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In the palliative and hospice medicine of Ukraine, there are a number of unresolved legal and organizational problems that stand in the way of a dignified existence of hopelessly ill patients in the last days and months of their lives. First of all, these are unresolved issues with the coverage of treatment and care of a sufficient number of categories of patients: palliative care is provided mainly to patients with oncological, cardiovascular and neurological profiles of treatment. Secondly, it is the lack of adequate analgesia for a significant number of inpatients and the vast majority of patients receiving treatment at home. Availability of recently legalized medical cannabis remains low for palliative care patients, and palliative care euthanasia is not legalized. In our previous research, we found out that Ukrainian society is not ready for a dialogue about the need to legalize euthanasia, and that the best model of preparing society for euthanasia is the Canadian one, which is based on a comprehensive study of the opinions of the general public and direct participants of the Medical Assistance in Dying (MAiD), as well as on the implementation of decisions federal court. The article is devoted to legal procedures and socio-medical aspects of euthanasia and MAiD in the Netherlands, Belgium and Germany. Certain aspects of legalization, its context and circumstances, compared with the conditions of Ukraine. The article is an original theoretical study performed using the method of systematic analysis, comparative and bibliosemantic methods. Note that we are clarifying the terminology of the previous stages of the study: MAiD is performed by the patient himself, euthanasia is performed by the doctor. In our opinion, Ukraine needs the legalization of euthanasia and MAiD for all age categories, and with the implementation of special additional consent procedures for adult incapacitated patients. In the experience of the countries of the current comparison, we paid special attention to the prevention of abuses in the implementation of these procedures, in the conditions of frequent disregard for the norms of the law since the beginning of the war. Keywords: palliative and hospice care, suicides of palliative patients, Medical Assistance in Dying, right to life, right to die.
In the palliative and hospice medicine of Ukraine, there are a number of unresolved legal and organizational problems that stand in the way of a dignified existence of hopelessly ill patients in the last days and months of their lives. First of all, these are unresolved issues with the coverage of treatment and care of a sufficient number of categories of patients: palliative care is provided mainly to patients with oncological, cardiovascular and neurological profiles of treatment. Secondly, it is the lack of adequate analgesia for a significant number of inpatients and the vast majority of patients receiving treatment at home. Availability of recently legalized medical cannabis remains low for palliative care patients, and palliative care euthanasia is not legalized. In our previous research, we found out that Ukrainian society is not ready for a dialogue about the need to legalize euthanasia, and that the best model of preparing society for euthanasia is the Canadian one, which is based on a comprehensive study of the opinions of the general public and direct participants of the Medical Assistance in Dying (MAiD), as well as on the implementation of decisions federal court. The article is devoted to legal procedures and socio-medical aspects of euthanasia and MAiD in the Netherlands, Belgium and Germany. Certain aspects of legalization, its context and circumstances, compared with the conditions of Ukraine. The article is an original theoretical study performed using the method of systematic analysis, comparative and bibliosemantic methods. Note that we are clarifying the terminology of the previous stages of the study: MAiD is performed by the patient himself, euthanasia is performed by the doctor. In our opinion, Ukraine needs the legalization of euthanasia and MAiD for all age categories, and with the implementation of special additional consent procedures for adult incapacitated patients. In the experience of the countries of the current comparison, we paid special attention to the prevention of abuses in the implementation of these procedures, in the conditions of frequent disregard for the norms of the law since the beginning of the war. Keywords: palliative and hospice care, suicides of palliative patients, Medical Assistance in Dying, right to life, right to die.
Background. The practice of countries in legalizing euthanasia is useful for other countries that have not yet allowed Medical Assistance in Dying (MAiD). Palliative patients in these countries have varying levels of access to medical care, including adequate analgesia. Medical care in many countries does not meet the needs of palliative patients, and systems of palliative and hospice care are often poorly developed. MAiD can be an alternative to the suffering of palliative patients at the end of life. Aim. Analysis of legal, social and financial aspects of euthanasia legalization in different countries of the world. Materials and Methods. The method of system analysis, comparative method and bibliosemantic method were used for the research. Results and Conclusions. The path to the legalization of euthanasia begins with a wide public debate. Important is the opinion of medical professionals, who are usually divided into two camps: those who deny the necessity and humanity of euthanasia, as well as those who advocate legalization to end the suffering of their patients, seeking to satisfy their persistent and conscious desire to exercise their "right to die". Countries take different paths and at different speeds to legalize euthanasia. The difference between the models of legalized euthanasia lies, first of all, in its permitted type (passive or active), distribution to different age categories of hopeless patients (in particular, to children), to incapacitated patients with cognitive disorders. Active euthanasia is allowed in such European countries as the Netherlands (since 2001), Belgium (since 2002), Luxembourg (since 2009), Spain (since 2010), Switzerland (since 2011). Since these years, there has been a change in the attitude towards medically assisted death of the European Court of Human Rights, which previously categorically regarded euthanasia as intentional murder. In all countries that have legalized euthanasia, an active discussion continues regarding the rules for its implementation. A common feature of countries that have already legalized euthanasia is the approval of the procedure by at least a third of medical professionals. Keywords: medically assisted suicide, suicide tourism, Quality of Death Index, suicide of critically ill palliative patients, right to life, right to die.
Medical Assistance in Dying (MAiD) is legally used in such countries as the Netherlands, Belgium, Luxembourg, Switzerland, Colombia, Canada, Australia, Spain, Germany, and the USA. Portugal and New Zealand are considering legal euthanasia laws. MAiD is performed by injecting a lethal substance into a terminally ill person by a doctor or the patient himself. Euthanasia is one of the services that palliative patients need in the last months and days of their lives. The availability of MAiD increases the country's ranking in the Quality of Death Index and reduces the need for euthanasia tourism. Ukraine needs the legalization of MAiD, as well as the improvement of the palliative and hospice care system in general. The research was conducted using the methods of systematic analysis, the comparative method and the bibliosemantic method with the search for literary sources and legal acts in Google, Google Scholar and PubMed, with an emphasis on Ukraine, Switzerland, the USA, Canada and Israel. During the comparative analysis, it was concluded that the Canadian model of the MAiD is optimal for Ukraine, taking into account the experience of its construction, society's perception and problems related to the application of the legislative norms of the MAiD. The Canadian health care system, the MAiD practice is guided by the social perception of its work models. Legislators respond sensitively to thorough scientific research and court decisions, which respect state and social institutions. The analyzed results of scientific research in Switzerland, the USA and Israel warn researchers and legislators against possible abuses in the implementation of MAiD. But at the same time, they attest to the importance of an accessible MAiD procedure for terminally ill palliative patients, which should be available for the realization of the right to a dignified death along with quality palliative medicine for the realization of the right to a dignified life. Keywords: palliative and hospice care, health care system reform, Medical Assistance in Dying, Quality of Death Index, right to life, right to die.
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