Dispensary Agent Collaborative

February 27th, 2014 by Will Humble Leave a reply »

Last Wednesday we held a Medical Marijuana Dispensary Collaborative.  It was modeled after last year’s successful ADVICE Collaborative, which brought dialysis facilities together to share best practices and engage in a dialog to reduce infection control violations and improve patient care.  The goal of the meeting was to avoid future deficiencies by ensuring that dispensaries understand our expectations and to help us better understand their challenges. 

The Dispensary Collaborative had a great turnout, with almost 150 dispensary agents, board members, and medical directors. The all-day meeting covered dispensary inspection results, patient and dispensary agent educational resources offered by the Arizona Poison Control, the administrative rules process, financial audit requirements (including the difference between profit and non-profit entities), and our computerized Point of Sale system that’s used by dispensaries to verify the status of cards and record marijuana transactions. 

Overall, the input and suggestions that we received from the dispensaries was constructive and will be helpful as we continue to move forward with building a solid relationship with our dispensary stakeholders.



  1. Bill Hayes says:

    great! did you tell them to stop selling meds with pesticides in them without labeling them as such?

    Did you ask when any of these places are going ot be cropping out?

    Did you do the math on how much was sold as opposed to how much COULD have been legally produced by patients and or caregivers??

    Did you actually do anything that benefited the patients who rely on you sir or was this just more hand shakes and shoulder rubbing with your “stakeholders”.

    Keep it real folks.

    This crap law is now and always will be about the money unless you under-write it.

    Pathetic that the electorate that put this law into place cares so little about it.

  2. When do the patients get their meeting? says:

    A day late and a dollar short!

    Really Mr. Humble you are so pathetic. I talked to several dispensary agents that attended this meeting and they were disgusted with your demands, especially the one to spend $20,000 with your hand-picked accounting firm to have a forensic audit done to prove the dispensary is truly non-profit!

    You’re sitting on 6 million dollars of patient monies collected, there is no reduction of fees for anyone unless you are destitute, a veteran or 65 or over. The majority of the 40,000 plus patients are not dirt poor, or veterans or 65 or over. Stop with your uneducated approach to a medicine that you know nothing about, will learn nothing about and all you care about is lining the pockets of your friends over there at Sherman & Howard law firm. This law firm is unethical and there are court transcripts showing this. Get a clue and get a professional cannabis consultant in from Colorado to show you how to run a medical marijuana program that truly benefits the patients not your pet clients.

    • Will Humble says:

      Thanks for the constructive criticism!

      • James says:

        Director Humble,

        I trust that your reply above has the right dosage of sarcasm that those posts deserved. Everyone knows that the authors of those blog posts want nothing more than to grow weed for themselves and their ONE AND ONLY concern is that they’re adversely affected by the 25 mile rule. The court has spoken and now they’re relegated to attacking you on the blogs. They’ve been doing it for years underground – and probably still are — and are having difficulty adapting to a MMJ model. Accept it for what it is. It’s those strident voices that will be our worse enemy in 2016 if they can’t work within the confines of the law now. This isn’t Colorado – unfortunately in many ways – however, unless we deal the cards we’ve been dealt, we won’t move the discussion and therefore the industry any further. I believe your response says it all so enough said.

        In regards to constructive comments/criticism, consider this.
        Dispensaries wouldn’t have to spend $20,000 in auditing fees if they’d been doing things right all along. They’re paying to “get the books in order” so that their accountants will be able to defend indefensible conduct. However, the department has to accept some responsibility in that regard. Requiring dispensaries to create some “creative accounting” because you’ve incorporated impossible rules – i.e. can’t pay a dispensary agent for meds — is unrealistic. No one has to get rich, but growers certainly aren’t “donating” time after having spent the considerable amount of time, energy, money and effort for months to grow quality, medical grade cannabis. Dispensaries shouldn’t have to add those people to their boards or pay $50,000/month for “deliveries” simply to compensate growers what is due them. There needs to be a recognition that those people need to be paid, and they’re being paid for the cannabis, not for time and not for gas, etc.

        Secondly, unless and until DHS comes down hard on dispensaries who are clearly diverting funds from their non-profit dispensary to their for-profit holding company, the practice is going to continue with reckless abandon. There are cases that I personally know of where the revenues aren’t even hitting the dispensary itself, but are going directly into the holding company’s pockets, well beyond getting a reasonable ROI. The department needs to decide to either make the program a for-profit model, which is really the only model that is sustainable, or not. However, if you’re only giving lip service to a not for profit model, then you’re doing a disservice to all and have created a program ripe for fraud.

        How are you holding dispensaries accountable for their educational and charitable endeavors? What about the obligation to provide meds for indigent patients or patients in need? These requirements shouldn’t be reported on annually, but like most not for profits, verification should be made on a quarterly basis. DHS could use some U of A or ASU graduate school interns studying non-profit management to monitor those activities and to provide counsel to the dispensaries.

