 Michelle Powell's Office of Legislative Counsel. We're talking about S54. So what I passed out for you is two documents You'll have a hard copy of the chapter 86 and title 18 Which is for your medical marijuana program, and I just wanted you to have the entirety of the chapter so you have this because The the last discussion I was kind of giving you the broad overview and talking about the concepts They are kind of kind of trying to orient you but and then There was interest in kind of having a side-by-side of the what's in 54 and what's in current law that would have been 50 pages long, and I don't know necessarily that helpful because it's not late And so what I what I've done is figure we have a copy of this. I created a side-by-side Suscript with What I tried to think about were kind of a lot of the policy issues and the policy differences are things that people tend to key in on You know the language is different that the the idea behind this just to refresh your based memory is that so in 54 because it Sets up a new commercial cannabis regulatory system for licensing folks to Everything from cultivate to sell Cannabis Set up this new cannabis control board the medical program would continue to operate under department public safety until January 1st of 2021 and then that program and I would anticipate Also in future legislation there would be a proposal to move the positions Over as well under the board, but because they're only doing positions and funding for FY 20 in this it isn't in S 54, but the idea is that just once the board is up and running Because they're going to be adopting the medical rules in accordance with this new framework That then the programs would shift over as well So what you have with regard to the statutory provisions that are in here in 54 is it is on that date When the program shift over it repeals this chapter 86 and these new Chapters for that regulate the the registry and the dispensary kick in and they are you know Substantially scaled down from what you have now in chapter 86 And so it just kind of provides the framework for it but it moves a lot of it and the development of Procedures and things like that to the board to be to do it to kind of hand-in-hand how they're doing the commercial market Because thinking about and so the reason why and I just to address one issue that comes up for folks a lot as well Why not get the commercial market up and running? Don't do anything with the medical now and you can do that from later point in time But the issue is that if you're not looking at the system as a whole What you're going to wind up with is you're going to wind up with a commercial licensees that are going to be operating under one System and the medical that's operating under a different system and then it comes to if you think about the dispensaries or the registry or stuff if If they are under certain types of restrictions that don't exist in the commercial market the Senate had wanted to protect The registry and the and they want to keep having medical dispensaries Exist in a world where there are commercial sales as well. And so they're so they wanted to Open questions for this committee is whether it makes sense to have one board and one system for what is in effect a medical marijuana system and Versus a tax and regulations as you Have reminded us before we have had a medical system for 14 years under DPS and there's So that's an open question for us as to whether or not to include Medical marijuana under the cannabis board Appreciate what the Senate wants to do and what What the people across the hall made one-to-one but as the This committee has made no decision one way or another and we're not taking it as a beta-complete Nope, I'm just trying to explain the reasoning for how it's structured as to date So Jude, I'll just say so the the new thing that's on S 54 under my name is not from me Okay, so I'm just gonna I'm just gonna talk a little bit about what we have The side-by-side Documents you have a side-by-side and then you have a copy online. Yeah So Sure and I actually I want you to to let me know what's the best way for you to move through all of this I'm gonna bring up actually on This is excerpted language from 54, so if I can just start moving through the The the side-by-side so the first issue and we talked a little bit about it on The last time I was in here was about the in the definition section and you haven't I don't know why This is so tiny I'm here. Sorry. I know I sent it to the copy room and Into that way so but if you look at the definition section that you have currently so so on your in current law And you look at section 44 72 in the definition section and so right now The way we were talking about the other day is that so for someone to apply to be on the registry they have to have a debilitating medical condition and They would go to their health care provider And that health care provider could if they choose to but they're not required to sign a medical verification form Attesting to the fact that their patient has one of these medical conditions there is a Requirement in the current law that there has to be a bonafide health care professional patient Relationship which is basically in a relationship of at least three months Duration and you'll see the language that's there in the existing law in section 44 72 Of the bonafide health care professional patient relationship that is not in s54 So there is a requirement that in 54 that the patient have a health care provider and the health care provider Definition is the same in both places the health care provider would have to sign the medical verification form Attesting to the fact that the person and then we talked about this a little bit the last time the definition in current law is is debilitating medical condition and It lists what that debilitating medical condition means That's subdivision four in section 44 72 under the current law The definition is the exact same in 54, but they refer to it as a qualifying medical condition So So while while while the language is the same What the actual definitions are you take out the words debilitating and that changes legislative intent now That is what we want to do fine, but rest me the fact that the existing definitions are the same Does not mean the future decisions will be the same when you take out the word That's what the Will of the committee is that's what the will of the committee is but rest assured That is a significant change So what is qualifying defined as like are we defining that here? Do we have it's just the term analogy if you look in the way that it has for So what I have up on the screen is from 54 it just it's just the term It's just the term that's used the definition is identical. Okay, so it just says Qualifying, you know a person who has a qualifying medical condition may apply to the registry And then and then the existing law says a person who has a debilitating medical condition. So it's just it's just So those are the two of what I would say the primary differences with regard to the definition section So next box down. Is it okay? Just to kind of just go down the chart. Okay so The in current law the language is very prescriptive about what Informations contained in the application the merit medical verification form and the process for for confirmation of the information So if you look at section 44 73 So it's like on pages 4 and 5 of your chapter handout You'll see that it goes through and it specifies in detail, you know DPS has developed the medical verification form the form has to include a cover sheet that includes Information, you know the following information it has to include a verification, you know And it goes through in a lot of detail about what everything's supposed to look like and how they go about all the different steps for that in contrast in 54 54 directs the board to establish an application process through rulemaking and Directs them to create a medical verification form an application form But it doesn't go through and it isn't prescriptive in the same way about how they do that But they adopt that through the process of rulemaking So maybe this will not be a question for you, but we'll be a question House government operations or others We have a system that is worth We have forms that have been done Why not go with what there is So that will be what's that what's the purpose of reinventing the wheels? So that As you're taking John as you're taking questions So the next one I just know that there is a requirement in current law the DPS act on the application within night within 30 days There isn't anything specifically in 54 with regard to that There's requirements around that the board being established the procedure for applications and and all of that So I think it's contained within how they would do that But there's not a directive the statutory directive in there for them to to do it within 30 months within 30 days There's also a requirement that there's a Under current law that there's a revert view board for purposes of making recommendations to the general assembly and hearing appeals for registry denials and The S54 sets up a different process for appeals in Which is that the board so? Somebody could appeal a decision within 30 days To the executive director who then assigns the case to an appellate officer It sets forth the basis for review of the decision and then beyond that There's a right to appeal the decision of the appellate officer to the Vermont Supreme Court And so that's something that is standard currently in Title three with regard to a lot of agencies follow that procedure and have that procedure And so this would be a standard