“We need to urgently address these hurdles for both patients and businesses to prevent the program from imploding on itself.”
This week’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 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 complete testimony of Lizz Palmer, a longtime patient who is also the marketing director for Bay State Extracts.
Thank you for allowing those of us directly involved in the Massachusetts Medical Marijuana Program the ability to speak on our experiences today. Please allow me to introduce myself: my name is Lizz Palmer and I have been a patient since those with chronic migraine have been allowed to get a doctor’s recommendation for cannabis. My diagnoses also include epilepsy and fibromyalgia. In addition, I have been a member of the MA cannabis industry since November of 2018.
Like many here today, the lack of evolution of the Massachusetts Medical Marijuana program is not only creating a detrimental experience for patients but also killing off the very businesses in which we need to access our medicine. With the long list of improvements that need to be made to serve patients, I struggled with how to frame all of the issues in a single document in such a manner that could explain the pain points on how the current program is failing for both patients and the businesses that serve them.
The best approach I could possibly come up with is taking you through a typical patient-experience of securing my medicine while giving the Commission insight on the atrocious obstacles for dispensaries to keep running.
Only until very recently, I have lived in the south-central part of Massachusetts for most of my life. In order to secure the right amount of medicine and dosage in that area of the Commonwealth, I would have to travel over 102 miles in total between 3 dispensaries and my home. It has become increasingly difficult to find products that are only found on medical menus in one location: RSO, high-dose/ sugar-free edibles and minor-cannabinoid dominant products that exceed the THC limits of the recreational menus. Therefore, 102 miles of driving it is.
Also – delivery for patients continues to be non-existent in most of the state with the one exception of a Worcester medical dispensary that required a $150 minimum delivery charge.
The journey I am about to take you through has not changed since medical dispensaries opened in the Commonwealth.
Before walking into a dispensary, I often login to MassCIP to check my extended allotment – I am allowed to purchase 12 ounces in 60 days versus a recreational customer who can purchase 60 ounces of product within 60 days (1 ounce limit per day!). The portal has remained the same, non-ADA friendly website since the handover from the DPH to the CCC. Most elderly patients – like my father – cannot read the data due to the awful layout and small print. I also have had too many experiences of going to get my medicine for the CCC patient portal to be down – meaning I could not secure my medicine that day and would go without.
After checking my allotment and to make sure the system is working to purchase, I check into the dispensary which takes over 5 minutes per 1 patient. The barcode on the patient ID does nothing – a terrible waste of money for the CCC – and the admissions desk has to manually input multiple lines of personal information to get me checked in. While this check-in process takes place, 5 recreational customers are easily able to get processed if there is another admissions/security person at the front of the desk – otherwise I hold up the line for both patients and recreational customers. Already, checking in a patient costs the dispensary more money than 5x the amount of payroll time to check in a recreational customer.
While picking up my pre-ordered product, the budtender (or sales associate) must be badged for dispensing medical – an extra cost to the business. When walking up to the counter, it is rare for a medical dispensary to offer seating or low counters for those with assistive devices or in pain. Since serving patients takes longer, I have often found myself leaning against walls during days of intolerable pain. I have spoken with many people who have given up on going to medical dispensaries due to the lack of accommodations for those with disabilities while we wait longer than recreational customers to get our medicine. Yes – many dispensaries meet the bare minimum – but is the bare minimum enough to make your patients comfortable to pick up their medicine?
The check-out process takes 3-5x longer than a single recreational customer due to the manual inputs, redundancies and allotment checks that need to take place per CCC regulations. Now a single medical patient is costing as much to process as 7-10 recreational customers. If I request a product that needs to be moved from the recreational inventory to the medical inventory, that’s an extra 10-20 minutes of wait time – not to mention the cost of METRC tags, personnel moving the product and juggling the computer inventory. In addition to the disproportionate fees charged to a medical license over a recreational business it is no wonder why we are losing medical dispensaries at a higher rate than their recreational counter-parts.
By the time I am done picking up my medication at one dispensary, I have to repeat this process at 2 more other dispensaries as well on average. The CCC has created these conditions in which patients no longer wish to be a part of the program just from the purchasing process alone. It is no wonder why so many are no longer renewing their patient registrations.
The Massachusetts Medical Marijuana program is the reason why our 1 billion dollar recreational market exists today – we fought for our right to this medicine to now only be treated like second-class, unimportant citizens because the CCC set up our program to fail through disproportionate fees, red-tape and only see the greed from the 20% taxation recreational customers pay. We are losing our ability to access medicine due to business closures that CCC only has themselves to blame for.
We need to urgently address these hurdles for both patients and businesses to prevent the program from imploding on itself.
Immediate relief can come to patients by simplifying our allotment process, expanding our allotments, changing how concentrates/topicals and infused flower are counted towards our allotment system.
Immediate relief can come to businesses by lowering their medical licensing fees, the Vertical Integration Requirement, eliminating multiple badges for serving both patients and customers and eliminating some of the METRC red-tape in transferring products.
By no means does this mean that will solve it all.
Long-term solutions are needed for the years of neglect of the medical program in order for it to run that is both profitable for businesses and ease the use of access for patients. The patient portal needs to be overhauled to be more accessible and easier to understand: barcodes on IDs need to be of functional use, eliminate as much manual-data input as possible, clear expiration dates of doctors versus state registration, and set rules to allow patients to access their medicine no matter their physical disability. This includes opening up delivery services to public housing, senior living centers and making it profitable for businesses to deliver cannabis medication. Business could easily gain more patients by becoming a reciprocal program such as Maine or in D.C. where temporary medicine of 2 oz or more per day is allowed to be dispensed.
We are only in this crisis because of the rules and lack of patient-experience understanding by the CCC. You are the only ones who can fix this, otherwise we patients may continue to either make long-haul drives to reciprocal states or drop from the program altogether. It is your job to fix this problem, and you cannot brush patient needs to the side anymore.
Either way – I refuse to pay 20% taxation on my medicine. Remember – this is our medicine, not a recreational product.
Thank you for your time.
Best Regards,
Elizabeth “Lizz” Palmer
