 Hey, my name is James Pepper. I'm the chair of the Vermont Cannabis Control Board. Today is December 2nd, 2021. It's 11 a.m. December 3rd, 2021. Thank you. And call this meeting to order. Today we're going to be talking about the future of the medical program in Vermont. And before we get to the agenda, I'd like to just discuss a few administrative details. A reminder that we pre-filed two of our rules with the Interagency Committee on Administrative Rules last Wednesday. They're available on our website. They cover our application requirements for the various license types and our compliance and enforcement regulations. I want to remind everyone listening if this is very much the starting line of the rulemaking process, not the finish line. We will continue to discuss these rules at our board meetings. We'll take comment on them, both from the administration, from the legislature, and from the public. And we have the ability to adjust them along the way. We all know that every state that has gone before us has struggled with unintended consequences of well-intentioned regulations. And we've tried our best to learn from these mistakes. Of course, the best thing that members of the public, people watching, people that are going to be impacted by these rules, can do for us is to help us spot the places that might be overly burdensome, unnecessary, impossible to achieve, gorgeous areas that we may have missed altogether. We also, as a board, are probably going to have to start meeting a little bit more frequently over the coming weeks. Next week, the board's going to be meeting, the cannabis board will be meeting on Wednesday at 11 a.m. likely and Friday at 11. And then our exploratory subcommittee of our advisory committee is going to meet next Thursday at 11 to discuss some of the requirements that are in our January 15th report. And when we have agendas finalized for those meetings, we will post them to our website, which again is ccb.vermont.gov. So before we turn to the agenda, anything to add, Julie, Kyle? No, thank you. So I would, have you had a chance to review the minutes from 11.23? All right, I would take a motion to approve the minutes. All in favor? All right. Okay, moving to the agenda. So again, today we're discussing the future of the medical cannabis program in Vermont. The medical registry is currently under the umbrella of the Department of Public Safety. However, the Cannabis Control Board takes it over on January 1st, 2022. Under Act 164, the current statutes and regulations that control the program expire on March 1st, 2022. And we as a board need to recreate the regulations. And we've been given two essential directives on how to do that. One is that no new regulation we create can be more restrictive than the current regulations. And two, to the extent that we can, we need to aim to align our regulations with the adult use, the regulations for the medical program with the adult use recreational program. So before we, as a board, turn to discussing how the registry should change, I think it's really critical that we all understand what we have the authority to change versus what is set by statute and is squarely within the legislature's purview. I thought it would be helpful for Bryn to walk us through some of these distinctions and then we'll turn to some of the specific recommendations that we received from our medical subcommittee, of our advisory committee, and then we'll just have an open discussion. Bryn? Okay. You ready? Yep. Thank you for the introduction. I'm just going to talk about kind of a high-level overview of the medical program and what exists in statute versus what exists in rule. And this is not an exhaustive list of what is in the rule and what's in the statute. It's really more of a list of the issues that have come up over and over again both in the advisory committee, subcommittee, medical subcommittee, and also just in the public comment periods. So I just have a document here that kind of reviews the high level of the program, what's in statute and what is in rule. And as Pepper mentioned, there is statutes that are governing the program that are going away in March. So the statutes that take effect that are set to take effect in March are a little bit different than the statutes that are going away. So there's a few different levels here. There is what is in statute as it is set to take effect in March, and then what is going away, and then specifically what the board has the authority to do in rule. So we'll just start out with what's in the statutes as they're set to take effect in March. So first of all, and just as a reminder, what is in the statutes is what is within the legislature's purview to change. The board does not have the authority to change what is set by statute. So first is the qualifying conditions for what type of condition can get a patient onto the registry. There's a series of qualifying conditions that are set in statute. It's outlined here. In subsection A, these are the various conditions or diseases that are qualifying. Subsection B is post-traumatic stress disorder. Subsection C is a disease or medical condition that's chronic debilitating and then produces one of a series of symptoms. So that's set by statute. The board does not have the authority to add conditions or change conditions without legislative action. The second thing that's set by statute is the per-patient cultivation limits. So what is set in statute as they are set to take effect in March is a per-patient cultivation limit of two mature and seven immature plants. Also the possession limits, the per-patient possession limits, is set to two ounces by statute. The requirement that caregivers have a criminal history record check that's fingerprint supported. So a fingerprint-supported criminal history record check that's both for Vermont, out-of-state, and also at the I records. That is a statutory requirement. The patient to caregiver ratio is set by statute at one to one and also the required fee for an annual renewal of the registration for caregivers and patients. That is also a statutory requirement. So there are also some statutory provisions that do exist now but don't exist once the new set of statutes that govern the program take effect in March. So the first is a requirement