One of our top priorities as we implement the AZ Medical Marijuana Act over the coming months is to ensure that we develop good Rules (called Administrative Code) so we can regulate medical marijuana effectively. Rules that are clear, objective, well-researched, and that balance competing interests are absolutely critical in order to effectively implement a responsible medical marijuana program. Our goal is to develop rules that’ll ensure qualified patients have access to marijuana for their medical condition while preventing (to the extent possible) recreational marijuana users from accessing marijuana through the Act’s provisions. In addition, we want to develop Rules that ensure that marijuana dispensaries act responsibly and have adequate security and inventory controls.
In order to achieve these goals we will need your help. Over the coming months we need input from all Arizona residents so that we’re able to balance all of the competing interests and come up with the most responsible set of regulations possible. I’m certain we’ll have plenty of comments from the people who intend to apply for a dispensary license or become a qualified patient, caregiver, dispensary agent, or provide medical marijuana recommendations. However, it’s more challenging to get input from residents who will have no direct interest in the industry but still want the law to be implemented in an effective way that minimizes abuse.
Please reach out to some of your stakeholder groups and ask them to check out our new website, review our informal draft rules and provide us with input so that we can make good decisions. Here are a few tips for people that would like to provide input:
- Use our comment website so that you can submit electronic comments
- Encourage folks to tell us what they like about the informal draft rule as well as what they don’t like. There’s a tendency for people to focus on things they don’t like and it’s just as important for us to know when something is on target.
- Encourage constructive comments and pragmatic alternative. It is even better if people submit alternate Rule language.
- Encourage people to focus on what’s good public policy rather than submitting comments that are designed to give themselves a competitive advantage or that are self-serving.
- Remember to remind stakeholders as they comment that the provisions of the Act limit our ability to regulate in many ways. For example, while the Act gives ADHS broad authority to regulate dispensaries but little authority to regulate caregivers or employer employee relations. You might want to remind folks to make sure that the Act provides the ADHS with the regulatory authority to act before spending a lot of time submitting comments.
Also, if you aren’t able to comment on this informal draft Rule between now and January 7, there will be additional time to comment in February and March.
P.S. The Governor signed the Proclamation that makes Proposition 203 law on Tuesday, so the 120 day implementation period will end on April 13.
Your continued efforts at transparency and to maintain trust with your constituency are apparent, and I want to express our growing confidence in your demonstrated ethic. Achieving the balance you reference in the call for comments will be no easy task, and history tells us the least vocal now (to provide constructive input) will often be the most vocal later (to criticize).
Although I have provided formal feedback on the form, I think it might serve well to address two concerns which will be taking up a great deal of communication and perhaps tying up the resources of your staff. Brief answers here on your blog may prevent considerable speculation and duplicative feedback.
The first: Regarding R9-17-307 C: The Department has apparently made no provision that allows a dispensary to receive seeds to begin and maintain cultivation. In fact, the rules specifically prohibit the acquisition of any marijuana from outside the dispensary or qualified patient system. Specific strains have demonstrated efficacy for particular medical conditions, and restricted or denied access to these studied and validated varieties may not serve the patient population well. My assumption (only) is that most dispensaries will focus on cultivation of high THC strains, rather than follow a medical evidence model to provide the best match for a given diagnosis and constellation of symptoms. If possible, ADHS should consider implementing a “seed clearing house”, or designate an approved resource for dispensaries to acquire a variety of strains. In the absence of this, it appears you are requiring the dispensary to wait for a qualified patient to provide seeds, or to break the law to acquire them.
And secondly, the method by which dispensaries will be chosen has not been clarified. Understandably, this may not yet have been decided.
My apologies for using this venue if you feel it inappropriate to raise these concerns on your blog.
I would just like to say I appreciate all the hard work your department has put in. The 2 year residency is a vital part of these rules to ensure that Arizona is benefiting not outside states.