        Moreover, unless and until DHS in fact does step in and hold dispensary owners to the voracity of their original applications (why can’t a dispensary owner who allegedly had a location and money at the time they won the lottery open after almost 1 1/2 years?) Have you considered that perhaps the application was fraudulent in the first place? How is that fair to those applicants who submitted factual applications, yet didn’t receive “the lucky ball?” If the integrity of the process is questioned, you lose all credibility. You were directed by Judge Warner to review those applications and provide administrative relief – that’s it. That was almost 7 months ago and the vast majority of those plaintiffs are still piddling around because the problems they had originally – when they claimed they were taken care of – weren’t. (All of that could be remedied by requiring that whatever location you submit is where you need to open barring some extenuating circumstance, i.e. the building burned down, etc. No more of this landlord letter nonsense when the landlord never intended to lease the site in the first place)..

        Why haven’t those people who caused the program to be delayed by a year, been held accountable and their certificates returned to the pool for the next lottery, if appropriate? How is that fair to the majority of people who weren’t awarded a license?

        Further, unless and until the department holds dispensaries who are clearly in violation of the AMMA responsible (illegal compassion clubs, illegal collaborative dispensary/compassion club delivery models, etc), the industry perception is that the department is impotent and “DHS isn’t going to do anything”. Whether that’s true or not, that is clearly the perception. Why not report – without divulging confidential information – complaints, pending investigations, closed investigations, etc to a) act as a deterrent and b) provide transparency? I have spoken to local law enforcement and if reports of these illegal clubs were made, that would give them what they need to start the investigation; that apparently hasn’t been done.

        I recognize that DHS is not law enforcement, however a task force that makes recommendations to law enforcement when there are clear violations would ensure that integrity is maintained and that there are consequences for misconduct.

        Director Humble, while I understand that the department has probably grown weary of litigation, there needs to be accountability or the perception is that there is no accountability. Your staff has seen some incredibly large grows, I’m sure. While DHS has no regs in regards to the size of a cultivation site, an admonition that you “grow at your own risk of antagonizing the Federal government” might be in order. Unless you protect the integrity of the AMMA based on the conduct of a few it will be lost for all forever. Hopefully that isn’t your intention, so these are the types of safeguards that are appropriate and should be considered.

        I truly believe that it was initially your intent to build a model program. Unfortunately, with all of the litigation, public opposition, political sabotage, etc., that message has been muddled. However, what else would you expect? When you allocate dispensaries with the drop of a lottery ball, this is what you get. Nevertheless, I’m optimistic that it’s not too late to right the ship and get things in order!

        You have dispensary owners with some experience now. You have legal counsel who recognize areas for improvement. You have dispensary agents who are in the trenches every day. You have patients who are stakeholders and have a vested interest. You have law enforcement who has seen breaches in the system. You have enough data and human intelligence — if you really want it — to improve the program dramatically…if that is truly your intent!

        It would be money much better spent than funding litigation to keep a 5 year old boy with seizures from getting a tincture to put on his cereal upon the recommendation of a physician and under the watchful eye of distraught parents.

        The ball is in your court to take the bull by the horns and to regain control. It’s your call! Hopefully you will be on the right side of history when all is said and done.

    • James says:

      Do you really think comments like this change anything? If so, why don’t you post your name instead of hiding anonymously.

      DHS and that law firm are the ONLY reason the program has moved forward. Can you imagine if our county attorney was in charge of DHS.

      Get a life and get the facts…or at least change your strain!

    • James says:

      Do you really think comments like this change anything? If so, why don’t you post your name instead of hiding anonymously.

      DHS and that law firm are the ONLY reason the program has moved forward. Can you imagine if our county attorney was in charge of DHS.

      Get a life and get the facts…or at least change your strain!

  3. sarah yates says:

    ADHS blankets over the MMJ community as it slowly constricts the quality of service offered to its patients.

    To that effect I do hope Kavanaugh is successful with the removal of the AMMA later this year, it seems no one cares for this program or its patients any longer.

    Show me a positive news article about AZ MMJ and I will show you a surprised face. 

    • James says:

      Talk to a patient who is helped and you won’t see a surprised face, but an extremely grateful person.

    • Bill Hayes says:

      whenever you’d like to sit down and talk, bring something to record with, I have plenty of people.

      Try Zander Welton who can now use his medicine and all the other kids who are about to flock to sunny Arizona in search of the next cure for disease.

  4. Bill Hayes says:

    James, I know you were not speaking to me. I have added more constructive criticism in regards to this program than anyone else I have seen publicly. I am a dispensary agent as well as a vested partner in a licensed dispensary, as well as a patient. Still think you are able to assume to understand my motives?
    While you make some quality points of discussion and you make them so eloquently might I add, please remember the above statement, I have been talking to Will on this blog since it’s inception so do forgive me if my patience has run thin.

