Laboratory developed tests (LDTs) have no FDA or CLIA oversight. Avoiding regulatory oversight is just one of the ways those involved in the use of these tests avoid accountability. Without answerability to third parties they have essentially removed themselves from consequences.
College of American Pathologists (CAP) accreditation is the sole avenue for complaint. CAP does not sanction. They only have the ability to educate lab to come under compliance with CAP standards under threat of loss of accreditation and it is under this threat that they can force a laboratory to correct both unintentional and intentional errors. This is what was done in my case.
I filed a complaint with CAP in January of 2012. The “Litigation packet ” showing forensic fraud was sent to CAP and I was informed that the investigation could take many months. In October of 2012 I was suddenly reported to the Board of Registration in Medicine for “noncompliance” with AA meetings (that were the sole and direct result of this test) and action was taken against my medical license which resulted in my suspension.
In December of 2012, the Chief Investigator for CAP, Amy Daniels called me to see how I was doing in light of the “amended” test. She told me that the test had been invalidated on October 4, 2012. I told her this was news to me as I was in the process of being suspended for “noncompliance” and called the Director of Operations at Physician Health Services (PHS) Linda Bresnahan who predictably told me she was unaware of any revision to the test.
But the very next day a letter was sent out signed by PHS Medical Director Dr. Luis Sanchez, M.D. stating that they had just found out about the amended test on December 10. 2012, the day before when I called them. Interestingly the letter acknowledged the invalidity of the test but stated PHS and the BORM would “continue to disregard” it. Sanchez also made it a point in the letter to state they were were not aware of any consequences resulting from it. They denied any knowledge of an October 4, 2012 revision which would have been 67-days earlier than this acknowledgment and dismissal of the test.
In response to 93-A demand letters from my attorney for fraud, PHS, Quest and USDTL all refused to consider any damages by blaming my suspension on me. They claimed my suspension was due to my “noncompliance” with attending AA meetings that was officially reported to the Board October 18, 2012. The claimed the test that was used as a stepping-stone for all subsequent adverse events was completely irrelevant and had nothing to do with anything. This is what is known as “moving the goalpost.” What they did not know was that I would eventually be able to get the document proving they knew what they knew and when they knew it.
The response letters revealed important information that was previously only speculative with no way to prove. Both labs, in defense, claimed that the test was sent as “clinical” specimen at the request of PHS (an ultra vires out of scope act as they are a 503(B) charity. PHS is not a healthcare provider and is not authorized to practice medicine.
PHS and the labs were apparently unaware of the new HIPAA Privacy rule that requires labs to provide patients with their lab tests without approval from the agency ordering the test. PHS had previously refused to provide labs by hiding under confidentiality and medical records regulations.
At first they refused but CAP and the DOJ -civil rights division forced USDTL to provide the document below dated October 4, 2012 informing Dr. Luis Sanchez of the amended test he reported in a signed letter to a state agency that he had just found out about December 10, 2012. The letter undeniably shows Sanchez lied to a state agency in a written letter. This is also a prima facie crime. It is just one of many crimes that Board Attorney Deb Stoller has facilitated for PHS as her job is to ignore, suppress, minimize and deflect any criminal acts committed by PHS and protect them. And this needs to be made public. PHS needs to be held accountable. So too do the actions of Ms. Stoller whose job as an agent of the state makes her involvement even more egregious than the perpetrators.
The documents below show a clear violation of M.G.L. 256 (B) Section 69 done under Color of Law.
Title 18, U.S.C., Section 242
Deprivation of Rights Under Color of Law
This statute makes it a crime for any person acting under color of law, statute, ordinance, regulation, or custom to willfully deprive or cause to be deprived from any person those rights, privileges, or immunities secured or protected by the Constitution and laws of the U.S.
This law further prohibits a person acting under color of law, statute, ordinance, regulation or custom to willfully subject or cause to be subjected any person to different punishments, pains, or penalties, than those prescribed for punishment of citizens on account of such person being an alien or by reason of his/her color or race.
