that use them have no oversight form the FDA or any other agency able to hold them to account.  It is a free for all.

Those ensnared in this web do know the enemy but can do nothing about it.   I am hearing story after story of doctors seeking help from their medical societies, law enforcement,  the media and the ACLU only to be turned away.

Their stories are remarkably similar An increasing number of complaints involving PHPs and the preferred assessment and treatment centers and contracted commercial labs are being reported.   A recent lawsuit filed by a doctor against the North Carolina PHP and Medical Board reported on Medscape last week is a prototypical case. The scenario typically goes like this: An accusation is made against a doctor who has had no previous disciplinary history or concerns (alcohol on breath, throwing a surgical instrument) and referred to the state PHP; An assessment is recommended by the PHP at an out-of-state “PHP-approved” assessment and treatment center; the assessment confirms a psychiatric problem or substance use disorder and recommends typically three-months of inpatient treatment followed by a 5-year contract with the state PHP for monitoring. It is becoming clear that doctors who do not fit the diagnostic criteria for a disease are being diagnosed with a disease. There are also complaints of laboratory misconduct and forensic fraud.

It is important to recognize that State PHP programs require strict adherence to 12-step doctrine11 and limit assessments to not only ASAM facilities but to a specific constellation of 12-step assessment and treatment centers with medical directors who belong to a group called like-minded docs.  It is in fact a “rigged game.”

In “Six lessons from state physician health programs to promote long-term recovery” Dupont and Dr. Greg Skipper attribute this success rate to the following factors:12

(1) Zero tolerance for any use of alcohol and other drugs;

(2) Thorough evaluation and patient-focused care;

(3) Prolonged, frequent random testing for both alcohol and other drugs;

(4) Effective use of leverage;

(5) Defining and managing relapses; and

(6) The goal of lifelong recovery rooted in the 12-Step fellowships.12

In truth the sole basis for these claims is a single retrospective cohort study of 904 physicians monitored by 16 state PHPs initially published in the British Medical Journal in 2008.2 In 2009 the same study was published in the Journal of Substance Abuse Treatment3 and deemed the “PHP-blueprint. Methodologically flawed and rife with conflicts-of-interest this study is the sole foundation of all of the claims.   Of the 904 participants 102 were “lost to follow up” and of the remaining 802, 155 failed to complete the contract but despite the small numbers this study has been hashed and rehashed to brandish the claims of an 80% success rate physician including subsets of psychiatrists,4 surgeons5 and anesthesiologists6  In his address to the House Subcommittee Dupont, who is a co-author on every one of these papers, claims similar success in a subgroup of opioid addicted doctors.

None of this has been subjected to normal scientific peer-review procedures and represents a serious departure from the normal standards of scientific inquiry

The same forces that have created and sustained the current monopoly of 12-step oriented treatment in America have grand plans through links  forged though government, private agencies and the drug and alcohol testing assessment and treatment industry.

Through a combination of large-scale funding, rhetorical persuasion and moral panics they have gained both tremendous sway and power in the profession of medicine and the collateral damage they have caused is widespread and permanent.   They are poised to do the same to others using the  same methods and the procedural protections afforded to those currently being tested for substances of abuse in Federal Workplace Drug Testing programs will be removed without your consent or knowledge.   I recently heard from someone  that these groups are lobbying the Nuclear Regulatory Commission into accepting this model with some resistance.

As far-fetched as all of this sounds all one has to do is look. The greatest threat to the civil liberties we seek to protect is no longer a threat but a reality.

Examine the documents below and connect the dots to see the coming Trojan horse for systemic application of a flawed substance abuse management program with no evidence base.

Medicalization of 12-step  will be accomplished when “addiction medicine” becomes recognized as a bona-fide medical specialty by the American Board of Medical Specialties.(ABMS) which is slated to occur within the next couple years. At that point this group will deem 12-step ideology as best practice  “evidence-based” doctor recommended care. This will “sanctify” the  ideology as medical “standard of care” and can then be imposed on anyone with impunity and immunity.   Medicalization subverts the Establishment clause of the 1st Amendment and the propaganda supporting this has already begun.   See the 12-step “facilitation”  piece below giving the reasoning they will use.  This is not facilitation but coercion.

