Guest Opinion: A call to “increase patient access now by assisting currently operating vertically-integrated med dispensaries to stay in business.”
February’s Massachusetts Cannabis Control Commission hearing on the state’s Medical Use of Marijuana Program was a watershed event. The agency and industry face many issues, but the troubles before patients and med operators are some of the most pressing, and the action or inaction the body takes in the upcoming months will dictate med accessibility for vulnerable people statewide for years to come.
And so in addition to our wall-to-wall coverage of the consequential hearing, we are also running some of the poignant, heartfelt, and informed words of those who offered input. The following is the testimony of Ellen Andrew-Kasper of Alternative Compassion Services in Hull and Bridgewater. Though in agreement with most advocates on many points, she does not believe that removing the vertical integration requirement for medical operators is a silver-bullet solution to the problems afoot. -TJM Editors
I am an RN and veteran interested in the benefits of using cannabis for a variety of physical and mental health challenges and have been involved in assisting to startup and do outreach for a small, locally owned and operated medical dispensary that opened in 2017. We were among the early medical dispensaries that helped to safely and compliantly usher cannabis into Massachusetts and have witnessed many changes in the industry since. A recent article in MJBiz stated that the total number of MMJ pts decreases by roughly one-third after recreational sales are launched in states.
That certainly seems to have been the case here in Massachusetts. We are committed to serving medical patients but with the plethora of Adult Use dispensaries and the flood of cannabis on the market it is difficult to compete with a Med license alone. In order to continue to serve our patients we’ve been forced to spend time and money campaigning in two towns to overturn recreational cannabis bans to allow us to add Adult Use sales to our Medical dispensaries.
There is much publicity around the number of med dispensaries closing resulting in decreased patient access to tax free medicine and other pt benefits. The closing of med dispensaries not only impacts patients but the livelihoods of dedicated employees, many with families to support. The sole remedy for this lack of medical dispensaries has focused on eliminating the vertical integration requirement for a med license. The idea for vertical integration was that it would provide patients and dispensary staff assurance of known, quality products. We can speak to the quality of our own products and educate about them. Sourcing third-party products for medical essentially erases that product distinction.
Being involved in opening a small medical dispensary that was required to invest millions of dollars to vertically integrate and has monthly operating costs for grow, kitchen, extraction, packaging, manufacturing staff, scrubs, PPE, HVAC, electricity, water, plant food, etc, it seems quite unfair to allow easy, much less expensive access to a medical license. In addition it does nothing to increase patient access now by assisting currently operating vertically integrated med dispensaries to stay in business.
People can improve patient access by supporting existing medical dispensaries that are trying to operate compliantly and honestly, and that are committed to supplying safe, quality cannabis to patients. In their part, patient advocacy organizations can partner with medical dispensaries that offer delivery services, advocate for safe products with accurate, honest THC levels, and advocate for state-state reciprocity for med patients. And the CCC to do the following:
- Adjust Inequity in medical/adult-use license fees. (An RMD pays $50,000/yr for a medical vertically integrated location and also $50,000/yr for a small medical retail-only store. An adult-use license is $10,000/yr.)
- If vertical integration is eliminated, reimburse Vertically Integrated businesses for overpaying for years. We’d love to be reimbursed $20,000 x6 years and $40,000 x3 years for increased license fees. The rec program should be able to support the medical program.
- Automatic ability to add adult-use to a medical facility where available with an expedited process for compliant companies in business for years.
- Decrease cost of employee registration $500/$115. Credit fees back for employees who leave within 90 days.
- Eliminate separate badges for each license within the same company. (Staff in the same company may require two medical and two adult-use ($1500) just for badges and added $500 or each background check.
- Consider employees owning and being responsible for their own badges.
- Eliminate RVT training as dispensaries are responsible for training their staff.
- Eliminate costly redundancies that cause delays in licensing and renewals. For example-fingerprints that are submitted once should not have to be resubmitted ever again.
- Reciprocity for Medical Patients with other states. Bill S1082 addresses this.
- Ensuring compliance with use of sales, promotions, loyalty programs intended to benefit patients going to medical dispensaries and not for use in recreational dispensaries.
- License caps for areas already saturated.
- If vertical integration is eliminated consider having one license only. Consumers decide whether to access adult-use or medical.
- Ensure public safety with honest testing and potency labelling. Remediated products should be labelled as such.
- Recall contaminated products. As a compliant company with patient safety in mind, it’s expensive to maintain a clean facility and impossible to compete with companies putting out contaminated, falsely labelled products.