that a patient has to designate a single dispensary that they can use. The next is that bonafide healthcare professional patient relationship which is a which is the requirement that there be a three month relationship between the patient and the caregiver or the healthcare professional. The limitation on dispensaries that they can only sell two ounces to a patient per patient per month. The definition of a registered caregiver is also going away. The new the statutes that take effect in March still refer to caregivers but there's not an associated definition for what a caregiver is. And then the limitation that there be only five dispensaries statewide unless the patient registry goes above seven thousand. That is also disappearing. So this last short list here is again the list of issues that have come up repeatedly in public comment and also in the medical subcommittee. The board does have the authority to dictate and rule whether or not the dispensaries will provide out-of-state reciprocity. So if you're a patient out-of-state if you can come and purchase as a patient in-state that's up to the board. Limitations on the number of people that a dispensary can serve at one time. The amount that a dispensary can provide to a patient in a given time period. And then again a note that it is set by statute that a patient can't possess more than two ounces at a time. And then lastly the standards for denial of the caregiver card based on the criminal history record. So the criminal history record is required by statute but what appears on that record the board does have some authority to dictate whether or not a caregiver could get a card based on that record. So again this is a high-level overview of the issues that have come up kind of over and over again as the medical program has been discussed and where the board has authority to make decisions and where the legislature needs to take action to change certain things. Okay and Bryn I know you asked me to tell you if there's anything missing from this list before the meeting. I do have one question and maybe Lindsay can answer it is we've heard a lot about third-party testing for medical dispensaries and I think that I have heard from the dispensaries that they are relying on a rule or a statute I don't know which as to that they can't share any of their samples with a anyone anyone other than other dispensary. So I'm not sure if that's a rule or a statute and maybe Lindsay notice. We can look into it. I know it's in rule I just am not 100 positive okay because they are not allowed to dispense or give cannabis to anybody but a patient the caregiver or another dispensary which I believe is in the current statute. Okay so I'll we can just verify that by the way just for the record that was Lindsay Wells who's manages the Vermont Registry program. Okay I think that is very helpful it's very helpful for all of us to know what we can do by rule and what we need to work with our partners in the legislature to accomplish. I have a question in the adult use side we talked about training and education of staff is that something we can do rules for the medical side as well. That is a rule by yes yes yeah this qualifications and standards there can be done by rule. Okay. So then why don't um before we really kind of dig into policy and discussions why don't we look at what the medical subcommittee recommended to us and I can pull that up I have some slides on that and I need to do some supplemental discussion. You can pull it further if you need to. Okay and let me just leave it like this so I can kind of read my notes as well because this is they are working on a final report I'm looking at kind of a draft of the so I only put the kind of high level recommendations here. So just as a reminder the medical subcommittee the membership was Meg Delia she was the representative from the Vermont Cannabis Trades Association. Jim Romanoff who is the chair of the marijuana for symptomary relief oversight committee. Matt Myers is the director of prevention services at the department of health he was the designee for Dr. Levine and so their first recommendation is really around continued access to products. So I included the kind of paragraph and support of this but essentially what this says is we need to ensure that the current Vermont patients have access to the medicine that they've relied on while we transition into adult use recreational and the trade association has committed to maintaining a three month supply minimum supply of biomass for their patients based upon the previous three months of sales and so that will include everything that's needed to make RSO any of the kind of specialty products that are only available on the on the medical side and you know this I think we have required this in our rules as kind of a precondition of licensure for the integrated licensees to maintain this three month supply and then the kind of secondary recommendation here under this heading is also to have us work with the trade association to continue to collect data on sales inventory and demand if they kind of you know if we allow some other these other kind of things to take shape and we have more patients or fewer patients just keep a kind of close eye on on the sales and inventory and demand throughout this transition to adult use second recommendation remove the three month relationship requirement as Bryn just mentioned this is actually not in the new statutes and so we don't have to do anything here this will disappear on its own you know I think the the original purpose behind the three month relationship really was to ensure that there wasn't kind of doctor shopping or kind of you know doctors offices that would pop up just for the purposes of handing out medical cards but I think there's probably sufficient evidence out there over the last 11 years that that's not I don't think this is a real concern exactly remove the patient designation of dispensary requirement again this is one that will go away it's not in the new set of statutes over past in act 164 so we don't have to necessarily decide to do this or not it's just going to go away remove the caregiver fingerprint requirement um so just to think about caregivers um you know these are people that have that serve multiple