procedure of the board for all of their appeals of their decisions And so it would follow that Pardon They're going to be an independent executive agency So moving on to caregivers so current law Provides that a person can apply to be a registered patients caregiver and they would be able to possess cannabis Or go to a dispensary on behalf of a patient or to grow a cannabis for that patient under current law an Applicant to be a caregiver has to submit fingerprints to DPS and have the print supported criminal background check and DPS is is allowed to deny that person a caregiver registration Based on their criminal history record disqualifying crimes include drug-related fences violent felonies and a conviction for abuse of a vulnerable adult There are not requirements for criminal background checks for caregivers under S 54 There's no background checks. Nope. Nope No, but again, it's the this would exist where anyone can possess Or purchase or anybody I guess anybody can possess now, but Don't use Medical Why why have to me why have to separate why why why you have a medical system? I mean, that's I mean If it's not going to be a separate system And there's I mean This will be it. This is an amp. This isn't an question for the committee in terms of for the committee to discuss what is the What's the value What's the purpose so Policy question obviously not for me, but I would just say that there is in the language that I went over last time I was here in 54 there's the discussion about what of what advantages there are for Patience in terms of possession limits and being able to access a accessory and then in 54 There's the specific language about what services and products dispensaries can provide that are not permitted under the commercial system Okay, so So still on caregivers Under current law, there's a one-to-one ratio patient caregiver except for folks who are on their registry who are under 18 may have Two caregivers and that is the same in 54 Moving on to fees. There's an applicant a $50 application fee and an annual renewal fee for $50 for patients and for caregivers in S54 there is the The ability to collect a fee established, but the board is to come back to the General Assembly next January With a proposal for all the various fees that are contained in 54 because there are a number of them throughout the system with regard to all the various different types of licenses and so They're going to be looking at those and then coming back to the General Assembly for further recommendation No to the General Assembly Currently patient and caregivers are provided with registry identification cards and that's the same So we've already talked a little bit around around possession Currently patients can cultivate up to two mature seven immature cannabis plants and they can possess up to two ounces Those separate and apart from those plants The cultivation limits stay the same for patients under 54 the Possession limit goes from two to three ounces and then there's the additional language that I discussed last time where address the S54 copies the language that was passed last year in each 511 with regard to what What do you do with the cannabis that's harvested from your plants once your plants are mature and you harvest it You're allowed to keep that cannabis that's called that that you harvest it as long as you keep it And on the property where the where the plants were cultivated So that mirrors current law with regard to the general public, but that was not because the medical Chapter wasn't amended at all last year and 511 that that wasn't those two weren't true about How many ounces in the What we passed last year They can have up to one ounce They can have two mature and four immature plants, but anything they harvest off their plants They can keep as long as they keep it with their plants and that does not count to their one ounce And there's no limit to what you can harvest off your own plants And the tax and whatever the number is and the tax and regulations proposal is the number of Ounces Possessed as an adult does that change from the one ounce? No, so a Question for government operations, which has done nothing but around medical marijuana What's the rationale for going on two to three? Why why there needs to be an increase in that get the thing about storage If you're growing outside probably Since we have about like a two-month growing period, but if you have an indoor operation I think you can have You know a two or three harvest a year, but you would want to talk to somebody from ag or the dispensaries about that Shane you put your life in your head Shane can you spell your name or actually write it down and give you because we have you stand-ins today, okay? Shane Lin gently about a dispensary executive director So the canvas plant. Yes. You harvest it but it's dead basically, you know, it's annual So it's one time in the fall if you're growing outdoors if you are indoors you can have Upwards of probably five to six harvest cycles within a year, but there would be different plants So the plant itself if I got one plant I can have a stick one time And then you have to start over With a different scene And I would just When you say like what is like asking government operations? What is the reason from going from two to three? That's All part of the Senate proposal. So they haven't they have not done So we have taken a very light time For me This is the section that you are asking us yes or our Recommendation, so it's not like we're saying what you did house government operations. We disagree with it's might be This is what as you are amending the good work that the Senate did we suggest that you Clear respect So no changes to the non-medical adult use possession or anything like that the only the change for medical in 54 is going from two to three ounces and adding the Clarity around what happens when you harvest your plants Next box just a few little random things so Patients have to designate one particular Dispensary that they will use they're not allowed to go to and to any or all of them they have to designate one with EPS They have to make an appointment in order to go they can't just go whenever they want And they have to transport cannabis in a locked container None of those provisions are in 54 I will also just mention that Under 511 People who are not patients don't have to transport in a lock container Yes 30 hours No, this is for patients One caregiver per patient. Yes. Did that stay in say the same? So does that mean that If they are transporting Mm-hmm I'm sorry just mean they don't have to do it They don't have to do it in a locked box You need to have it in your lock glove box or your trunk. Oh Under current law, okay Would that so That's what that was that's part of the legalization law the legalization law, right? I mean it doesn't I mean I get But you could have it in your back I could have it in my purse I could have it I could have it anywhere I want but Patients because they're still operating under the medical and 511 didn't amend the medical So I can have it in my backpack, but a patient can only have it in a locked container So I just point that out Would not make sense to say, okay Just say you're a regular person and not a patient and making care of me So So moving on to the next one So current law has requirements for secure database for records of patients and caregivers accessible only by DPS They have to maintain a separate electronic database for law enforcement personnel to access 24 hours a day The there isn't any provision about that in 54 They do have a provision that individual names and identifying information about patients and caregivers are exempt from from public records law and copying but there is not the same kind of Close system database, but I don't know that that necessarily Translates to anything different between those two, but there is not something that requires a a Database for 24 7 access by law enforcement Again That sort of thing I would say when you thinking about was created at a time when it was still illegal for everybody So if you came across a law enforcement officer came across someone Who had was in possession of some some cannabis it was illegal unless you could prove that you were a medical patient Yes Right, that's what I that's right. So right now the difference is the difference is between a Regular person and somebody who's on the on the registry would be that The person who's on the registry can have three additional immature plants and they can have one additional ounce than I could So but but what I'm just saying is that when you're thinking about a lot of these things They were created in a moment when cannabis was Illegal for everybody unless you had an exception here So in terms of law enforcement being able to check a 24-hour database It would be that somebody says well they caught me with some cannabis and I say what I'm a patient But I don't have my card on me. They would be checking that Now it's a tick, you know, it's if I was publicly consuming it would be they would write me a ticket But it wouldn't be illegal for me to be in possession of that cannabis unless I was over my ounce But if we are System Which is called which is marijuana for symptom relief or medical marijuana and we're treating this as a way of addressing Qualifying or debilitating disease may be rather than this special kind of language around Around names, but isn't there in terms of the medical world On privacy protections and why should this it means so my question would be should this be any different or With the medical community freak out or I mean, you know, we're looking at the reason why these are not Subject