I think the clause below is horrible and wrong. Requiring that a patient have an existing relationship with a physician for 1 year is criminal. When you walk into the ER with a medical issue you are not denied treatment because you’ve not known the doctor for a year. Why would you discriminate against certain patients and not others? A patient can walk into dozens of different pain clinics and walk out with a prescription for deadly narcotics on the spot but when it comes to a benign plant you would make them wait a year? CRIMINAL and shame on you.
A statement, initialed by the physician, that the physician:
i. Has a professional relationship with the qualifying patient that has existed for at least one year and the physician has seen or assessed the qualifying patient on at least four visits for the patient’s debilitating medical condition during the course of the professional relationship; or
Please be sure to voice you comments/suggestions on our electronic comment page.
Good afternoon Mr. Humble,
First off, thank you for your neutrality with enforcement of the people’s will when it comes to Prop 203, secondly, I commend the AZ DHS for the very professional manner to which they are handling this, and for the open, honest inclusiveness of we, the People of Arizona, as to how to properly provide a viable, natural medicine to patients, like myself.
I read about the implementation of the 1 year relationship provision that the DHS has said needs to be present in order to obtain a recommendation, which was announced today! While I do not oppose this, I do honestly suggest an exceptions provision. For example, I suffer from Spastic Diplegia Cerebral Palsy, which entails chronic muscle spasms and joint pain, caused by inflammation. This condition, and a myriad of others have been life long, and will not simply go away. I have ample documentation from numerous licensed physicians, x rays, I have had 6 major surgeries to improve mobility, lessen neuromuscular spasticity, as wel l ato improve ambulation (walking with walkers, using my wheelchair etc) Now under this regulation, I would have to wait to receive a recommendation, even though I have lived with this valid condition for the entirety of my life, yet I utilize benefits of Cannabis now immensely. I have had recommendations from physicians in my home state of California to use Cannabis as a therapeutic treatment and did provide valid medical history, all the information concerning other meds I have taken, surgeries, any hospitalizations, as well as have discussed the risk to benefit factor with the Dr. So, I do applaud this requirement, however, my point with this hopeful exception is that there are people right now with Cancer, who may have a grim prognosis, and have only say, 6 months to live, should they have to wait 1 year to get not only relief, but protection? Fact is, they cannot. I say, with no degree of frivolity, they’ve waited long enough.Please add an expedient exception process based on a stringent, case by case, documented basis. People like myself and other legitimate beneficiaries of this law would thank you greatly for implementation of such a practice.
Eric N. Franks
Patient, advocate, and active citizen in my community!
Thank you for the quick and thorough posting of the rules. AZDHS is really doing a great thing by getting the community involved in the process. At first glance, though, I did see two things that I did not like. They were 1) The requirement of a 1-year doctor-patient-relationship prior to a medical marijuana recommendation and 2) The requirement of dispensaries to self-produce 70% of their medicine.
Here is why: If a potential patient’s primary doctor will not write a recommendation (for whatever reason, whether personal beliefs or fear or federal law) and that patient needs to go elsewhere to obtain a recommendation for this natural medicine that works for them, under these current rules it is impossible for them to get their medication for another year. A cancer patient or HIV/ AIDS patient simply does not have a year to wait for symptom relief.
And secondly, regarding the 70% piece, many of the small business owners who I’ve spoken with who have interest in entering this field have expressed that they are either specifically proficient on the business side, or are particularly talented in the field of horticulture. This part of the rules makes it impossible for people to align their work with where their specialties lie. If a businessperson is great with business and not so much with gardening, s/he should have the option to forgo the entire (strenuous and demanding) cultivation side and buy wholesale. I see this portion limiting potential dispensary owners.
I’d love to see these parts amended, but so far, I commend DHS on their hard work! This is definitely a lengthy process and we appreciate what you’re doing for the state.
Thank you for your thoughts and suggestions, we appreciate it! Please be sure to comment on the rules via our electronic comment page .