functions um and we can pull up the definition if we'd like but just from a very high level they um they can go to the dispensaries on behalf of a patient who might be terminally ill or immobile and they can also be a designated grower for a patient and so the the the fear of that this regulation is meant to address is really that you know a lot of the patients are very vulnerable and they could be get get into a bad situation with a caregiver where you know they might try and exploit a vulnerable adult you know the idea is to try and make sure that caregivers are kind of they don't have a a history of kind of um harming vulnerable people um the fingerprint requirement um you know historically we've done um background checks on caregivers and there have not been problems that have arisen from this relationship um most the vast majority of caregivers are spouses parents children of patients not to say that those people can engage in kind of predatory behavior but um you know I to me a fingerprint supportive background check is a pretty um arduous requirement for a caregiver and you know the the recommendation from the subcommittee is to get rid of it we can still do a state background check um but the the fingerprint really is about a 50 state background checking with the fbi record so the recommendation was to remove it did that change with act 164 did something around fingerprints change the new legislation this you can see the difference between the 18 vsa and the 7 vsa so the 18 um are the old um requirements and the seven are the ones that are supposed to take effect in march so this is a new requirement however there was language in the old ledges in the old statutes around doing you know criminal history background checks so this is in some ways new in some ways old um public awareness um so this is really uh the the thought was is that the ccb licensees the medical oversight committee healthcare professionals should be allowed to talk openly more openly about the medical program i think this kind of skirts the line between advertising and um public awareness you know i i think um i don't the the exact language is that the subcommittee recommends that the ccb allow licensees and healthcare providers to disseminate information to increase public awareness on the medical program i don't i don't really fully know what that means other than a lot of people don't know it exists a lot of healthcare professionals don't know it exists and that there should be some allowance for the ccb or the dispensaries to kind of promote themselves um again this there's some interplay with our advertising that you probably want to consider before we when we talk about this in our discussion remove the three person requirement and i think what bren said is this goes away or maybe not currently i think it's either by rule or by statute that only three people can be at a dispensary at a time the idea here is to ensure privacy you know there's still stigma around cannabis of course and if you're at a teacher or a healthcare professional and you're also on the registry you might not want to be in a place that's open to the general public um to to get your medicine that's cannabis yeah and i mean with the way we decided to work with the integrators or both feeding a retail license that currently operated dispensary and not requiring a separate entrance necessarily this is now would be kind of hard to practically yeah you know do right i think it's still ensure privacy in four or five people a minute depends on how you know spaces yeah absolutely i'm just thinking they could what if there's three i'm thinking of a scenario where there's three medical patients that come in and there's a people waiting for adult use do they kick everybody out you know what i mean you know i think we yeah in rule he said that you could have a kind of reservation system or an appointment system and you could do curbside so i think we do have ways to kind of protect privacy of the patients that um might have other things that they you know other issues going on yeah so i think we i think we have dealt with this if we wanted to eliminate the three person requirement no and that's what i'm trying to say i think it would be just judging by we've put in a lot of parameters but just this strict person count would be could be challenging to achieve or maintain given the way that some of the dispensaries are currently set up yeah expand the definition of i mean this is essentially expand the qualifying conditions specifically the medical subcommittee wanted to include anxiety sleep disorders and any condition that would prompt the prescription of an opioid or a diagnosis of opioid use disorder there was a lot of discussion around adding just eliminating the the list of conditions altogether and just going whatever a doctor would recommend that fundamentally changes the way that the program works currently um currently doctors are not actually recommending the use of cannabis they are merely um they're merely attesting that their patient has one of these listed conditions so there is a fear that if you change fundamentally that a doctor has to recommend because of the state of science in the united states and what's being taught in medical school is that no doctor might actually end up recommending cannabis and you could see the patient decrease as opposed to increase and again this is strictly by statute we don't have any authority to expand this in our own right or in our own regard so if we wanted to add things like anxiety sleep we would have to ask the legislature to do that sleep disorders exempt certain conditions i mean these are qualifying conditions or debilitating medical conditions from annual renewal requirement this is really about increasing or decreasing the cost and decreasing the hurdles that patients that have terminal or incurable diseases have to go through in order to stay on the registry i mean um i think really it's kind of there's only a handful of conditions that aren't lifelong that are debilitating medical conditions and so why do those folks need to go for an annual renewal why do they need a letter from their doctor every single year saying yes i still have terminal cancer expand the definition of possession limits and purchase caps i think