to you know, but they're private is because this is a medical Why not use that language And this may be No, it's not and there is some specifically with regard to the patient information But because it's all exempt is the way it is on there But you can certainly add some language into 54 around around the hippostock So also around access to data in the registry So in response to a person's specific or property specific inquiry by law enforcement DPS can verify the identities of a property address or a patient So if somebody's concerned about that their neighbor has seven immature plants instead of four immature plants and And they drop a dime then DPS can confirm to the law enforcement officer that calls that that yes That person's on the registry and that's the same in 54 bottom of the page Current law establishes a marijuana for symptom relief oversight committee for making recommendations to the general assembly. There is no Parallel to that in 54 because there is this new board that is Directed to be doing that regularly So next page Currently dispensaries are limited in how much cannabis they can possess based on the number of plant patients who designate that dispensary and so the formula is for each patient that is designated dispensary the Dispensary can have two mature seven immature and four ounces per patient And so that's their cap in 54. There are no statutory limitations Based on cultivation, it's going to be determined by the board as the board is establishing tiers for the different types of licenses And so if a if a dispensary You know Is going to based on their license? They may be in certain categories based on their cultivation size But that's going to be something that's going to be developing by role Patients do not have to designate a Dispensary I mean that was there exactly and then how are we able to designate defines If we're taking away the designation then it doesn't make sense to Dispensary under current laws required to have a sliding scale the system that takes into account patient's ability to pay and In s54 requires the board to adopt rules regarding We're back So dispensaries are currently required to have a sliding fee scales Soliding scale fee system that takes into account register patient's ability to pay and under 54 requires the board to adopt rules regarding pricing guidelines for the goal of ensuring cannabis and cannabis products are sufficiently affordable to patients Think about having some So under current law Requires a biennial audit for dispensaries There's not such a requirement in the staff trailing which is 54 But it requires the board to adopt rules regarding record-keeping banking and financial transactions For Is this for just medical? Oh, no you have to for the other ones as well. Yeah So so is this language for the manager trying to is this language for future any kind at any Store that is distributing Yes, but it also there's a this is also required for dispensaries Yeah This is very important There's some I don't have it in here yet, but commerce made some recommendations to government operations on the financial transactions in the banking So so Currently dispensaries are required to label cannabis as follows. They have to identify a particular strain They have to identify the amount of THC in each single dose of an edible or Product and they have to contain a statement to the effect of the state does not attest to the medicinal value of canvas In 54, there's a lot more with regard to labeling There has to be there's requirements that cannabis is clearly identifiable with a standard symbol Indicating that is cannabis so the idea that the board's gonna have adopt a symbol that basically everything at any product Whether it's being sold through dispensaries or through the retail is gonna contain the symbol They have to label the with the potency of the cannabis by the amount of THC and CBD and milligrams total There has to be an appropriate warnings concerning the potential negative consequences of consuming cannabis and the need to keep the product away from Persons under 21 years of age So that's for cannabis, and then they have separate ones for cannabis products So for cannabis products requirement that they have to be using the standard symbol They have to label with the potency represented by the amount of THC and CBD and milligrams total and per serving They have to list the length of time on the label that it typically takes for a product to take effect and The appropriate warning is concerning potential negative consequences of consuming cannabis and the need to keep it away from under 21 Yes, there's medical is available to people under 21 So There are there is something I mean, so I'm not quite sure how we fit in that appropriate me There may need to be different kinds of warnings or a different type of things Available it because under current law medicinal marijuana is available to youth youth who have cancer youth who have Epilepsy and stuff like that. So If we believe in that to then have a warning going we're giving it to your kid because your kid This is really Charles Webb is really effective or epilepsy And then have a boop see not supposed to warning not under 21 We did take test the one For the record for the record represent a John Gannon promoting to Detect testimony about an adult patient Giving is medical marijuana to his son and daughter And his son sold it that's cool. So just That may be one reason to warn Most patients are above the age of 21 There's only a small group that are under the age of 21 and Shane can probably provide better testimony He's a wonderful person, but I would be looking to the state agency that has all the registered Because Shane may be the dispensary magnet with two There are five, but thank you, that's a good I never thought of that All right, so next page is Current under current law There is no requirement for testing Cannabis or cannabis products for contaminants and potency for quality assurance and control and that is something that is required under S54 So the board's adopting rules that'll build out I'm with those procedures and standards for testing with me I So so that's part of what the board will be developing rules They were the way that it's contemplated is that there in terms of compliance testing the state would be doing that and They would probably the board is to come back to the General Assembly with a build out for a year for the second And third fiscal year with how they're going to have positions or or or work with other agencies I would imagine they're going to be looking to be utilizing the services of the ag lab and there's language that government operations is adding That would allow the ag lab to possess cannabis and cannabis products for the purpose of Testing those products the way that they currently have the authority to do that with hemp And so the board would be able to use the ag lab for compliance testing the way that like DPS might use the ag lab for compliance testing And so that is so the compliance testing different from the dispensaries kind of testing their own for Purposes of determining how they're going to be labeling That makes sense Also under 54 That is not under current law is that it requires the board to adopt restrictions on the use of pesticides that are injurious to human Health and establish standards for both indoor and outdoor cultivation of cannabis including environmental protection requirements For adopting No, it would everything will be regulated by the by the cannabis control board Yep, they're gonna either be and again, it's the the because at the beginning It's just the rulemaking and setting everything up But they are supposed to come back with a proposal for the implementation of how they're going to be doing compliance and law enforcement around this so it may be that they have Recommend that they are partnering with ag to do with certain plant inspectors They're in the agency of agriculture or maybe they want to look to transfer positions over or maybe they want to create their Own positions within the control board But that's one of the things we're supposed to be looking at is come is coming up with a proposal For the for the year two and three build out for inspections There's requirements and for the rulemaking that they be that the board be collaborating with other state agencies Parties in the rulemaking process where there may be expert some expertise in existing state government. So when you're talking about Let's say on pesticides, right? They're probably not going to reinvent the wheel They're going to be working with the agency of agriculture food and markets with regard to what you know looking at well What pesticides are currently banned if they're going to be in certain consumable products? What should they what should be allowable? They may be looking at copying rules and applying those and adopting those for cultivators Under the commercial system and for dispensaries And so they'll be working with other people. There is an advisory board. That's part of the government operations draft there's an they are required to establish an advisory board and There are people that would be represented on the advisory board in public health and plant science and various things like that so next currently There are only five Licenses available for dispensaries that statutory Licensees may serve patients at two locations and have a separate location for cultivation There's no specified number of licenses in 54. That's numbers to be determined by the board So those are a cannabis established licensed cannabis establishments as opposed to a licensed Dispensary and then for a licensed cannabis establishment. There's