Just to address the 1 year physician-patient relationship: If you read R9-17-101 16. b. the one year does not apply if the physician “assumes primary responsibility for providing management and routine care of the patient’s debilitating medical condition….” This means if you see a new physician and he/she will be seeing you in the future on a routine basis to “oversee” your debilitating medical condition, he/she can give you the recommendation. This simply prevents one from seeing a “pot-friendly doc” who will give him/her a recommendation and not see him/her for another year when he/she needs a recommendation renewed.
To all who are concerned with the one year physician provision, the draft rule language also provides a second alternative to the 1 year relationship if:
“The physician assumes primary responsibility for providing management and routine care of the patient’s debilitating medical condition after conducting a comprehensive medical history and physical examination, including a personal review of the patient’s medical record maintained by other treating physicians that may include the patient’s reaction and response to conventional medical therapies.”
Just wanted to jump in regarding the 1 year Dr patient relationship rule. I will leave a formal comment as well.
I am a caregiver for an MS patient who has been receiving care at the best facility in Phoenix for about 10 years – St. Joes/Barrows. I was informed by his PCP last week that NO Drs at St Joes will be allowed by the Catholic Church to recommend medical marijuana.
So first off DHS would inject itself into and force a change in the Dr patient relationship. DHS would destroy many such ongoing Dr/patient relationships and force an unreasonable and uncalled for delay in the benefits approved in the law with the proposed rule. Since we’re unlikely to find better Drs you would force us to “shop” for a Dr to go see 4x per year just for the recommendation and still go to Barrow for everything else. Precisely what you are trying to avoid-Drs who only give out recommendations. Since he is on disability and this unnecessary care would not likely be covered by insurance, this would be a huge extra cost for no good reason.
Requiring 4 visits per year to a single Dr is arbitrary and assumes that DHS knows better than the Dr treating a patient how often they need to be seen. I’d like to know what this number is based on and how 4 can be the right number for all the listed conditions. How many times does MS have to be diagnosed? His condition has not changed in over ten years and it will not improve, ever. MS does not go away.
In our case we see a PCP and two different neurologists, a nuro-ophthalmologist and a urologist all working as a team to treat the MS. We see none of them 4 times a year but we probably have 10 or more Dr visits per year (lots more if you count PAs which can’t make recommendations).
I’ve worked in healthcare for 20 years and I know of no such restriction on any medical professional anywhere that limits their ability to treat a patient or prescribe drugs or therapy until they have seen a patient for a year and then for 4 visits. A patient can go to a Dr on Tuesday and that Dr can cut his chest open on Wednesday and hold his heart in his hand but with your proposed rule a Dr would not be allow to recommend medical marijuana to someone for a year after seeing him.
I can’t see how this rule would ever stand-up as a “standard of care” or being reasonable since it would be totally unique and unprecedented. DHS is not supposed to re-write the law and add restrictions to limit use and availability unreasonably. Further it would add unnecessarily to medical expense in AZ, and limit a very basic America freedom-choice of doctors and how often you see them.