    The 25 mile rule is unconstitutional, the judge agreed, did you miss that fact? Another motion had been drafted and was funded by patients in less than 48 hrs. Still think it’s just a couple people, check the class action page lol. Learn to protect your rights before you don’t have any buddy.

    As you even suggest, board members, lol, no, try growers and importers.

    Next, rehashing compassion clubs? There is a reason judge Fink didn’t rule, figure out what that is yet? Maybe because there is nothing in the AMMA restricting patient to patient SALES? In fact, the only way a patient can have their card revoked is to “SELL marijuana to a person not authorized by this chapter. ” So who CAN a patient SELL marijuana to in accordance with the AMMA? Not a dispensary or dispensary agent so says the AMMA, but, that’s it. Statutory construction provides the same determination, redendo singulus singularis, meaning applies only to the end, as in. .. “Nothing of value is transferred”. Checkmate.

    Next time you address me take into consideration I filed the ONLY lawsuit against AZDHS (Will) that isn’t listed on the AZDHS website, anywhere, other than this blog. There is a reason for that and it isn’t because I haven’t done my due diligence, and don’t understand the law or the system in place it governs. I know every word, and as I have been saying for years, “words” are very important in a court room as each has been defined carefully. Generally the definition is not what you think it is.

    Thanks for your post above, where has it been all this time I have been here complaining as a dispensary agent, , dispensary owner, caregiver and patient?!

  5. Bill Hayes says:

    For anyone that doesn’t know because they didn’t read it all.
    36-2815. Revocation
    (Caution: 1998 Prop. 105 applies)
    A. The department shall immediately revoke the registry identification card of a nonprofit medical marijuana dispensary agent who violates section 36-2804.01, subsection D, or section 36-2816, subsection B. The department shall suspend or revoke the registry identification card of a nonprofit medical marijuana dispensary agent for other violations of this chapter.
    B. The department shall immediately revoke the registration certificate of a registered nonprofit medical marijuana dispensary that violates section 2816, subsections B or C, and its board members and principal officers may not serve as the board members or principal officers for any other registered nonprofit medical marijuana dispensary.
    C. Any cardholder who SELLS marijuana to a person who is not allowed to possess marijuana for medical purposes under this chapter shall have his registry identification card revoked, and shall be subject to other penalties for the unauthorized SALE of marijuana and other applicable offenses.

    Emphasis mine. What you thought was the law was just one man’s interpretation of the AMMA wording, and that man is NOT a judge 😉

  6. Bill Hayes says:

    36-2801. Definitions
    (Caution: 1998 Prop. 105 applies)
    In this chapter, unless the context otherwise…

    2. “Cardholder” means a qualifying patient, a designated caregiver or a nonprofit medical marijuana dispensary agent who has been issued and possesses a valid registry identification card.

    So a cardholder CAN be a patient, and therefore a PATIENT can SELL marijuana to another PERSON who is allowed to possess marijuana for medical purposes under the AMMA.

    This isn’t about the AMMA folks, is about prison contracts for 100 % capacity or you pay the penalty. Same reason they are fighting the Welton case, who might I add, contacted me for help with meds long ago and that is when that whole thing got started.

    They need people to prosecute that will take the plea to establish a false precedent for “the status quot” to accept as the result of using hash or extracts, they need to bust illegal growers, importers etc.
    Learn to see the big picture and follow the money.

  7. Ian says:

    Dear Will Humble:

    I want to make sure you see this, so I’m posting here re: evidence of medical marijuana for migraines. Check out this source and please follow it further; let me know what you think.

    “Cannabis for Migraine Treatment: the Once and Future Prescription?”

    by Ethan Russo

    “Pain” in Science Direct
    Volume 76, Issues 1–2, May 1998, Pages 3–8

  8. Along with almost evrything which seems to bbe building within this area, your opinions are relatively stimulating.

    Even so, I beg your pardon, because I can not give credence to your whole theory,
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  9. Digusted says:

    Well it finally happened. http://www.azcentral.com/story/news/local/mesa/2014/03/23/mesa-boy-pot-extract/6795707/

    When can I buy my HASH in Dispensaries?

    A Judge has ruled qualified MMJ patients can consume extracts. I don’t know why it took a Judge to state this cannabis in all forms is to be accepted by qualified patients looking for relief, whether it be in HASH OIL RESINS EXTRACTS CONCENTRATES HEMP OIL

    This is all for MMJ patients not for anyone else.

    Thank God there is an ACLU.

  10. Digusted says:

    You know you give us this crap that there is ambiguity in the law between cannabis and marijuana vs plant material vs extracts

    MMJ patients knew this was crap Mr Humble and so does a Judge. This criminal code vs AMMA act interpretation was interpreted long ago correctly by MMJ patients but there

    are parties involved who are attempting to prevent me from any and all forms of my medicine.

    Thank God for the ACLU

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