five types of licenses There's cultivator product manufacturer wholesaler testing lab and retailer So if you're talking about point-of-service and being able to go and buy a product, it would be a licensed License cannabis retailer to purchase Cannabis product because I and because I don't have a medical condition right But if I have a medical condition The name the establishment that I would be the dispensary dispensary. Yep So will they always be separate or is there Do you provide in this law the opportunity for a candidate a licensed cannabis retailer and a licensed dispensary to be in the same building? They so you could have a dispensary owner who then obtains one they're allowed to get one retail license and If they there's language in 54 that specifies that if they're if they are going to be Co-located that the board or that the board adopt rules for ensuring patient confidentiality and Access to products and some privacy so that they're so that they are actually in the same facility That they're that the patients need to be addressed So Moving on so current law requires every applicant owner principal financier an employee to submit to unsupported criminal background checks So if you're gonna be an owner or you're gonna be associated with a dispensary or you're gonna work at a dispensary you have to get your record check That's the same under S54 Current law requires DPS to adopt rules to determine whether a person should be denied Either a license or participation as an employee or On the board of a dispensary because of their criminal history record indicates that the person's association with dispensary would pose a demonstrable threat to public safety And the rules should consider whether a person who has been who has a conviction Has been rehabilitated The standard in 54 is the board is to adopt rules for determining whether a person should be denied A card because their criminal history record Based on factors that demonstrate whether the applicant presently poses a threat to public safety or the proper functioning of the regulated market under the current system Folks who have a conviction or a pending charge for a drug related Offense or a violent felony are not able to be either associated in any way with a dispensary And under 54 non-violent drug offenses shall not automatically disqualify And they're not there's nothing in the statutory language in 54 that says you're automatically out It requires the board to adopt a rule system on Determining how they make this assessment around whether or not the person Presently poses a threat to public safety or the proper functioning of a regulated market and states if you look at the other states They all have different ways of doing it some do it up a point system some So there's a lot of different models out there But the that is a big difference in the terms of a lot of things in 54 a lot of the stated goals in 54 are to Try and move as much of the illegal market into the regulated market And and then there's been a shift in thinking around the issue of people who might have had previous drug Convictions and whether or not that should exclude people from participation in the market And so that's just something that's kind of evolved and changed over over the years With a Whether there is a difference Well, so this isn't who can purchase Who can work and I work who can who can just like who can give out a prescription Is different than who can sell aspirin? There may be I'm not saying there should be I'm just saying there may be a difference in terms of vulnerability or amount you know For the risk of who was behind the counter So moving on to the next one Require current law requires DPS to adopt rules regarding the medium and manner in which a dispensary may notify register patients of its services and then I'm fairly sure that by rule DPS Essentially banned all advertising Under 54 it requires the board to adopt guidelines on advertising marketing and signage But I also put some language in there on the next page That's part of the commercial system in 54, but not on the medical But you might want to consider is that Language that fans advertising that's deceptive false misleading promotes over consumption Represents that it has curative effects Can't offer a prize reward or inducement for purchasing cannabis products Can't have advertising that depicts a person under 21 years of age consuming or is designed to be or has the effect of being particularly appealing to persons under 21 years of age You can't have Certain types of advertisements unless the licensee can show that no more than 30% of the audience is reasonably expected to be under 21 Advertising has to contain warnings and then there's prior there's a requirement that any advertising that's done has to be approved By the board prior to publication So those are just some things that are elsewhere in 54 if you wanted to consider those on the medical side Next is current law requires DPS to provide I'm trying to get this presently there is no Correct Under 54 It will be some advertising There could be some advertising yes, the board's gonna adopt the rules around that Those things that are listed there are things that are set up for the commercial system that you may want to import for The medical dispensaries as well. I just wanted to show you give you some examples of things to consider Next the current law requires DPS to provide educational and safety information Developed by Department of Health to each patient and caregiver Under 54 requires the board to adopt Requirements for the dissemination of educational materials to consumers who purchase cannabis and cannabis products Current law allows dispensaries to deliver and 54 does as well Um currently there is Anyone know Um Yes Finally so current law provides and That's nothing in chapter 86 shall be construed to prevent a municipality from prohibiting the establishment of it of a dispensary or From regulating the time place and manner of a dispensary through zoning or other local ordinances And there's nothing in 54 under the dispensary law about this But there's language elsewhere that you could import as because it's applied just to the commercial establishments There's a process where municipalities can opt out by putting it on the ballot for a vote They can issue local control licenses similar to what they do with alcohol and they can require compliance with local ordinances and bylaws No I would say the existing law is a little vague. It's not conferring You know because we're a Dylan's rule state This language under existing laws not conferring new powers, but it's saying We're not taking away any powers you might have but they don't actually have to the power to ban so Well Is the question before the town Do nothing and It's I mean it's the opt-in opt-out concept that there was So is there a difference in that in these two things And these two things I would say that under current law I would say it's not there's not really a process put forth or a procedure I would say that I would that this just says that 86 doesn't interfere with a municipality's inherent authority whatever that is, but it doesn't grant them I would argue not necessarily any new authority under current law And so under current law I would say they would need to comply with whatever zoning You know requirements or stuff like that So if your town is not zoned for that type of business or whatever, you know They also have ability to regulate based on nuisance and certain things And so whatever their inherent authority that they've been given by the legislature. They could use But they haven't been directly. I would say, you know necessarily given you know a procedure to ban In 54, there is new process where you towns can ban. Yes towns can ban Why do we want I mean under current law If I decide I want to There's space and there's only forward whatever and I decide I want to open a dispensary in Moscow and my dispensary meets full of the Zoning requirements the only limitation They can put on is and you can only be open one day a week Moscow, I mean if I meet it sounds like under current law if I meet everything They can't say you can't be there Right. I mean is that what it said with it? No, am I reading it wrong? For my recollection for in this bill they can pass an ordinance Yes, you can't be there. So we know where one or business in this town Okay, and they can pass an ordinance. How do you pass the ordinance? Okay Yeah, and then they're people come people can petition to have it removed within a certain Okay, so what this does So the language this one because the language that I have over on the 54 side is not for dispensaries I just put it there for you to right consider that it is part of that So is the language in current law around dispensaries in this bill No, there's nothing in there Right I think you told us this the other day when you first came in but am I correct that the Trial period, you know where the dispensaries throw away that basically we are moving this S54 as passed by the Senate will move everything from title 18 to title 7 about Everything eventually yes What it does is in the sections that you have is the adoption of the new statutory language framework and Then chapter 86 will be repealed Yep, and then and then the new stuff comes in and that's January 1st 2021 Nope title 7 is currently alcoholic beverages and tobacco and it's retitled alcohol it beverages tobacco and cannabis Alcoholic beverages cannabis tobacco No So that's the walkthrough of just the kind of what I would see is the framing of the main points You know there are certainly Lots there's lots in here lots of language and smaller points and things like that But I didn't know how to take all of this and put it in a chart against the other one Your response to Sandy The response to Sandy was that In 2021 everything related to medical marijuana The current law goes away and gets put in something else Whatever section the things that you have outlined here Are they changing immediately or is this what's going to change in 2021? 