I am wearing two hats during this process- 1 as a hopeful, prospective dispensary owner, and 2 as a 21 year sufferer of Crohn’s Disease. While I applaud the overall regulations that came out, I hope there can be some meaningful discussion around a few areas. I will comment on the electronic form, but did not know if that was public and would like some other’s input as well…I am writing this as a patient…I feel the 1 year patient/doctor relationship is not fair, nor is it in the best interest of individuals who truly need medicinal cannabis. A lot of people have doctors with whom they have had longstanding relationships, and while patients and doctors do not always agree 100% over care, patients value these relationships with the doctors and do not want to leave them. A lot of doctors will not write recommendations for a number of reasons- from philosophical to logistical to prudence. The regulations the way they are written either require the 1 year relationship or require these patients to leave these doctors who know their conditons, history and in a lot of cases husbands, wives, children etc., and move onto another doctor who will take over the primary care of this condition in order to receive a recommendation. I do not understand how the state can require an alternate doctor to take over the primary care of a condition for someone who is quite happy with their present doctor/patient relationship…Going to another doctor for medicinal cannabis is aking to going to a seperate doctor to manage pain because a lot of doctors refse to prescribe pain meds. I think an MD who cares about their license and ability to continue practicing medicine in AZ would be quite able to decide the benefits of medicinal cannabis for a patient through an examination of the individual and possibly a review of their medical records etc. Doctors have had to screen people for years who have attempted to “fake” conditions to receive pain meds etc. without needing a year and 4 visits to do so. Possibly speak with some doctors at Pain Clinics to determine their processes/procedures for accepting new patients and prescribing opiates etc…This scenario makes a lot more sense to me than requiring a patient to transfer the primary care of whatever horrible condition they may be dealing with in order to secure a recommendation. I hope this is one area in which you reconsider the present regulations the way they are drafted. Thanks for your consideration.
I work in psychiatric clinic…I see recipients who abuse medication (already legal and lethal) that are designed to be medications…I see this 40 hours a week; if you make a psychotic mimicking substance like Marijuana in to a medication; It will be abused by the people who use it. It is shamefully good for the industry I work in; marijuana along with abused benzos and methodone guarantees that there will be mentally unhealthy people out there. My paycheck will be the same, but my recipients are more likely to be inpatient than outpatient. As for motivating the mentally ill to want to join rehabilitation programs; this will be impossible; as marijuana leads to amotivational syndrome (this is the most confirmed fact; if you doubt this please smoke some marijuana, drug free people will not notice you missing) Deinstutionalization and the push to motivate people to do something with their lives and having a purpose to do more than be a medicated zombie or to do things other than sitting at home bored and depressed will be all for nothing.
The patient-provider relationships in the draft usurp those already defined in the state.
What if a patient has a specialist that doesn’t agree with medical marijuana ? What if the doctor recommending the marijuana does not have the skill of the specialist ? Patient made to suffer, patient at risk.
What if a patient gives up decades of knowing a doctor simply to transfer to a doctor with a different philosophy ? patient made to suffer, patient at risk.
What if a previously healthy user wants to use recreationally enough to establish a relationsip and lie about a condition, and then neglects all REAL ailments in his/her body because of desire to continue receiving recreational meds ? This drives the patient to the ER and prevents ANY sort of preventative medicine in their life. Patient at risk, dollars spent, lawsuits readied.
Just leave the patient privileges where they are per state law already, that’s where the chips are going to fall anyway with the will of the people.
The current definitions in the draft for patient/doctor relationship place patients at risk of suffering needlessly in the hope of curbing a few recreational users. We have to accept diversion and abuse of opioids and benzodiazepines because of their efficacy. The same onus lies with marijuana. It’s efficacy is unparalleled where indicated. The thing is, marijuana won’t kill anyone via overdose, or make them a physical slave to a pill bottle.
Please think carefully about all of the terrible compromises that would have to be made when you place curbing recreation ABOVE patient’s rights.
The only bad thing I see about this is that some clinics and hospitals are barring their doctors from recommending medical marijuana to their patients. In rural areas this will be a problem. If you change doctors for your medical MJ script you may have to drive 60 miles away. It also forces you to sever your relationship with your doctor of many years. Then when you get sick again you jeopardize your health as your original doctor will no longer be your primary doctor, forcing you to drive a long distance to get emergency health care.
Thank you Mr. Humble, for your willingness to work with us all, and for further clarification of this issue.
“R9-17-302. Applying for a Dispensary Registration Certificate
A. Each principal officer or board member of a dispensary is an Arizona resident and has been an Arizona resident for the two years immediately preceding the date the dispensary submits a dispensary certificate application. ”
Thank you, thank you, thank you. Let’s put penalties in place for the loopholes they will use their lawyers to try and find and in a word Beautiful!