um brinn mentioned that the purchase caps do go away in the new legislation and that's the two ounces per month the possession limit really deals with the plant count which as brinn noted was too mature seven immature and again this is legislative so we don't have the authority to kind of with the stroke of a pen change that reciprocity this would be allowing individuals with valid medical cards in other states come to vermont and visit our dispensaries we can talk about that during the discussion the thought there was that this would increase the number of patients on the registry or that are participating and you know if there's increased scale on the patient side and then they can provide cheaper products they can you know leverage economies of scale to provide cheaper products to the patients remove the application fee for patients really the the medical fund has been in the black it's been positive year after year and a lot of people think that that kind of overage surplus should be applied to either reducing application fees for patients or reducing them reducing or removing so the medical subcommittee recommended redefining and expanding the definition of registered caregiver and this is somewhat controversial in the subcommittee and the medical oversight committee has spent a lot of time dealing with this the kind of thought was from them from the oversight committee is that you kind of bifurcate the definition you say there's a caregiver that can you know go to the dispensary on a patient's behalf can administer medicine on a you know to a patient and then there's a separate kind of caregiver that's a designated grower and so what the subcommittee this the subcommittee asked to buy for this bifurcation and then they said when it comes to purely kind of administering medicine or picking up medicine that that should be an unlimited ratio you know one person should have as many caregivers as is necessary to kind of you know administer their medicine for them but when it came to designated growers that ratio should stay a one-to-one and so that's the kind of contours of this of this recommendation and I think that's it they also there's three other there's four other recommendations that weren't all that well defined around data collection and in trying to increase research so I've asked for more information on those you know they don't require kind of rule changes so we can kind of think about them separately when I get more information on them and then just as a reminder there is the marijuana for symptom relief oversight committee that committee is wrapped up in title 18 so that committee sorry also will expire with the expiration of the statutes they were tasked the medical well we are tasked with proposing an alternative to that something to take its place and you know the medical for or marijuana for symptom relief oversight committee met quite a few times and came up with this recommendation it was contained in our november 1st report so it's not new to any of us but I figured I'd include it here just because I think it's really important that we are going to have a group I mean what is it 12 people here that represent a vast majority of interest on the medical program including patients and caregivers healthcare professionals and cultivators that will be providing us continuous recommendations on how to improve the kind of what you can see here the ability of the patients to access the program increase affordability make sure that the dispensaries are actually serving the needs of the patients and then also how to leverage any excess money that's in the fund whether that should go towards sort of improved services products educational opportunities etc so I wanted to just leave this up on the board as we move to our discussion of the future of the medical program which is the vision mission mission and mission and vision statement that we created around the medical program which is that we're going to try our best to ensure that patients and caregivers have continuity of access to the existing program services we're going to endeavor to reduce the regulatory burden increase safety and affordability of the medical program ensure that these are quality products and that we have educational programs for healthcare professionals so I just want to leave that up on the board because as we discuss things I think it's important just to be able to refer back to this so let me just see where I am so turning to kind of our discussion of the medical program in advance of this meeting I went back and watched our meeting on the medical program that we did I think back in May a long time ago at this point but and I was just reminded in watching that and hearing from the patients just how vital this program is and yet at the same time how restrictive it is and how inaccessible it is to a large segment of patients and how unaffordable it is to a large segment of patients as well and of course you know it's our job to kind of start untangling that that situation that being said we have very strict timelines and we have these deadlines looming over us with the expiration of the statutes and the implementation of new rules and all the kind of uncertainty around bringing on an adult rec market while trying to maintain continuity of services and I think my initial reaction to all of that is that we really need to be thinking about our task in two phases the first phase really to me would be to want to achieve our immediate statutory duties which are to redraft the rules with those two directives you know no more restrictive than the current rules and aim to align our new regulations with the adult record regulations and then the second which I think is also kind of contained in our mission and vision is really ensure that the current patients in this kind of onset of the adult rec market are held harmless by this kind of new profit motive moving into the state and you know these new the current dispensaries being allowed to kind of participate in this new aspect of the market so on that second kind of ensuring that patients are held harmless I think that could mean you know ensuring continuity of products reducing waving fees reducing or waving renewal requirements patient caregiver ratios etc and then with respect to kind