21 So let me ask a simple Why put it in here at all right now and why not do it at another Time as opposed to in the last two weeks of the legislative session I hear you And if I could figure out how to do that and do all the rest of the stuff that has to happen before I would do it And so but the issue is that if you think about the when we talk about all the things of the way that 86 operates now and Nothing is going to change and you have right but you have but what But but what will be happening is that Once the board get starts in the fall, they're gonna start working on adopting rules for the new commercial system, but also for what the medical rules will look like for 21 So there's not it's not that there's not a There's not a shifting of the DPS rules over automatically to the board again big I'm sorry Because of the policy, I mean you could certainly have a conversation and talk about whether or not You would want to do that and leave 86 the way that it is shifted over to seven change the terminology shift the rules over But in thinking about what you have let's say let's say let's use an example for the For like the testing and the labeling and all of that kind of stuff so if They're adopting there the board is going to be as requirements to be adopting all these standards for testing and labeling for these newly licensed cannabis establishments that are they're coming online if dispensaries continue to operate Under the old ones Rather than then you're going to have the new commercial ones with Testing requirements labeling requirements all those kinds of things that you probably want from a consumer protection standpoint But dispensaries are going to be offering under the old system where they are not required to do any of that and if so if you wait like another year Let's say and say tackle that next year Then the board is still going to have to adopt new rules And we know that rulemaking can take considerable amount of time and there's a lot of people who are very interested in this issue And so you want to make sure that you're having plenty of time for public comment and for hearings and things like that So you have to think that rulemaking will take 10 to 12 months At least from your date of enactment of any of your statutory changes And so what happens is you're going to have your medical program lagging behind your commercial program And so does it make sense? you know like to have Some of the things that are currently in the system once you have a kind of open System and it goes to this issue that you brought up at the beginning where there may just be varying Opinions on the policy of whether or not there's a true value to having a medical program when you have commercial stores available and And And so the the reason of trying to get everything up so that it will kind of merge at one point It's so you can kind of take best practices and things that are you know that people would agree are best practices around Consumer protection and testing and labeling and stuff around pesticides and inspections and things like that that don't exist in the current system You're going to be folding those into the dispensaries But things that maybe you don't want to hold dispensaries or patients to under the existing system Like you have to make an appointment. You can only go to one store, you know or things like that You you know if you have if you are so restrictive about that, but yet that same person Can just walk into any store Any commercial store then you might see people really fleeing the medical program and the and again I realize it may not be your position but the position of the people who were working on this bill and passed it in the Senate so far has been that they Value to have to continue to have a medical program and they don't want to it so So That's why you kind of have to do it all in Concert and and that hopefully there's going to be a tremendous amount of overlap So if you you know that that there shouldn't necessarily if something is from a public health standard You want you know to be advising, you know, whether it's a patient or someone else you want to you know A lot of that's going to be very very similar And that there's only going to be a you know a few different areas where there's going to be differences between a between a dispensary and And a why is your code so hard to remember is it somebody Is you know, so You know, so there are these You know up in the I'm just going to draw your attention back to the intense section on dispensaries You know it lists the things that dispensaries can do that Commercial can't so they can be vertically integrated Products aren't taxed they can deliver They can allow patients to purchase products without leaving their vehicles They can produce and sell products that have a higher THC content that may be Permitted under the commercial so there's potency Limitations in the commercial system that may not but when it comes to a medical product that may be appropriate for certain Circumstances for a met for somebody on the registry but not for the commercial system. They also Could we could sell larger quantity so there's so there's a you know, there's a Subset, you know of Advantages if you're a patient to being able to go to a particular store Those may not be for you reason enough to to maintain a medical system When the dispensaries start selling under the commercial side, they start before any licenses New licenses Doing early sales that's being still being discussed across the hall. There's that's not definite That's not definite The proposal if they decide to go with that is they would be Be following the existing DPS rules with some exceptions. So the exceptions around plant counts and Location and things like that That was pretty much my question. It seemed like Part of the apparatus for the early sales of the product under the way I understand Sorry, this bill does not contemplate eliminating the medical. Yeah, no, I understand that but we talked about the possibility The way I understand it the mechanism under which the dispensaries can sell prior to the issuing of other licenses is through The current medical or the modified medical plan If there were early sales, yes, it would be there. Yeah, sounds like that's not Sandy and then at some point the possibility love to give share of the opportunity to share Share the recommendations of the governor's marijuana policy things so that because that's So so my question has to do with with that interim period So we don't have right now there There's no there's no testing for mold. Okay, and and and presumably the board is going to say thou shall test for mold but When will that when will that take effect on the dispensaries that are operating under the way team Is there going to be some kind of interim thing that that that has an overlay of new regulation on top of what the UPS is Already doing in that no, so the way that the time the bigger timeline works, and I don't I don't know if you guys have the It's always changing Right, but so on there as you look at so on or before December 1st 2020 We're going to see adoption of final rules Right, and so they'll probably be like these rules shall take effect and those medical rules are going to take effect January 1st 2021 when the new statutes come in with the program shift over and all of that stuff And so they're going to have a heads up because they're going to be up I would assume, you know participating in the comment and process that DPS is going to be working with the board You know that I'm sure the board is going to be looking at the existing DPS rules They're not going to reinvent the wheel. They don't have to they're going to look a lot of what's been working and what they want to import over And so what will happen is on that January 1st 2021 is the program shift over They operate under the new statutory guidance. They operate under the new rules and they operate under the board And so they wouldn't be required to go doing all of the new testing stuff until that time Because you have to have you have to give everybody plenty of time for the adoption of the rules Does that answer your question So the How long it took to really consider doing the medical program itself I mean you start to take your testimony 14 years ago Because this really is sort of the layering on of many new things So it's certainly what it took us long to get to a program that makes a lot of sense for the people who are real need And that we're going to try and move this very quickly Okay Discussions and what will end up being our recommendations Specific language and then general concepts Thank you so much I know I Just learned a lot The shale everything from the health department, so I'm here to talk about the recommendations that came out of the summer Governors marijuana Commission prevention and education report um We the commissioner was the chair of the the committee whatever you want to call it that looked at prevention and education and They they actually broke up into subgroups and then came back together. So it was a whole process and Your illustrious chair was also a participant Sorry, I just wanted to let you know because I didn't talk about it because it wasn't 54 that came over from the Senate, but it is in the government