The annual patient card fees really shouldn’t exceed $100, this is in place to help terminal cancer patients, MS patients, etc. Other than that my initial response is that you all have flat out impressed me! I really like the restrictiveness to reduce fly by night recommendation being sold!
I will use the proper feedback protocols, I just couldn’t wait to tell you all we appreciate your hard work on this project!
Thank you again for your professional approach to the cause!!
As a potential dispensary owner, is there an option for an application to be approved pending inspection scheduled at a later date from the application submission?
If so can a potential dispensary secure a location without investing the money to “be operational” as required by the state, and do so only upon application approval?
This would allow for a potential dispensary to apply for a certificate and get approved pending final inspection with the state, without spending the capital required to operate prior to receiving approval.
In these guild lines I do not see to much on cultivating and the amount that a store can cultivate. How will the supply be monitored to assure that all of the dispensaries will stay open in a area ,so people can get there pursciption without having to trave to far to get them.
it seems to me that the description of the medical director (which was an unexpected requirement) is the actual description of what a pharmacist does, certainly a pharmacist can be included in the acceptable medical director definition
what is the purpose of the 30% limit that a dispensary can sell to other dispensaries? The goal is to provide the best quality, having 124 dispensaries trying to grow their own is going to limit the expertise that is out there that would provide a better quality, safer product
What are you guys talking about?
That is the exact loophole that “pot friendly docs” are going to use, except it’s going to make them tons more money, because the patient is going to be forced to have an “ongoing relationship” so the doctor can “oversee” your debilitating medical condition…!
I highly doubt any legit family practitioners are going to want to assume responsibility, as the language says…
I have already voiced my comments via the electronic comment form. Thanks guys.
Good job on program implementation thus far. However, one major cause for concern is the fact that the regulations listed below would appear to force an applicant for a dispensary registration certificate to commit financial resources to a building lease or purchase before the application would be approved.
As R9-17-107 (B) and R-9-17-302 B(5) is written, one would have to have a building space before the application would be considered “complete”.
B. “A registration packet for a dispensary is not complete until the applicant provides the Department with written notice that the dispensary is ready for an inspection by the Department.”
R9-17-302. Applying for a Dispensary Registration Certificate B(5)
“A copy of the certificate of occupancy or other documentation issued by the local jurisdiction to the applicant authorizing occupancy of the building as a dispensary and, if applicable, as the dispensary’s cultivation site;
For example: This inspection would obviously cover the building’s security system. Is it fair to force dispensary applicants to invest in installing a suitable security system before knowing that their application would be approved? I think an approach that would work would be to give a preliminary approval, based upon review of the application, building and security plans. The applicant could then proceed with confidence to secure the space and implement requirements to finalize the application.
Also, I noticed that there is no provision for the application fees to be refunded in the event an application is not approved. Does the department plan keeping these fees? Your thoughts.
With all due respect. What if the patient does not wish to transfer his care to another physician? What if the patient qualifies for medicinal cannabis but his primary care physician has political objections or fears of loss of license? This assumption of primary responsibility is not required of any other medicine or treatment option, why the discrimination against medical cannabis?
Rules are extremely important, especially when it comes to regulating medical marijuana. Thanks for sharing and I’ll make sure to pass this along to my friends.
I’m unable to respond to each of the comments that you’ll see below because of my other responsibilities here at the Department. If you want us to consider your suggestions please make sure that you use our public comment tool on the 203 website.
Also, please make sure that you read the Rule package carefully before commenting. It’s clear that many of the commenters have misunderstandings about what’s in the informal draft Rule. For example: there are 2 definitions that can apply to the doctor patient relationship- either of which would be valid. Others are confused and believe that the draft includes a requirement for a pharmacist at dispensaries- when in reality we’re asking for a (MD or DO) medical director.
Thanks… and make sure you turn in your comments to the official 203 site.