of phase two I think that's really where we need to reimagine the system and really think about systemic ways that we can improve access affordability and quality and I know that one issue that gets brought up quite a bit is having a kind of patient caregiver co-op dispensary you know I think that should be on the table for our exploratory committee next week I think I mean we can do a lot to kind of think about ways to really attack the kind of accessibility and affordability and quality of the program but I think we should move to kind of a discussion of some of these specifics and the specific recommendations and think about the direction that we want to go as a board so I'm happy to take any advice on whether you think phase one phase two approach makes sense and if so what should be part of phase one I'm happy to you know further kind of discuss my thoughts on on that but you know we should have a little bit of an open discussion about the whole thing I think yeah I mean I think you're right that the meeting our statutory requirement and making sure the rules are up-to-date and consistent where they need to be with the adult use is a good phase one and then phase two I think is really like you said reimagining the system that it works well for everyone yeah I agree I think that makes sense I want folks to feel like they're left behind I think you know as I look at these recommendations on the whole I think they they move the program they move the needle there's some stuff that I want more information into the process on from the medical subcommittee and also to hear I mean we've heard a lot about I'm thinking specifically again around this caregiver conversation and I've said publicly in meetings that I think the ratio needs to move off of a one to one ratio and the guy said that I don't want the word near not Julie I think you have said that as well and so and you know quite honestly the optics of the subcommittee don't do it any favors as to understanding why they don't want to move the cultivation side of caregiving off that one to one ratio so I didn't know if if you recall any of their thoughts as to why that shouldn't move because we hear a lot or at least I've heard a lot you know there's a lot of really great caregivers who can grow for medical purposes in this state that are registered what happens if something does go wrong like it does from time to time with everybody from a grow-up perspective that there is some type of you know past issue whatever the case may be that that loses that patient the ability to have that kind of same relationship with a caregiver why can't they receive product from more than one caregiver why can't one caregiver you know provide product to more than one patient I'm really just at a mental block as to why that's why that's not a good idea I mean the conversation that I heard really was around you're creating essentially you have your regulated market where people are getting licenses you're subject to testing requirements they're subject to kind of getting licenses around retail and then if you allow this kind of expansive you know patient to caregiver ratio you're essentially saying because the caregivers won't be subject to those I mean we then all of a sudden you're having a caregiver for potentially I don't know the number that I hear is one to five so five patients let's just use that as an example five patients they can grow you know 10 I guess 10 mature and you know 35 immature plants and they're outside of any sort of real regulations so none of the testing none of the kind of product safety consumer safety issues are involved and you know they're not paying a fee for this they're not paying taxes on it they're they're really just kind of an unregulated piece of our regulated market right and so you know I agree with with some of that because when like my whole thinking is that when these things start entering the chain of commerce that's when it turns into a consumer safety issue when these cannabis products and that's when we really need to we have a responsibility as a board to take care of our most vulnerable the most vulnerable asked for the consumers of this product so I don't have a problem with increasing the patient to caregiver ratio I do think that that will trigger us to create regulations around additional quality control regulations around what that looks like yeah I mean I would agree with that I think we go too high then we run run the risk of quality kind of taking a dip I think it's it's no matter if it's cannabis or anything else you can be really good at doing something in a small batch that doesn't necessarily mean your skills translate to doing it at scale and that's just the way that it takes time it's learning curve right I think if we go too high on that ratio count we could run into problems but I also fear you know the narratives out there that we're not going to be able to change at least initially is that there's people that just don't frankly trust the dispensaries for one reason or another so if they can't get their product from a registered caregiver are they going to turn to the to the illicit market or are they going to go to the dispensaries to get their product in that situation I'd rather just raise the caregiver count at least you know off the one-to-one ratio I don't I don't necessarily have a magic number in my head at this moment in time I'd love to hear you know comment on it or have more discussion on it but I'd rather than be able to go to somebody else that is least has least come forward to us and registered versus you know getting it from somebody who has not taken those steps to to show that they're not trying to you know pull a fast one on somebody who's part of the sensitive part of our community to your thought Kyle about you know what will somebody do if there's not if they can't get enough or get the right thing from their caregiver is it within our purview to say whether or not people can use their medical cards at adult use retail establishments without tax or is that something that the legislature would have to do you know I don't really answer that but because there are because there are I mean I think it would depend on how much we expand the registry or allow loosening of the like on ramps into the registry