operations amendment is very key to probably what you're discussing which is that of the the Retail excise tax, which is that it's 16% currently in 54 the government operations amendment 30% of that revenue is dedicated to a new prevention Substance misuse prevention fund good With a six million dollar cap very exciting Yes, that's very exciting and I'll talk about that six million dollar figure shortly so I'm Previous to that in 2016 the health department did what's called a health impact assessment Which is a process where you bring a lot of different stakeholders together and look at a policy That's being proposed and think about how if that policy were to be enacted. How could you make it? Have a better health impact or less bad health impact depending on the policy So we've leaned we also leaned on those findings in and putting this together So just I'll give you a very brief overview of Some of the things that I think apply to s54 and I will talk about the The number that Michelle just just quoted which is the six million dollar number and what that well The health department could hope to do with that from day So one of the things that I think is really important is that we have two legal substances tobacco and Alcohol we we learned a lot. We have learned a lot over the years about them and what works and what doesn't work in terms of prevention and Some of the really really important things are smoke-free policies limiting access Which I know this committee has heard a lot about and there's all sorts of different ways to limit out access in terms of limiting outlet density The type of outlet so making sure that you're limiting who who is going into these outlets that is not You know a bakery that sells, you know regular cookies and brownies and also sells THC So you've got a kid going in there that might have easier access for example Limiting the times that things can be sold and then limiting the age obviously that that items can be sold Also something that's good is that it's the increasing of taxes in order to establish minimum prices so pricing is a really important tool and Children and young people are particularly sensitive to price Align for local control. So this is an option to learn to ensure that local municipalities can control All of the things I just mentioned so not just whether or not there's a licensee, but what types Where they are how they control who goes in all of those things Packaging and child resistant packaging is a very important thing to consider And making sure that kid. I mean, this is a problem. That's been very serious in Colorado is the young children Taking too much of an edible and ending up in the emergency room So boy think they do now They do Limiting of advertising so the the question of For example point of sale one thing that I talked about when we're talking about the campaigns that the health department's working on is this point Of sale advertising so if you're a kid right now and you walk into a store corner store You might be bombarded by tobacco advertising right there might be cigarette. It's all over the place So there's all different types of advertising as we know and and youth exposure to that As we've seen with jewel can be really really important and impactful And so having meaningful restrictions on advertising is a very important prevention strategy And enforcing the laws they don't do any good unless we have the personnel and the funding and the capacity to make sure that They are followed. So that's a very important piece So that's So I would have to do I can I'm Willing and happy to come back and answer that I would have to like really scrub it To address but to what extent where you think that maybe there might be things like the one that pops out to me is advertised Yeah, I don't know. So maybe this version is but the advertising that came up from the Senate was really problematic So I can try to do that analysis for the committee It's got laps has language We're not in terms of I believe there is It go ops has six boats to vote it out I believe there is an interest in continuing this to move and so to wait for go ops to finish it or it then to go to Ways and means to that I mean You know what whatever your latest draft is and we may have influence You know rather than asking Shaila to write it. No, no, I just I just was I was just suggesting that she work on whatever Yeah, yeah Don't worry. I only have stuff to do in this committee tomorrow. So I'll have plenty of time So the funding so what is the could this council recommended Various different places to to invest money in order to really invest in a comprehensive prevention strategy for marijuana We got the six million dollar figure from the marijuana Yes, I'll get this So So one of the things that was Conceived was this idea of establishing a council and a fund and that we would have to be able to manage that and The amendment that is on that How scovops is considering now would have have this Fund a special fund and the bill 146 that you are contemplating has a council already So we would not want to duplicate either of those efforts. So I'm going to skip those two recommendations This for those who are interested this report has an explanation of what comprehensive community-based Prevention looks like I know the committee's heard about the Iceland model and the Finland model in Chile mall But we kind of go through that and and and attempt to give examples So it's a good place to go if you're looking for those examples So just even on this one and above there's no mention of a liver monitors and Maybe there should be some prevention put into their older verminers use of Cannabis and also Interactions with other medications Yeah, I just got an email from Someone who attended your morning or about that. Yeah, so so it's a good It's a good point and I think one of the things that's really important about this model of Regional prevention network. So that's the the six million dollar number is establishing these regional prevention Networks and the concept behind those is that they would do an assessment a needs assessment of their region and Be able to be flexible enough to determine So let's say it's a region that doesn't have a whole ton of young people and they are having a very big problem with Falls related to mixing substances That that could be a strategy that they decide to implement Good to see it in there because otherwise This is done the report is done, but However, I'm not sure how we would do that, but yes, I think that that's but that's sort of the the reason that we want to The reason that we that the department is interested in this type of model is to allow communities to respond to The problems that are facing them specifically and not prescribe Okay, state of Vermont everybody's gonna do this same thing Cuz that doesn't work as well So evidence-based strategies and evidence-informed strategies are very important and so what we've done in the past when we've done the regional prevention framework system is provide like I Think they call it menu And also allow for them to request a specific Program or type so that it would still have to be approved But it but that if it's not on the menu doesn't mean that they couldn't You know do it as long as it was shown that it was really an effective thing Now he's gonna just give me money So That so when we looked so When we went to testify when the Commission went to testify for house gobs the total number for all of the different strategies, so this is just the community-based strategy that this Prevention council recommended There it goes on to recommend funding for school-based prevention to the tune of 15 million and Given the joint fiscal estimates for what the revenue is going to be in the tax and regulate system When the programs and the department was asked to prioritize among these this actually this group Had prioritized that community regional network as the top Most important thing if we had to choose And so that is where that recommendation came from And that number if we had everything we wanted in the whole wide world We would also have school-based prevention and fund it fully and fund it outside of the Per student caps the idea here would be to ensure that every single school has Sufficient number of student, you know counselors who could actually work with students on the ground to do real prevention Intervention treatment and referral Work Is there any data from ALE on the like we know that there's like A dozen and a half schools that have the substance Counselors is there any data in terms of those that happen those that don't happen I mean look into that we give grants to schools to do and I don't know some of them I think can use it for that. So let me yeah, let me try to find out I don't have that off the top man. The other thing is some nonprofits from them in schools So it there it's not there's not one kind of way that they're placed there You know like I know spectrum funds several in the Burlington schools. So at any rate, I Let me see what I can find out. I don't know just trying to figure out, you know Have you know X amount of resources whatever those turn out to be and I think that we want to make recommendations about Where it's gonna be the most effective place to put those resources and I understand what your your recommendation is those community-based Regional networks and I see that they would work at schools as well I was gonna say so they could choose that so they could say look This is the whole the whole is you know having more counseling more services for students in schools And and use that funding through that model But yeah, so again if the world if we could