Have a nice holiday…
I know you are a busy man with many responsibilities. I know your department has put much thought into these regulations to prevent recreational smokers.
I am a “Travelling Nurse” and I see the poorest of poor patients. It is better to err on the side of the patient, instead of trying to be so restrictive that no one benefits from this law.
I see paraplegics, quads, patients with every type of illness where their nausea is so bad that they can not eat. For many of them MJ helps the patient function so that they are able to eat.
Many of the doctors I have spoken to are willing to recommend Medical MJ but the hospital or clinic to which they belong prohibits them from doing so. Some doctors are afraid they will be prosecuted or they might jeopardize losing their medical license.
You must understand that there are many cases where the patient needs to stay with their existing doctor even if that doctor cannot or will not recommend Medical MJ.
I have patients who are locked into their current doctor due to insurance requirements. If they go to another doctor they lose their coverage. I have patients who live in rural communities where there may only be one doctor. I have patients who are unable to travel or can not travel long distances.
I have patients who have established long term relationships with their doctors. Their doctor may believe Medical MJ will help their patient, but many doctors do not want to write a recommendation for a myriad of reasons.
Do not put any restrictions on a patient seeing any doctor for a Medical MJ prescription, except making sure the patient has a documented history that would warrant Medical MJ. Make it easy, not difficult, for those who are suffering.
If a Doctor chooses to be “liberal” with his or her prescriptions give the doctor a “hefty” fine, take away the doctor’s license or send the doctor to jail, but allow the poorest of the poor to see their regular doctor and concurrently see a doctor for their Medical MJ recommendation.
Also keep costs down for the poor. $150 each year for a Medcal MJ card is a lot of money for someone who has no income, or who draws a $600-$700 check for social security disability.
Having a doctor on call for the dispensary will only drive up costs for Medical MJ for the patient. A pharmacist is all that is needed. Make dispensaries safe, but do not add extra rules that will raise the price for the patient who already is struggling to survive.
Thank you Will and staff for your hard work, but remember the poor patient should always be on your mind when you are setting up these rules.
I will respond electronically as well, but I am a pharmacist. As such, I am well qualified to operate a dispensary without being overseen by a physician. (medical director)
Why require each dispensary to grow their own? Why not let there be grow sites for people who do it best.
I am a caregiver. My patient’s doctor is prevented from making a medical marijuana by his hospital. We have to see that specialist always. What are we to do?
Susan- I agree with you that a Pharmacist is more than qualified to be a medical director. The definition essentially describes a retail pharmacist. Also, how would one find an MD or DO who would want to be a medical director of a dispensary but does not want to have the ability to refer marijuana to his/her patients?
I just learned today my doctor will not prescribe me medical marijuana because the hospital to which he belongs is telling him that he can’t. I’m not changing physicians. Does that mean I can’t get nedical marijuana?
Nice article Mr. Will Humble.
Thanks a lot about the information
I appreciate your informative article. I do hope that the plight of many disabled who could not afford the annual card fee is revisited. Many are lucky to have a roof over their heads and food on their table.
This does not feel like a fair minded taxing of our poor for medical treatment. I suspect many will be forced to deal with the criminal element this was meant to eliminate.
there are tons of people who are tied to certain doctors that won’t recommend marijuana even where it is indicated. these people are unable to transfer care to another doctor. This is only one of MANY scenarios where the current suggestions bind patient’s hands and prevent them from receiving A+ healthcare in Arizona.
The current definitions of doctor/patient privilege in the draft MUST be removed completely. There is no reason (or mandate) for paring down this definition that already exists legally. We go to various doctors for various things. If we can benefit from marijuana’s efficacy, we need the right to be able to see a marijuana-only doctor IN ADDITION TO our other doctors. None of this monolithic stuff, monolithic doesn’t work in medicine.
As you can see by the comments above, these provisions must NOT be imposed, and must be wholly excised from the draft.