False Statements Relating to Health Care Matters (18 U.S.C. § 1035) It is a crime to knowingly and willfully falsify or conceal a material fact, make any materially false statement, or use any materially false, fictitious, or fraudulent writing or document in connection with the delivery of or payment for health care benefits, items, or services. 11 Chapter 2 ~ Summary of Fraud and Abuse Laws
Mail and Wire Fraud (18 U.S.C. §§1341 and 1343) Statutes, which prohibit the use of the mails or the wires to further “schemes” to defraud
Perjury and False Statements
PERJURY BY WRITTEN INSTRUMENT.
FALSE STATEMENTS (18 U.S.C. § 1001)
This statute prohibits the making of any false, fictitious, or fraudulent statement to the United States or a government agency. This statute is exceedingly broad: It covers any statement or representation made to the government or any of its agents. A statement can be made either orally or in writing, and it can be sworn or unsworn.
Supression of Dissent: Basic Information
2. The keys to backfire
• “Reveal: expose the injustice, challenge cover-up
• Redeem: validate the target, challenge devaluation
• Reframe: emphasize the injustice, counter reinterpretation
• Redirect: mobilize support, be wary of official channels• Resist: stand up to intimidation and bribery”
I can think of nothing more institutionally unjust than an unregulated zero-tolerance monitoring program with no oversight using unregulated drug and alcohol testing of unknown validity. But that is what is occurring. Some of us are trying to expose this corrupt system but barriers exist. As with the Laboratory Developed Tests (LDTs), those involved have intentionally taken steps to remove both answerability and accountability. Both the tests and the body of individuals administering these tests are notable for their lack of transparency, oversight and regulation. This renders them a power unto themselves.
Doctors (and others coerced into Professional Health Programs) across the country have reported going to law enforcement and state agencies only to be turned away. The Federation of State Physician Health Programs (FSPHP) has convinced these outside agencies that this is a “parochial” issue best handled by the medical profession.. Those reporting crimes are turned back over to the very people committing the crimes.
Although no reliable statistics exist, anecdotal reports suggest an alarming upsurge in physician suicide. This necessitates a reappraisal of known predisposing risk factors such as substance abuse and depression but also requires a critical examination of what external forces or vulnerabilities might be unique to doctors and how they might be involved in the descent from suicidal ideation to suicidal planning to completed suicide.
Depression and Substance Abuse Comparable to General Population
Depression and substance abuse are the two biggest risk factors for suicide. The prevalence of depression in physicians is close to that of the general population 1,2 and, if one looks critically at the evidence based literature, substance abuse in medical professionals approximates that of the general population. Controlled studies using DSM diagnostic criteria suggest that physicians have the same rates (8-14%) of substance abuse and dependence as the rest of the population 3 and slightly lower rates compared to other occupations.4,5 Epidemiological surveys reveal the same. Hughes, et al.6 found a lifetime prevalence of drug or alcohol abuse or dependence in physicians of 7.9%, markedly less than the 14.6% prevalence reported in the general population by Kessler.7
State Physician Health Programs
Perhaps it is how physicians are treated differently when they develop a substance abuse or mental health problem.
Physician Health Programs (PHP) can be considered an equivalent to Employee Assistance Programs (EAPs) for other occupations. PHPs meet with, assess and monitor doctors who have been referred to them for substance use or other mental or behavioral health problems. Originally developed as “impaired physician” programs, the PHPs were created to help doctors who developed problems with substance abuse or addiction an alternative to disciplinary action by State Medical Boards. These programs existed in almost every state by 1980. Often staffed by volunteer physicians and funded State Medical Societies, these programs served the dual purpose of helping sick colleagues and protecting the public. Preferring rehabilitation to probation or license revocation so long as the public was protected from imminent danger, most medical boards accepted the concept with support and referrals. Most EAPs were developed with the collaboration of workers unions or some other group supporting the rights and interests of the workers. As there is no such organization representing doctors, PHPs developed in the absence of regulation or oversight. As a consequence there is no meaningful accountability.
“Because PHP practices are unknown to most physicians before becoming a client of the PHP, many PHPs operate out- side 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.”8
Noting that “for most physicians, participation in a PHP evaluation is coercive, and once a PHP recommends monitoring, physicians have little choice but to cooperate with any and all recommendations if they wish to continue practicing medicine,” Knight and Boyd raise serious ethical and managerial questions about current PHP policies and practice including conflicts of interest in referrals for evaluation and treatment, lack of adherence to standards of care for forensic testing of substances of abuse, violations of ethical guidelines in PHP research, and conflicts of interest with state licensing boards.