The ASAM White Paper on Drug Testing promotes random testing of everyone using the Non-FDA approved tests of unknown validity currently used in state physician health programs. This will be implemented through the healthcare system by removing procedural protections currently in place under federal guidelines. This is sure to be a boon for anyone battening and fattening off the Drug and Alcohol Testing Industry Association or rehab racket gravy train but a burden and pain for the rest of us.

The conflicts of interest are unfathomable.

Dupont and fellow “Gang of Four” member Peter Bensinger (DEA chief, 1976–1981) run a corporate drug-testing business. Their employee-assistance company, Bensinger, DuPont & Associates is the sixth largest in the nation and managing drug testing for some 10 million Americans including Kraft Foods,  the FAA and even the Justice Department.  They sell drug-testing management programs.  The “New Paradigm” is simply a ruse to get non-FDA approved testing into the wider workplace via loopholes and workarounds.  His ties to the drug and alcohol testing and treatment industry are easy to find.  Drug testing is a multi-billion-dollar-a-year industry. DATIA [Drug & Alcohol Testing Industry Association] represents more than 1,200 companies and employs a DC-based lobbying firm, Washington Policy.  Many of the non-FDA approved tests they are using in the “PHP-blueprint” they in fact introduced to the market themselves with no evidence base. It is reprehensible.

And the people who will suffer most in the “New Paradigm” will be those who are already marginal in American society. That’s a given. I have heard from doctors who are gay or belong to a minority group who claim they were referred to a PHP due to discrimination but had no recourse.

Medicalization of behavior  removes due process as the victimized are simply put in a labeled group and via actuarial logic that safely that removes the underlying prejudice from view by categorization of risk.   Discrimination is justified and rationalized.   So read the documents below and connect the dots. Then do something about it.  Say something. Write something.  Do something.  The Emperor has no clothes and this needs to be exposed. Either defend what you read below or protest this New Inquisition.  We need revolt and Revolution.  The Federation Of State Physician Health Programs (FSPHP) regime is simply another front-group designed to force the medical profession in line for the profits of the rehab racket.  The FSPHP is the enemy and State PHPs need to be reformed and repaired  with transparency and accountability. And to accomplish this the entire long running mess needs  to be bulldozed  and rebuilt from scratch.

  1. Robert Dupont’s 2012 Keynote speech before the Drug and Alcohol Testing Industry Association
  2. Robert Dupont’s address before the House Subcommittee on Oversight and Investigation Combatting the Opioid Epidemic
  3. 2014 Journal of the American Medical Association (JAMA) article entitled “Addiction Medicine: The Birth of a New Discipline
  4. The ASAM White Paper on Drug Testing
  5. Why good addiction centers connect clients to AA or NA

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  1. Hoffman A, Silvers J. Steal This Urine Test: Fighting Drug Hysteria in America. 1 ed: Penguin Books.
  2. DuPont RL, McLellan AT, Carr G, Gendel M, Skipper GE. How are addicted physicians treated? A national survey of Physician Health Programs. Journal of substance abuse treatment. Jul 2009;37(1):1-7.
  3. White WL, Dupont RL, Skipper GE. Physicians health programs: What counselors can learn from these remarkable programs. Counselor. 2007;8(2):42-47.
  4. Skipper GE, Campbell MD, Dupont RL. Anesthesiologists with substance use disorders: a 5-year outcome study from 16 state physician health programs. Anesthesia and analgesia. Sep 2009;109(3):891-896.
  5. Yellowlees PM, Campbell MD, Rose JS, et al. Psychiatrists With Substance Use Disorders: Positive Treatment Outcomes From Physician Health Programs. Psychiatric services. Oct 1 2014.
  6. DuPont RL, McLellan AT, White WL, Merlo LJ, Gold MS. Setting the standard for recovery: Physicians’ Health Programs. Journal of Medical Regulation. Mar 2010;95(4):10-25.
  7. Dupont RL, Skipper GE. Six lessons from state physician health programs to promote long-term recovery. Journal of psychoactive drugs. Jan-Mar 2012;44(1):72-78.
  8. McLellan AT, Skipper GS, Campbell M, DuPont RL. Five year outcomes in a cohort study of physicians treated for substance use disorders in the United States. Bmj. 2008;337:a2038.
  9. DuPont RL, McLellan AT, White WL, Merlo LJ, Gold MS. Setting the standard for recovery: Physicians’ Health Programs. Journal of substance abuse treatment. Mar 2009;36(2):159-171.
  10. Buhl A, Oreskovich MR, Meredith CW, Campbell MD, Dupont RL. Prognosis for the recovery of surgeons from chemical dependency: a 5-year outcome study. Archives of surgery. Nov 2011;146(11):1286-1291.