It seems to me, too, that the description of a medical director is the definition of a pharmacist. The number pharmacies dictating the number of dispensaries illustrates the strong connection between the two. It is only natural that a pharmacist should be the one to oversee the inventory, control and dispensing. At te very least be included in the definition of a medical director
I’m in the same predicament as many others. Well, my doctor belongs to a major clinic with many branch locations. She tells me that clinic rules prohibit her from recommending medical marijuana. I have a 3 year case history resulting from a terrible accident and I’m in constant pain. I can’t afford the costs of seeing another doctor. I don’t think my insurance would allow me to see anyone else. Please, please allow me to stay with my current doctor for most of my care andallow me to see another doctor annually for a medical marijuana recommendation. Thank you very much.
To Billy- If the web predictions are correct there will be a couple thousand applications turned in. ASDH has 90 days to deny or approve an application. This means that thousands of store fronts and warehouses will be tied up in some form of lease agreement with potential dispensary operators and growers. I would not want to be in the market to open a restaurant or coffee shop during this period. Also, 90 percent of the business fronts will end up with no renters after the decision. While it would be difficult for dispensary owners to put up the money to hold a building, it would also put undo stress on the rest of the local business world. We would like to see Prop 203 help local businesses not put on an extra burden upon them in these tough times.
My doctor also says he can’t recommend medical marijuana due to his clinic’s policies. I can’t afford to change doctors due to transportaion costs, due to losing my medical coverage, due to my doctor’s expertise. Don’t make me see another doctor as my primary physician.
It is clear to me from the replies on this blog that the condition of assuming full primary responsibility for the patient is not fair nor ethical. Requiring a patient to give up his doctor in order to receive a cannabis recommendation is like holding them hostage.
Please reconsider this provision in the new law.
to Chad- there is NO WAY there will be as many apps as previously thought since it’s quite apparent that DHS is catering to big business..there is a requirement that the applicant have their occupancy certs- meaning the building must be built out- not just secured, but the dispensary and grow op must be built with no guarantee of them ever opening! this needs to be removed!!!
I see alot of comments that agree with my thought more thought and answers to applicants to Dispenceries, One I have not seen is it the dispensery going to be City or County orintated in this process or are the people applying all going to be in Phoenix or Tucson. There is no mention on the application or rules on how many in each area of Arizona.
I am a caregiver for a severely disabled elderly woman who wants to get medical marijuana. I probably don’t mind the fingerprints, but the fees are outrageous. Plus I have to worry that I’ll be arrested even though I will only be delivering it to my patient. If I don’t get the card she’ll have to have it delivered by some dispensary. Also her doctor is also staff of one of those clinics that has outlawed recommendations by their doctors. So I see a lot of problems with what you’ve drafted. Allow my patient to keep her doctor and allow her to see a marijuana doctor maybe annually for a recommendation.
I do not get the medical Director position. What is the pupose if the Dept of Health is requiring all the safe guards which is good I do not see why from a business stand point for this. I think the Dept of Health is making this to political and not letting the small business person have a chance. I had high hopes of applying for this but it sounds like only Doctors or Pharmicist stand a chance. The doctor patient relationship is at the doctors office not the dispencery. You do not require a doctor to oversee a pharmicist. What good does this postion do it serves no purpose other than to make doctors more money and add hands into a business.
The “Rules” making process unfolding and all subjects surrounding this new law is very complex. Time line is in place and the tasks at hand in providing the “Rules” by certain dates are varied and many. The State, County and Local Governments are the big players. Dispencery owner/operators as a rule are money motivated self serving opportunists with limited experience with most of the responsibility to fund the government with the sales and easily intimidated by state,local and federal governments. The least powerful with the most to burden is the Patient/Caregiver, the patient jumps through all the hoops and pays all the bills. The Caregiver works for free and still pays the government and must maintain license. I am eager to see how all this is gonna be addressed in the coming weeks and knowing it’s going to be defined.