because then there are kind of general fund implications for that I think the legislature would say that it's in their authority but I don't know for sure because it it could be one possible solution to the problem that you're presenting yeah and and again the optics of the subcommittee and their makeup do not do that one keeping that one to one ratio any favors regardless of the merits of that recommendation and that's just the reality of it so I just wanted to understand a little bit more as to why versus yeah you can let caregivers come to us and get product for people but we're not suggesting that you can do more without us being part of the system you know what I mean so I just wanted to and in all your points as to why the decision was likely made make logical sense but in the you know in the mission of trying to keep continuity and allowing folks to get this on their terms versus our terms from a certain perspective right you know I think of that ratio adjusting it might be you know better for everybody yeah I think we need to adjust the ratio yeah or should adjust the ratio and I don't have a magic number in my head no I think if we go too high it's testing's gonna have to happen or something along those lines and there's gonna be more quality control but at some point you're creating another small business right so I'd have to think I think this is a phase two conversation right but it's kind of how I feel if we go above anything beyond like one to one to two that we should really think about having a cultivation tier that's specific to medical like a 25 plant or something like that that is or 50 plant that is specific to medical and it's subject to the regulation for the dollar market and then that kind of you can't have that conversation without then thinking about well should we then also have a medical co-op you know where a lot of growers can then you know centralize their product and you know have some shared resources and should that be subsidized by the cannabis fund I mean these these issues for me are all interrelated sure yeah well what else do you think we should do with respect to my broad bucket which is ensuring that current patients are held harmless we have the by the onset of adult rec and I should finish my sentence there and just to be absolutely clear about what I mean is that the dispensaries are allowed to sell their medical products on the in the through their attain the kind of non prohibitive ones on the adult rec market and so we need to make sure that the patient the current Vermont patients that are relying on those products are not going to show up and you know someone on the adult rec side is clean out the shelves right I think that was kind of my question about the use of the medical card at any retail location right with the tax benefit right because when you're purchasing medical cannabis you're not paying the that's any taxes right right no sales tax right no excise tax so I mean allowing people to purchase anywhere with a medical card you know means that they might be able to get it closer to their home right now only have I think five or six locations in Vermont they're not necessarily spread out evenly geographically evenly so it would allow people to be able to have more access um and should there be an issue with a medical crop or something happens to one of those businesses there's still other options for those patients maybe not for some of the specialty products right but for I'm not quite sure how what they're I think they're taught selling products are the flower and sort of the cartridges right so they're not those might be specialty products so the impact might be less yeah right if there's an issue um and I think that is the three month I mean we've all kind of agreed to that all right the three month supplies we think they're that satisfactory how what does that um do in terms of like the production of a product so it's three months of biomass but not necessarily like finished product right that's right um so there is I mean it's an issue that was raised that you know if I need some specialty concentrate maybe it won't be ready on the day that I need it so I think that there is you know I think most people that use those are pretty consistent with their purchasing habits because they treat it like medicine and so I think the the dispensaries are going to be I think that was part of that data ongoing data requirement just to make sure that the dispensaries can anticipate the kind of purchasing habits of their patients and make sure that the products are ready and available for them when they when they ask for them. So go back. No please. So back to this um and I don't know if David or friend have looked this question up since you brought it up but the testing requirement being a statutory role uh for the medical dispensaries needing to test from at other dispensaries versus third party labs that's something we would have an ability to do so there is a there is a requirement in statute the statutes that take effect in March um actually I think they're in effect right now that everybody has to have independent testing there there has been a question that's come up um about whether that applies to the integrated licensees but there is a statutory provision that provides that applies to everybody and I can find it. Yeah and it applies to the dispensaries as well. It does yes um it does and there's no conflict there I mean I know we're not clear on whether or not that's by statute of our rule but there's no conflict with uh and dispensaries can only share products with patients and other dispensaries right and that I'm not sure if that is in rule I do not I haven't seen that um in statute but um okay I can kind of find out where it is I'll let you know I just if we can allow dispensaries to use utilize third party testing I think it could amongst some bottlenecks at dispensaries but also give try and okay try and get back some trust that may have been lost from the public with dispensaries by using third party testing yeah to the extent that we're able to. It's 7 BSA 908 F is the requirement that campus products have to be tested by an independent licensed testing laboratory. So what do we think about the annual renewal for people with incurable conditions? What