Please donate here:  https://www.gofundme.com/PHPReform

There is a very urgent need for a “counterpower” to state physician health programs (PHPs). On average five or six medical students, doctors or residents contact me each week and I want to continue to help them and work toward advocacy and watchdog groups.  Unfortunately I am losing ground quickly.  We have made tremendous advances in the last year and I am working in many different venues to expose the problems written about here.  Those involved in this corrupt system are hoping that I will run out of resources and simply go away and have done everything they can to accomplish this. Without your help this will occur and it will unfortunately occur soon.

 

 

 

 

 

Letters From Those Abused and Afraid

Letters From Those Abused and Afraid.

I’m hearing from more and more doctors via my survey, emails and phone calls.  At this point the patterns are becoming crystal clear and they involve the same “physician wellness” actors, the same “PHP-approved” assessment and treatment facilities and the same commercial “forensic” drug testing labs.

It is all the same M.O.  A false accusations  is made followed by misrepresentation of laboratory developed tests (LDTs) or outright forensic fraud.    A referral is then made for an “evaluation” at one of the “PHP-approved” facilities where an “assessment” is “tailored” to fit a pre-determined diagnosis.  The PHP then says do anything and everything we say or we will “end you.”  And all too often that is exactly what they do.   It is Political Abuse of Psychiatry plain and simple.   It does not get any more egregious than this folks.

The Doctors dying from this system of institutional injustice are not dying by suicide.  This is more akin to murder and the murderers have removed themselves from all aspects of accountability including answerability, justification for actions and the ability to be punished by third party actors truly outside the system. It is a rigged game.

the-world-is-a-dangerous-place-to-live-not-because-of-the-people-who-are-evil-but-because-of-the-people-who-don_t-do-anything-about-itThe sociopaths responsible for ordering false assessments and falsified drug and alcohol testing as well as those complying with it in the drug and alcohol testing, assessment and treatment industry need to be held accountable.

Those ordering the falsified tests and assessments are essentially putting guns to the heads of doctors.  The labs and rehab centers complicit in this fraud are pulling the trigger.  Simple as that.

You can see some of these letters here:  Letters From Those Abused and Afraid.

The Irrational Authority

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The Irrational Authority.  Originally posted on:

Chaos Theory and Pharmacology

A blog dedicated to the study of complex relationships in pharmacology. “Journalism is printing what someone else does not want printed: everything else is public relations.” ― George Orwell

The Irrational Authority

Goodle F. Re: ‘Drug Policy: We Need Brave Politicians and Open Minds
The BMJ. December 17, 2014.

Drug policy: we probably need an “irrational authority”

“One thing is for certain. When society gives power of diagnosis and treatment to individuals
within a group schooled in just one uncompromising model of addiction with the majority attributing their very own sobriety to that model, they will exercise that power to diagnose and treat anyone and everyone according to that model. The birth of Addiction Medicine as an ABMS accepted discipline is sure to be a success for the drug and alcohol testing and 12-step treatment industry, but its spawn is sure to be an inauspicious mark on the Profession and Guild of Medicine and a bane of society for years to come.” ―Michael Lawrence Langan.(1)

References

1. DISRUPTED PHYSICIAN 101.2: “ADDICTION MEDICINE” IS A SELF-DESIGNATED PRACTICE SPECIALTY UNRECOGNIZED BY THE AMERICAN BOARD OF MEDICAL SPECIALTIES–(AN AMA CENSUS TERM INDICATING NEITHER TRAINING NOR COMPETENCE).
URL: https://disruptedphysician.com/2014/11/21/disrupted-physician-101-3-addic… (date accessed: December 17, 2014).