have everything we want in the world We would we would also be looking for about 15 million to fully fund that school system The last thing is funding research on health effects. So this is one million dollars for Cohort study you heard me talk a little bit about the pace study a couple days ago That's going to look at policy and education campaign effectiveness So that's a cohort study because we're trying to follow Kids over time the concept here is that the one of the things that we hear over and over and over again there's not enough research on the impact of marijuana on on Health period especially current THC levels and So the the Commission's idea here was that it's hard to get the federal funding to do that kind of work And we could do a cohort study With a probably with some university or college in Vermont to Track students or young people over time and actually measure those health effects in a way that was Effective and real And that would cost about a million bucks a year if we were going to maintain that What was that that's in addition to Oh, that was six million yeah Does that provide for anything that six million does that provide for anything at the health department any Personnel at the health department to work with these prevention groups So no, that's why it was seven the total. That's why this big This big number up here was seven million because there was additional Pieces evaluation and other pieces that we had wanted to include in that including staff time We'll live with it I would love more Put some more money So One of our I mean just so the committee knows what my business officer tells me to say is one FT cost about a hundred thousand dollars Does everybody heard the do your part campaign on vpr? I And just so I know my homework The committee would like this list In a chart right what's what's recommended here and what's in s-54 how it lines up 54 Around that Advertising seems to be the For the record my name is Jeffrey wall and I'm and I'm the director excuse me of the Vermont crime information center with the Vermont Department of Public Safety and we're the entity that currently oversees the dispensary program In Vermont as always I'd like to primarily spend my time today answering any questions that the committee may have I do have a few things that have been passed along to me as notes to some questions that may have come up So let me provide a few answers that might be helpful right up front and then I'll answer any questions that I can A question came up regarding patient numbers and how that potentially may have changed our high of patient numbers and the number literally changes moment-to-moment because we're always adding and folks are Not renewing their license, so it's even one day to the next changes, but as of June of 2018 We had a high of approximately 5,700 patients registered with the dispensary as of December 18 it was down to 300 patients with the registry and as of today when I checked with registry staff. We were at approximately 5,200 Not even sure what that number could come from but That those represent the current number of patients that we have On the registry Currently 5,200 approximately. Yes. Yes, and since the the Law was passed the last year We have seen a Steady but not substantial decrease. It hasn't fallen off per se, but it has been the number has been moving down We don't have any way to project this time next year what the number may look like there's just no ability To do that, but it has been Decreasing slightly. I understand there was also potentially a question around background checks for financiers And what information they have to disclose to the department? They are required to do a fingerprint supported record check the same way a dispensary employee or principal would would be But we don't have any additional oversight of financiers Having said that I am not sure what regulations might exist if someone wants to come in and invest a large amount of money and never Not what disclosures with tax or someone else they might have to make but as far as our the Department of Public Safety is concerned We don't have any additional oversight or inquiry into where the money is coming from for example That's not within our our wheelhouse so to speak on there there was a question about the The work perhaps a comment about the length of time for the fingerprint supported record checks to be completed From when we receive everything we need to receive it's typically two to three weeks However, sometimes folks may have to wait several weeks to get in to have their fingerprints taken to even begin the process So someone looking outside might think well if it takes PPS two to three weeks And it takes me three weeks to get in that's a six-week process Where our processing time may only be two to three weeks, but from the outside it's looks like it's a six or a week or longer process We process them we don't take them that they have to go through the same process than anyone else the same amount of time the same amount of time So they all they all go through the same the only group that we provide any priority to is individuals applying for Emergency child care or foster care placement. We do those to believe within 24 hours of receipt Everything else goes in the hopper. We process it as soon as we can we have a pretty good operation But it does take two to three weeks from when we receive everything to process it there as far as the Municipal opt-in or opt-out what we currently require for dispensaries as part of the application process or any update is a letter from the town they are proposing that simply Indicates that the town does not have any prohibition against the dispensary opening up or any type of Entity opening up in that location And that's primarily to be candid with the committee so that snow on at the town can come to us and go Why didn't anyone tell us about this? We didn't know about this and so it's is to make sure everyone is informed on that We do not track Towns that have a prohibition. I do know they're just in discussion there I believe a small number of towns and municipalities that may have prohibited through local ordinances We don't actually track that we require the dispensary to provide us with with proactive proof that there's nothing prohibiting them We typically get a letter from the either select board or if the town has a mayor or town office Town manager just stating that they've been approached by ABC And that there's nothing that prohibits that entity from opening or operating within the town So when we keep that on file again So that we're doing our due diligence Due diligence there. So those are those are a few questions that I understand folks may have Well, if we received something back saying they were prohibited Then we wouldn't proceed with the with the application or we would communicate that back We typically require the dispensaries to provide those to us So I doubt we would even see it They would simply say well, we're going to change where we're going because the town won't provide us or won't allow us to operate I I suppose we could get a letter, but I have a binary concept You were talking about background checks for financiers and that you do a fingerprint so if you know financier came back with Something on that person's record Would that be a reason for you to deny a permit or deny a license? Well, it would if it came back There is a metric in the current statute in the rule that talks about depending on the nature of the offense How long ago I was has there been any criminality since then? Either it's denied or it's preceded if someone had a misdemeanor Simple assault 25 years ago, and they have anything since then it's unlikely to hang hang up if it's something more recent Then it may be denied, but they can appeal that they can appeal that either on two grounds either the accuracy Which anyone having a criminal history of background check done may always appeal the accuracy of that Whether it be for educational license anything they can appeal the accuracy of that and we'll review that on the accuracy grounds Or that they've been rehabilitated So that if they had a misdemeanor marijuana, you know, 11 years ago, that's a drug offense So it would it would be a typical preclusion. However, they can come back and appeal and we would review that internally Determine whether or not we felt like they have been rehabilitated And then move forward as far as to whether or not it would That would specifically speak to someone's individual card or their ability to interact with but it wouldn't necessarily hold up the License application, but they may have to find funding from other sources That's a good that's that's a good question I Would honestly have to defer that primarily to to Individuals that would be involved with the cannabis control board Whoever will be setting or overseeing that up because they would have to be the ones to get their infrastructure Up to speed for us to hand off the program the program runs fairly well right now So handing it off to someone else from my perspective. Okay. Here's a highly functioning program We're handing this off to someone else Whether or not they're prepared to receive it or not would would depend on how well they're their rules and Our vetted and our setup I can speak from having been involved in rulemaking for this and also a couple of other programs We have at VCIC It can be a challenging process To go through and work through but with dedicated resources It's certainly very doable to get through in a in a 10 to 12 month process to well crafted Rules that can be useful and implement implementable. So from my perspective We're happy to