is the current cost is it $50 for the card only or is it is it is there another fee? So Lindsay I think it's $50 annual right for the card all right and then you would have to pay whatever your doctor requires for the doctor's visit to certify right? Well a lot of them build the insurance because you know if you're going to your oncologist for a regular checkup or whatever right because they built the insurance for that insurance won't cover you know doctor pot you know that that's the only service that he's like providing his was there any discussion about that insurance in the set not to deal with this is about insurance the workers company and horses in the subcommittee? There was not of course that's a tricky subject to unpack whether there should be I think New Jersey as a company that will insure people for medical marijuana yeah but I don't I think it would have to be insti yes yeah I'm just throwing it out there in my wish list yeah yeah I think it makes sense to waive the annual renewal for incurable diseases yeah do we want to distinguish which of these diseases from the just conditions I'm trying I think that there aren't very many on there that are curable right they were obviously the long-term it's gonna take me a second because I I am put out the list but I oh wait I think it's on the document print set okay is it on here Bryn? so when it comes to the kind of it seems crazy for us to just have a subset of these I think the only one that is ever really given anyone any sort of problem in the legislature is the chronic pain I really think that's the one where people say well that's by definition you know not incurable I think the definition is like sustained pain for three months or longer or something like that so yeah I don't know usually chronic pain comes with something else right it's not it doesn't generally just stand along so I don't know maybe we can just have a longer discussion about this but I think my recommendation would be we kind of have some sort of reduced application and fee requirements for for all of these except for chronic pain yeah and that makes sense I'm just thinking like you know I have trouble getting to see a doctor I mean maybe it's because I don't have any of these debilitating physical or mental issues but you know getting to see a doctor every year and for folks that may be suffering from one of these it might not be easy to get to your doctor physically you know what I mean so does chronic pain have to be every I mean generally if you have chronic pain like I said it comes from something else yeah long-term injury or you have some other illness like I don't even know if you would need to do that every year we have two years I don't know if we can make that change I think we can yeah I mean there's fiscal impacts to this but again like the program has been running a deficit or a positive in the positive for so many years that we should really I think maybe dig into maybe a little bit of the financing to see what the fiscal impact would be and there's but I uh I do think that you know someone with Parkinson's he's not going to just one day wake up and the Parkinson's is going to be gone you know to me having it having that have to have an annual renewal it just doesn't make a lot of sense my only other sort of devil's advocate thought is if we don't change that and people still have to renew every year and pay the fee every year we could have a plan for what to do with those funds that's useful to the patients whether it's some sort of medical education or education for medical providers or something like that right well I guess that ties into my other question which is should we just propose a reduced fee period for everyone just $50 now let's just cut it in half or something and again like it speaks to the issue just raised which is if there if there is extra money maybe we can use it for something that benefits patients or benefits the program but I also don't think you know this is the type of fee that should be set at exactly what it needs to be to cover the costs I guess my only like overarching thought is is it the fee that's the it could be the issue or is it the process and the physical having to go see your doctor that's the more of the issue if it's a $50 annual fee that doesn't again I mean $50 means something different to everybody right but it doesn't seem like it's overly burdensome necessarily more so than the the paperwork the visit the everything that goes along with going to your doctor seems like it might be the higher hurdle to take it over so maybe there's lower in the fee and the number of times yeah number of times that you have to renew maybe it's every two years you know for for chronic pain or something like that yeah and I do believe just as a side point but I do believe that you know there's certain requirements on which types of doctors and where those doctors can be located I think they allow doctors in New Hampshire in Massachusetts in New York but they and but they also allow telemedicine for those doctors as well I think um all right what about if we just saw something on your list right here going back to the caregiver I think it's what two mature plants and seven immature plants per patient yeah I think if we are interested in raising that ratio we would have to look at raising that again I'm worried about crop failures right that are at no fault of the very you know expert growers that we have is in the caregiver program we need to raise those yeah those at all even if we leave it at one and what do we need to raise I mean I do sort of think that you know this was written several years ago right and a lot has changed and some of the you know fears perhaps that were you know addressed or problems that we thought were going to occur when this was originally written maybe they didn't didn't well out and I don't know that we need to be as concerned about patients growing for themselves three or four plants you know having three or four mature plants at one time if they need it for themselves they're not and we're having a dog market yes and since then you can now you know if you can grow and give it away to your friend yeah and I know we've had these discussions and heard from folks members of the public on their thoughts on specific numbers