Competing interests: No competing interests

Additional comments

I. The original title of this response:

– Drug policy: we probably need an “irrational authority”.

Please read as:

– Drug policy: we definitely need an “irrational authority”.

II. Societies like the American Society of Addiction Medicine and American Psychiatric Association have been self-proclaimed as “rational authorities”: a euphemism created probably by complex defense mechanisms of self-preservation in a society used to suppress dissenters and reward the wrongdoers.

“The Ministry of Peace concerns itself with war, the Ministry of Truth with lies, the Ministry of Love with torture and the Ministry of Plenty with starvation. These contradictions are not accidental, nor do they result from ordinary hypocrisy: they are deliberate exercises in doublethink.”
― George Orwell, 1984

“Doublethink means the power of holding two contradictory beliefs in one’s mind simultaneously, and accepting both of them.”
― George Orwell, 1984

III. We probably need more “irrational authorities”.

The Elephant in the Room: Physician Suicide and Physician Health Programs

The Elephant in the Room: Physician Suicide and Physician Health Programs.

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Accountability is  rooted in organizational purpose and public trust.  Unfortunately, humanitarian ideals have been trampled by the imposition of corporate front groups who advance  hidden agendas under guises of science and scholarship  and patinas of benevolence.  Rife with conflicts of interest, these groups obfuscate, mislead and exploit us to further an underlying political and corporate agenda.  Healthcare and medicine has been infiltrated by various groups that pose a serious threat to both the humanitarian and evidence based aspects.

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The Plan to introduce non-FDA approved drug and alcohol tests into the Healthcare system and require doctors drug-test ALL PATIENTs including students and kids!

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The Plan to introduce non-FDA approved Laboratory Developed Tests (LDTs) into the Healthcare system and require doctors drug-test ALL PATIENTs including students and kids!

The ASAM plans to introduce non-FDA approved “forensic”  Laboratory Developed Tests (LDTs) into mainstream healthcare via a loophole.    This same group introduced most of these tests through a loophole and now they want to drug-and alcohol TEST EVERYBODY including STUDENTS AND KIDS through another loophole!   These tests are of unknown reliability and accuracy.  The LDT pathway does not even require proof that the test is even valid  (i.e. that the test is actually testing for the substance it claims to be testing) but with no FDA oversight or regulation the labs can claim anything they want in marketing it and they do.

If a doctor collects a test on a “patient”  the test is rendered “clinical” rather than “forensic” and by deeming this drug-testing  “clinical” rather than “forensic”  they can then call the consequences of a positive test “treatment” rather than “punishment.  ” It is via this loophole they plan to introduce and unleash the panoply of junk-science tests currently being used on other groups who have no say in the matter (probationers, parolees, private professional monitoring groups, etc. ) onto the general population at large.    A boon for the Drug and Alcohol Testing Industry Association and the assessment and treatment industry but a bane to the rest of society.    And to prevent this from happening more people need to be talking about this.

Disrupted Physician 101.2: “Addiction Medicine” is a Self-Designated Practice Specialty Unrecognized by the American Board of Medical Specialties–(An AMA Census Term Indicating Neither Training nor Competence)

Disrupted Physician 101.2: “Addiction Medicine” is a Self-Designated Practice Specialty Unrecognized by the American Board of Medical Specialties–(An AMA Census Term Indicating Neither Training nor Competence)B1A19yWIMAAQf7EThe fraudulent Addiction Medicine drug-testing, assessment and treatment complex is a  charade of prohibitionists and profiteers.  It is time that this be identified and addressed. Addiction Medicine has evolved in a Lord-of-the-Flies manner without regulatory scrutiny or oversight and an absence of the need to guard. They are the Robber barons of Science and Medicine who have bought and boondoggled their way into the Medical Profession and Society  and are poised to ruin both. It is time to take aim at these unsupervised pundits of authoritative opinion with facts, evidence base, and the scientific method. The immense and unconscionable conflicts of interest  must also be addressed. And the blinkered apathy of the masses and willful ignorance of organized medicine needs to end now!   If not the ASAM White Paper on Drug Testing  will come to pass and we will be  faced with a future Police State run by unqualified, illegitimate and irrational zealots and profiteers.

johnnyLawrence

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