So far, we’ve received well over 1,300 comments on the Informal Draft Rules that we posted December 17.  Our first comment period ends today.  We’ll be reviewing the comments and revising our initial draft over the next couple of weeks.  We’ll be releasing new draft rules for public comment on Monday, January 31, kicking off our next comment period (which will go through February 18).  After that, we’ll craft the final Rules and publish the finished package on March 28.

The following issues are generating the most comments:

  • The definition/requirements for patient-physician relationship;
  • Adding additional medical conditions including mental illness, PTSD, fibromyalgia, depression, etc.;
  • The fee structure (especially for patients with limited income);
  • The 25 mile limit for patient/caregiver cultivation (which is actually in the Initiative, not the rules);
  • The requirement that dispensaries cultivate 70% of their own product;
  • The processes for approving dispensary registration certificate;
  • The requirement that dispensaries have a medical director;
  • The qualifications for medical directors (e.g. allow other medical professionals including a pharmacist, naturopathic physician, homeopathic physician, family nurse practitioner, physician assistant, or registered nurse to be the medical director);
  • The 2 year residency requirement for dispensary applicants; and
  • The requirement that cultivation facilities be licensed in association with a dispensary (which is actually in the Initiative).

Overall, the comments so far have been constructive and many have been positive and support much of the overall language in informal draft rules.  All the comments on the informal draft rule are part of the public record and will be available for review on our hub 203 website (with personal identifiers removed) by next Wednesday.