Knight and Boyd recommend “that the broader medical community begin to reassess PHP’s as a whole” and that “consideration be given toward the implementation of independent ethical oversight and establish and appeals process for PHP clients who feel they are being treated unfairly.” 8 They also recommend the relationship of PHP’s between the evaluation and treatment centers and licensing boards be transparent and that national organizations review PHP practices and recommend national standards “that can be debated by all physicians, not just those who work within PHPs.”8 Unfortunately this has not happened. Most physicians have no idea that the state physician health programs have been taken over by the “impaired physicians movement.”
In his Psychology Todayblog, Boyd again recommends oversight and regulation of PHPs. He cites the North Carolina Physicians Health Program Audit released in April of 2014 that reported the below key findings:
As with Knight and Boyd’s paper outlining the ethical and managerial problems in PHPs, the NC PHP audit finding that abuse could occur and not be detected generated little interest from either the medical community or the media.
Although state PHPs present themselves as confidential caring programs of benevolence they are essentially monitoring programs for physicians who can be referred to them for issues such as being behind on chart notes. If the PHP feels a doctor is in need of PHP “services” they must then abide by any and all demands of the PHP or be reported to their medical board under threat of loss of licensure.
LDTs bypass the FDA approval process and have no meaningful regulatory oversight. The LDT pathway was not designed for “forensic” tests but clinical tests with low risk. Some are arguing for regulation and oversight of LDTs due to questionable validity and risk of patient harm.13
These same physicians are claiming a high success rate for PH programs9 and suggesting that they be used for random testing of all physicians.14
As with LDTs, the state PHPs are unregulated, and without oversight. State medical societies and departments of health have no control over state PHPs.
Their opacity is bolstered by peer-review immunity, HIPPA, HCQIA, and confidentiality agreements. The monitored physician is forced to abide by any and all demands of the PHP no matter how unreasonable-all under the coloration of medical utility and without any evidentiary standard or right to appeal.
The ASAM has a certification process for physicians and claim to be “addiction” specialists. This “board certification” is not recognized by the American Board of Medical Specialties and is not a recognized medical specialty. The goal of the ASAM is to be recognized as the experts in addiction medicine with the consensus expert opinion based on the 12-step prohibitionist brain disease model. The ASAM has aligned itself with a number of inpatient drug treatment centers (Hazelden, Talbott, Marworth, Bradford,etc) and are heavily funded by the drug testing industry. It is in fact a “rigged game.”
State PHPs are non-profit non-governmental organizations and have been granted quasi-governmental immunity by most State legislatures from legal liability.
By infiltrating “impaired physician” programs they have established themselves in almost every state by joining, gaining power, and removing dissenters. Groupthink and 12-step indoctrination are the goals. By advertising as advocates for doctors who are “caring,” “confidential resources,” “giving help,” and advocating for “colleagues in need” the outward appearance is one of benevolence.
The biggest obstacle is that this system allows them to throw the normal rules of conduct under the imperative of a higher goal assumed to trump all other consideration. Those outside of programs either defend or ignore the reports of ethical and criminal violations, complacent in their trust of these “experts” claiming they are just helping sick doctors and protecting the public.
With no oversight or regulatory body involved this is all done with impunity, immunity, and undercover. They use the accusation of substance abuse as an indication to disregard the claims of the accused. The physician is left without rights, depersonalized, and dehumanized. The imposition of confinement, stigmatization, lack of oversight of the organizations, peer-review protected confidentiality, and lack of procedural protection is a one-way train to hopelessness and despair.
By establishing a system that of coercion, control, secrecy, and misinformation, the FSPHP is claiming an “80% success rate” 15and deeming the “PHP-blueprint” as “the new paradigm in addiction medicine treatment.
The ASAM/FSPHP had a major influence on the DSM-V where drug abuse and dependence are no longer separate entities. They are also working behind the scenes to get legislation to randomly drug test all physicians.
They are now after the “disruptive physician” and the evidentiary criteria are fairly low and red flags include “deviating from workplace norm in dress or conduct” and being tardy for meetings.
They have identified “the aging physician” as a potential problem because “as the population of physicians ages,””cognitive functioning” becomes “a more common threat to the quality of medical care.”
