2022 Atlanta Board of Trustees Meeting

2/12/2022

State Medical Board of Ohio

30 E. Broad St., 3 rd Floor Columbus, Ohio 42315 (614) 466-3934 www.med.ohio.gov

Dear members of the Ohio Medical Board :

Thank you for the opportunity to review proposed rule 4731-11-04. In opening, I like medical boards to consider that obesity has been recognized as a chronic disease by our American Medical Association in 2013, to be treated the same as other diseases such as hypertension and type 2 diabetes. I was personally involved in the passing of that resolution, and I was the author of the later resolution calling on the AMA to help remove barriers to treatment so that physicians can practice the current standard of care with regards to the treatment of obesity without fear of reprisal. I appreciate the State ’ s concerns regarding mis-use of older medications due to the fact that they are Schedule IV controlled substances; however, as you review your rules, please consider the following question – would you have the same rule in place for a disease such as diabetes or hypertension? Also, will the rule improve the care the patient receives, or will it be a barrier for them to receive treatment? With that in mind, this proposed rule represents a good step in the right direction. In particular, eliminating the rule to only use medication short-term for a chronic condition is extremely helpful, and allows the current standard of care to be provided for many more Ohio patients living with obesity. That being said, I do have several concerns with the proposed language where I think it is overly prescriptive and will still represent a barrier to care for many patients, particularly with those with difficult to treat obesity. Item B (3) (d) – BMI is intended as a population-based measurement, and should not be strictly enforced with the individual patient. This language could be improved by adding language to the effect that “ or the benefits of weight loss treatment for the patient would significantly outweigh any risks of the medication being used. ” Further, this does not make allowance for on-label use of current or future medications in kids, where it is based on BMI percentile, not BMI (see Saxenda label, for example). You could address this with additional language, “ Or pursuant to guidance from package inserts. ”

5995 Greenwood Plaza Blvd. Ste 150, Greenwood Village, CO 80111 | 303.750.9454 www.ClinicalNutritionCenter.com