hand it off whenever we're required to by statute. We're happy to hold on to it as long to as well But it would really be up to the person receiving it as opposed to from my perspective Hand it off it's fine and it stays with us from my perspective We implement the program based on the statute So if the statute requires a stay in DPS, we'll keep administering it if the statute in the case it needs to move Then that's fine, too If there's a policy decision as whether it should or shouldn't I would have to defer to somebody else to speak to that policy But from my perspective as the administrator It's a deputy commissioner here or commissioner Anderson So So currently we have three full-time staff and one part-time staff temporary employee No, ma'am. No No, ma'am. No, ma'am. I'm not My my distribution of time varies wildly depending on to be candid partly what the legislature is curious about I spend more time dealing with it than other times But now as director I have my time gets divvied up under a number of things and I'd spend whatever time is required on any particular area So so I know that this was originally set up to be supposed to be self-sufficient in terms of funding the Administration of the program is that proven to be true? It has been yes, ma'am. It has been no other VCIC Operations are funded by this program And we do not divert any funds from any other Any other funds within VCIC fund There was a surplus of funds that that were generated partly through one-time monies that came in through application fees, etc and we had also had been and continued to be operating under a The charitable term I'll use is antiquated database to maintain this this program Knowing that's expensive it projects are expensive. We were banking that money. Some of that did get Taken away From that so reappropriate. Thank you much better term than taking away. Thank you reappropriated And I can't speak to where that ultimately ultimately went But we continue to move forward with the necessary projects on that but we have always taken I've been in my role for nine years approximately. So I haven't been here for the entire length of any type of marijuana registry But I've seen certainly since the dispensaries seen the program change and we've always taken it very seriously that this is meant to be a Self-funded self-sustaining program And tried to view it as such In terms of their thoughts as to the changes that are being proposed You've just described this as a well functioning Correct Maybe I'll take a step back. What is well functioning? What do you mean by that? From my perspective we meet our targets And there are certain targets as far as processing times, etc We meet those targets We have to process a complete application within 30 days. We meet those we meet those targets We have dispensaries. We have all of our dispensary licenses are coming being used none of them are sitting fallow or vacant They're all up and running. We do have while we have had a slight decrease in the number of patients Since the middle of last year we're still over 5,000 which if you look at the historical trend It's the rate has climbed substantially every year with a slight dip this year And I think we can say due to partly due to changes that happened last year in law around around marijuana and cannabis As far as that goes We tend to take our requirement to Provide necessary oversight as required by statute, but not micromanage the dispensaries There's a lot of information they required to provide to us There's a lot of statutory requirements on their operations and we hold them to that But we don't get involved in the day-to-day business operations of the dispensaries to let them operate And we serve Vermonters we talked to them every day we talked to the Vermont residents every day who are applying for the program answer questions On that and process their applications and get their cards back to them in a timely manner So from my perspective I would consider it a well a well functioning program One of the members of the marijuana oversight committee She raised the issue of Cartels have raised the issue of having to designate a dispenser From my perspective candidly who reduced one administrative hurdle I mean because we have to track that and if an individual wants to change dispenser We have to cancel their card issue them a new card mail it out into the administrative piece How it would affect the dispensaries I would have to defer to representatives of the dispensaries to talk about how it would affect them I believe it was mentioned earlier in the discussion part of the Metric of how much product they could produce was tied to the number of patients they had so you had to by nature Have some sort of corollary between those two and whether or not they could operate or function within a more Open for lack of a better word Market so to speak I would have to defer to them but from my just strictly from a it's one less thing we'd have to track one less detail we'd have to manage and would Reduce the amount of administrative Processing we have to do for patients Some of the forms have been described as very prescriptive Because they're in the legislation if you had a magic wand The language that is in the forms what what language what part of the existing forms right now are duplicative overly Detailed not useful for Managing the program or identifying The the forms that that patients health care providers and caregivers have to complete have gone through a number of iterations through the years Partly that is due to the fact that when this first came on for and even from my perspective nine years ago Volume was much lower So there was that issue but also the department didn't have a lot of expertise and managing Citizen registration. It wasn't anything that we did So we had to learn a little bit by working with the patients and then one of the dispensaries came on how to make things as Easy as possible given all the information we're required to collect and verify my I tend to Know that a lot of individuals don't realize quickly talking outside of for example these halls That we have to verify a fair amount of the information that's on the form We just don't take it and go okay. It all looks it's good We have to say call the health care provider back and go is this accurate is this true? Did you sign this is this complete? Are they a patient of yours for example, we're required to do that that sort of work So given the amount of information we're required to receive it and verify I think the forms are in pretty good shape the one thing I would recommend Where I to be able to do that is the requirement of having a cover page or cover letter It just literally is a page with just writing it has no input the patient don't actually do anything and some of the Goals of having that can be accomplished through the design of the form itself as opposed to having a page Which is just literally torn off and put in the recycle and there's no value added for us for that and I would I would Question and maybe there is an answer which is not which is not expected to this but question How many patients and caregivers and health care providers find it useful to have a cover page with all this information on it Rather than the form just being more self-guiding There we literally just recycle those pages when we get them back. There's there's nothing on them that we need So that would probably be the single thing Information that we require How much of it is From now that you have nine years of experience of running this program how much of it is Yeah, it makes sense to actually verify that Dr. Pugh is a doctor or you know is seeing Mm-hmm Well from my perspective and I appreciate the rephrasing of the question it does help The way the forms are constructed It's really meant to ensure that a qualifying patient is qualified and their health care provider does meet the requirements So those are the only way the forms could be streamlined or changed if that's perhaps part of the question would be as if the requirements Were streamlined or changed. Otherwise, we have to gather that level of detail in order to To move forward so unless the requirements change then the forms are going to have a certain amount of complexity regardless I may have missed this but number of Individuals who are youth who are in the registry? I didn't pull that number this morning. It is very low very low Handful a solid handful It's very low. It's very low. It's not not any kind of substantial group at all. It's fairly well There always are a couple, but it's fairly well I want to thank you Peace And I appreciate that that comment and I will certainly pass that along to the staff they do amazing work with the patients in the program So I'll make sure to pass that along. Thank you very much Given that we are interested as the committee that has focused on this area we are interested in Your comments on the medical marijuana And some of the shifts and changes Contemplated I will happily pass that along realizing This is why this is why I'm being very honest You may not be able to do that because this is from the point of view of it. This is mean this goes forward It's assuming the larger package goes goes goes forward What makes sense for maintaining the integrity of what you identify is one of the best I will absolutely pass that up. Thank you And they could get back to me by Tuesday as to whether or not I will pass it when I get back to the office this afternoon. You're welcome Thank you. Thank you very much. Thank you very much Very much for everybody we're having a come to Jesus It is has nothing to do with this film and has nothing to do with any other