The majority of physicians are unaware that the Federation of State Medical Boards House of Delegates adopted an updated Policy on Physician Impairment in 2011 that uses addiction as an example of a “potentially impairing illness.” According to the Federation of State Physician Health Programs …”physician illness and impairment exist on a continuum with illness typically predating impairment, often by many years. This is a critically important distinction. Illness is the existence of a disease. Impairment is a functional classification and implies the inability of the person affected by disease to perform specific activities.”
“Process addiction” was added as a potentially impairing illness including compulsive gambling, compulsive spending, compulsive video gaming, and “workaholism.” According to the FSPHP “the presence of a process addiction can be problematic or even impairing in itself, and it can contribute to relapse of a physician in recovery. As such, process addictions should be identified and treated.” They define three levels of relapse including the novel “relapse without use.”
Bullying, Helplessness, Hopelessness and Despair
Perceived helplessness is significantly associated with suicide.16 So too is hopelessness, and the feeling that no matter what you do there is simply no way out17,18 Bullying is known to be a predominant trigger for adolescent suicide19-21 One study found that adolescents in custody who were bullied were 9.22 times more likely to attempt suicide than those were not bullied.22
Heightened perceptions of defeat and entrapment are known to be powerful contributors to suicide.23,24 The “Cry of Pain” model 25,26 specifies that people are particularly prone to suicide when life experiences are interpreted as signaling defeat which is defined as a sense of “failed struggle” or loss of social position and resources.. The person is unable to identify an escape from or resolution to a defeating situation, a sense of entrapment proliferates with the perception of no way out, and this provides the central impetus for ending ones life.
There is also evidence that rescue factors such as social supports may play a role in preventing suicide. These rescue factors act buffers to protect against suicide in the face of varying degrees of life stress.27,28 The study of female physicians revealed meetings to discuss stressful work experiences as a potential protective factor, 29 and support at work when difficulties arose appeared to be a protective factor for the male physicians.30 Research involving Finnish physicians found that control over one’s work and organizational justice were the most important determinants of work-related wellbeing.31,32 Organizational justice is related to fairness and refers to an individuals perception of an organizations behaviors, decisions, and actions and how these influence one’s own attitudes and behaviors and has been identified as a psychosocial predictor of health and wellbeing3334 Low organizational justice has been identified as a notable risk factor for psychological distress and depression.35,36
A recent report indicates that job stress, coupled with inadequate treatment for mental illness may play a role in physician suicide..
Using data from the National Violent Death Reporting System the investigators compared 203 physicians who had committed suicide to more than 31,000 non-physicians and found that having a known mental health disorder or a job problem that contributed to the suicide significantly predicted being a physician.1
Physicians were 3.12 times more likely to have a job problem as a contributing factor. In addition, toxicology testing showed low rates of medication treatment. The authors concluded that inadequate treatment and increased problems related to job stress are potentially modifiable risk factors to reduce suicidal death among physicians.
They also warned that the database used likely underestimated physician suicides because of “underreporting and even deliberate miscoding because of the stigma attached.”
I can think of nothing more institutionally unjust than an unregulated zero-tolerance monitoring program with no oversight using unregulated drug and alcohol testing of unknown validity.
We have heard of numerous suicides due to these institutionally unjust programs. Three doctors died by suicide in Oklahoma in a one month period alone (August 2014). All three were being monitored by the Oklahoma PHP. I went to an all boys high-school of less than 350 students yet a classmate a couple years ahead of me died by suicide a few months ago. He was being monitored by the Washington PHP. His crime? A DUI in 2009–a one-off situational mistake that in all likelihood would never have recurred. But as is often the case with those ensnared by state PHPs he was forced to have a “re-assessment” as his five-year monitoring contract was coming to an end. These re-assessments are often precipitated by a positive Laboratory Developed Test (LDT) and state medical boards mandate these assessments can only be done at an out-of-state “PHP-approved” facility. Told he could no longer operate and was unsafe to practice medicine by the PHP and assessment center he then hanged himself. And at the conclusion of Dr. Pamela Wible’s haunting video below are listed just the known suicides of doctors; many were being monitored by their state PHPs–including the first name on the list– Dr. Gregory Miday.
None of these deaths were investigated. None were covered in the mainstream media. These are red flags that need to be acknowledged and addressed! This anecdotal evidence suggests the oft-used estimate of 400 suicides per year (an entire medical school class) is a vast underestimation of reality—extrapolating just the five deaths above to the entire population of US doctors suggests we are losing at least an entire medical school per year.
As physicians we need to demand transparency, oversight, regulation and auditing by outside groups. This is a public health emergency.
To wit:
They first came after the substance abusers and I did not speak out because I was not a substance abuser.
They then came for those with psychiatric diagnoses and I did not speak out because I was not diagnosed with a psychiatric disorder.
They then came after the “disruptive physician” and I did not speak out because I was not disruptive.
They then came after the aging physician and I did not speak out because I was young.
They then came after me and there was no one else to speak out for me.
Ford DE, Mead LA, Chang PP, Cooper-Patrick L, Wang NY, Klag MJ. Depression is a risk factor for coronary artery disease in men: the precursors study. Archives of internal medicine. Jul 13 1998;158(13):1422-1426.
Frank E, Dingle AD. Self-reported depression and suicide attempts among U.S. women physicians. The American journal of psychiatry. Dec 1999;156(12):1887-1894.
Brewster JM. Prevalence of alcohol and other drug problems among physicians. JAMA : the journal of the American Medical Association. Apr 11 1986;255(14):1913-1920.
Anthony J, Eaton W, Mandell W, al. e. Psychoactive Drug Dependence and abuse: More Common in Some Occupations than in Others? Journal of Employee Assistance Res. 1992;1:148-186.
Stinson F, DeBakely S, Steffens R. Prevalence of DSM-III-R Alcohol abuse and/or dependence among selected occupations. Alchohol Health Research World. 1992;16:165-172.
Hughes PH, Brandenburg N, Baldwin DC, Jr., et al. Prevalence of substance use among US physicians. JAMA : the journal of the American Medical Association. May 6 1992;267(17):2333-2339.
Kessler RC, Berglund P, Demler O, Jin R, Merikangas KR, Walters EE. Lifetime prevalence and age-of-onset distributions of DSM-IV disorders in the National Comorbidity Survey Replication. Archives of general psychiatry. Jun 2005;62(6):593-602.
Boyd JW, Knight JR. Ethical and managerial considerations regarding state physician health programs. Journal of addiction medicine. Dec 2012;6(4):243-246.
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.
Skipper GE, Weinmann W, Thierauf A, et al. Ethyl glucuronide: a biomarker to identify alcohol use by health professionals recovering from substance use disorders. Alcohol and alcoholism. Sep-Oct 2004;39(5):445-449.
Skipper GE, Thon N, Dupont RL, Baxter L, Wurst FM. Phosphatidylethanol: the potential role in further evaluating low positive urinary ethyl glucuronide and ethyl sulfate results. Alcoholism, clinical and experimental research. Sep 2013;37(9):1582-1586.
Skipper GE, Thon N, DuPont RL, Campbell MD, Weinmann W, Wurst FM. Cellular photo digital breathalyzer for monitoring alcohol use: a pilot study. European addiction research. 2014;20(3):137-142.
Sharfstein J. FDA Regulation of Laboratory-Developed Diagnostic Tests: Protect the Public, Advance the Science. JAMA : the journal of the American Medical Association. Jan 5 2015.
Pham JC, Pronovost PJ, Skipper GE. Identification of physician impairment. JAMA : the journal of the American Medical Association. May 22 2013;309(20):2101-2102.
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.
Rivers I, Noret N. Potential suicide ideation and its association with observing bullying at school. The Journal of adolescent health : official publication of the Society for Adolescent Medicine. Jul 2013;53(1 Suppl):S32-36.
Lester D, Walker RL. Hopelessness, helplessness, and haplessness as predictors of suicidal ideation. Omega. 2007;55(4):321-324.
Beck AT. Hopelessness as a predictor of eventual suicide. Annals of the New York Academy of Sciences. 1986;487:90-96.
Hinduja S, Patchin JW. Bullying, cyberbullying, and suicide. Archives of suicide research : official journal of the International Academy for Suicide Research. 2010;14(3):206-221.
Hertz MF, Donato I, Wright J. Bullying and suicide: a public health approach. The Journal of adolescent health : official publication of the Society for Adolescent Medicine. Jul 2013;53(1 Suppl):S1-3.
Kim YS, Leventhal B. Bullying and suicide. A review. International journal of adolescent medicine and health. Apr-Jun 2008;20(2):133-154.
Kiriakidis SP. Bullying and suicide attempts among adolescents kept in custody. Crisis. 2008;29(4):216-218.
Taylor PJ, Gooding P, Wood AM, Tarrier N. The role of defeat and entrapment in depression, anxiety, and suicide. Psychological bulletin. May 2011;137(3):391-420.
Lester D. Defeat and entrapment as predictors of depression and suicidal ideation versus hopelessness and helplessness. Psychological reports. Oct 2012;111(2):498-501.
Williams JMG. Cry of Pain. Harmondsworth: Penguin; 1997.
Williams JMG, Crane C, Barnhofer T, Duggan DS. Psychology and suicidal behavior: elaborating the entrapment model. In: Hawton K, ed. Prevention and treatment of suicidal behavior: from science to practice. Oxford: Oxford University Press; 2005:71-89.
Borowsky IW, Ireland M, Resnick MD. Adolescent suicide attempts: Risks and protectors. Pediatrics. 2001;107(485).
Clum GA, Febbraro GAR. Stress, social support and problem-solving appraisal/skill: Prediction of suicide severity within a college sample. Journal of Psychopathology and Behavioral Assessment. 1994;16:37-46.
Fridner A, Belkic K, Marini M, Minucci D, Pavan L, Schenck-Gustafsson K. Survey on recent suicidal ideation among female university hospital physicians in Sweden and Italy (the HOUPE study): cross-sectional associations with work stressors. Gender medicine. Apr 2009;6(1):314-328.
Fridner A, Belkic K, Minucci D, et al. Work environment and recent suicidal thoughts among male university hospital physicians in Sweden and Italy: the health and organization among university hospital physicians in Europe (HOUPE) study. Gender medicine. Aug 2011;8(4):269-279.
Lindfors PM, Meretoja OA, Toyry SM, Luukkonen RA, Elovainio MJ, Leino TJ. Job satisfaction, work ability and life satisfaction among Finnish anaesthesiologists. Acta anaesthesiologica Scandinavica. Aug 2007;51(7):815-822.
Heponiemi T, Kuusio H, Sinervo T, Elovainio M. Job attitudes and well-being among public vs. private physicians: organizational justice and job control as mediators. European journal of public health. Aug 2011;21(4):520-525.
Elovainio M, Kivimaki M, Vahtera J. Organizational justice: evidence of a new psychosocial predictor of health. Am J Public Health. Jan 2002;92(1):105-108.
Lawson KJ, Noblet AJ, Rodwell JJ. Promoting employee wellbeing: the relevance of work characteristics and organizational justice. Health promotion international. Sep 2009;24(3):223-233.
Hayashi T, Odagiri Y, Ohya Y, Tanaka K, Shimomitsu T. Organizational justice, willingness to work, and psychological distress: results from a private Japanese company. Journal of occupational and environmental medicine / American College of Occupational and Environmental Medicine. Feb 2011;53(2):174-181.
Lang J, Bliese PD, Lang JW, Adler AB. Work gets unfair for the depressed: cross-lagged relations between organizational justice perceptions and depressive symptoms. The Journal of applied psychology. May 2011;96(3):602-618.
Physician Suicide–What to do When Your Doctor Dies Suddenly by Pamela Wible, M.D.
Physician Suicide 101: Secrets, Lies & Solutions by Dr. Pamela Wible, M.D
Physician Suicide 101: Secrets, Lies & Solutions By Dr. Pamela Wible, M.D. will hopefully serve as a stepping-stone to start discussing Physician Health Programs (PHPs) and their relationship to physician suicide. (click on photo above to access article).
The current state-of-affairs is one of unrestrained managerial authority and absolute power with no meaningful oversight, regulation or accountability. Moreover, the authority bestowed on this group is both illegitimate and irrational. The Federation of State Physician Health Programs is composed of American Society of Addiction Medicine “specialists” in “Addiction Medicine.” The ASAM is not even recognized by the American Board of Medical Specialties as a bona fide specialty. It is a Self-Designated-Medical-Specialty; an AMA term used to keep track of what any group of doctors…