if they're going to be adjusted and I don't have all of those in my head I guess I'm saying I'm open to the conversation of raising them do I have the magic numbers off the top of my head at this moment in time no but you know it makes sense to me yeah yeah I think you can't separate this conversation from the patient caregiver conversation which we have not but I just want to make sure that's clear because there is a fear and I've seen this play out in the legislature over and over again that when you expand either patient caregiver or plant cows that you get into the situation where you know people aren't really thinking about crop failures or you know things like that they're thinking that these folks are trying to skirt the regulated market and so while I don't necessarily agree with that I think that because this is statutory yeah we need to really think about where we want to kind of put our I mean we can make the recommendation of course but you know I think that we are less we are more likely to lose on both than if we if we recommend both than if we kind of aim our kind of recommendation at increasing one or the other you're suggesting that we pick our arguments yeah yeah sorry yeah it's very concise wait what I said yes I understand what you're saying and there's a lot of track buckets to keep in our head and I'm sure everybody's had them but we have immediate control over what we need to make recommendations on and we'll have control over some time I'm sure we'll hear a public comment on what is most important and that would be helpful in terms of deciding which of those things are most important for us to put on and just yeah just going back to the May 24th meeting and you know we did hear that the two to two and seven was inadequate we heard that over and over again actually from patients you know Eric St. Croix I don't know if you remember him he was caregiving for a very young child and he said the two and seven was not enough and that was in addition to buying two ounces from the dispensaries growing the plants and then having to supplement from the illicit market so yeah I mean I'm very sympathetic to that I just I have a feeling that we might lose everything if we try and change too much in this kind of phase one this and the other side of that right how about the fingerprint requirement that goes away right so we actually or no that's not that does not go away yes that starts on us yeah so I feel very comfortable removing this just as a baseline we again can still do Vermont supported background checks you know in-state background checks if we want to I don't think that there's ever been an issue on the on the caregiver side to date I won't ask you that because it's probably confidential but uh you know just given the close relationship and if we recommend increasing one to two I don't feel like that should trigger any sort of fingerprint either and that's a legislative we're making a recommendation to the legislature right that's not a rule that's we would have to ask for that to be removed I agree I think it's it adds a burden that's unnecessary yeah there is an adult abuse registry as well that if we could ensure that we have access to that as well or someone could do a check on that then maybe that would kind of really be a backstop backstop to just getting rid of this is that like folks that have taken advantage of senior citizens yeah I think it's I think it's probably elder abuse elder abuse registry yeah that exists is it just elder abuse or is it any vulnerable adult I think you're right it's vulnerable adult yeah is that something you think we get access do we as a board we get access to we would need authority that's probably also a statutory fix okay I think that's the main reason for this I don't think I know that you know there's certain disqualifying crimes in the current statutes we probably are going to loosen up a little bit I think you know certain drug offenses are disqualifying for caregivers but you know we can have that conversation I think we would probably just follow the rules that we have for adult wreck on disqualifying crimes and apply that to caregivers yeah that makes sense to me what else do we have here so debilitating medical conditions obviously this is every single time a new one gets added it's a multi-year process um and it usually takes a lot of witnesses coming in and saying why this is important it becomes very political very quickly so why really do I really do like the path that a lot of states well a handful of states have done which is if you're going to prescribe an opiate then you also automatically you know are eligible to be on the registry I think that that could get go down a path of us having to really show science that opiates good science that cannabis is a substitute for opiates I think we would need to have a very strong kind of um you know evidence-based reports on that and I just I know that they're starting to come online it was kind of longitudinal studies but they're just not at a point where I think the legislature is willing to kind of make that take that uh as kind of gospel it just seems like we've heard from so many people who have we have have successfully moved from opiates to cannabis or have been completely clean after moving from opiates to cannabis yeah well I mean that's what I'm talking about it just seems like we've heard from so many people both in who are willing to comment it publicly and people who told us I think personally and privately so I don't know I um that one is the one I think is the most important to add really and it would would it be if you're getting prescribed an opiate um or would it be I'm thinking more about um substance abuse substance use disorder yeah substance use disorder but I mean both I just don't know if that's an actual medical diagnosis we could find that out we have the doctors willing to kind of say this person has opiate use disorder it sounds like an official medical condition because again it's gonna have to rely on a doctor verifying that this conditioning is present and then there's of course though you know the other factor is like does this apply if you have opiate use disorder and you're under 18 or under 21 is it the same as if you're over 21 I don't know I mean we had deaths in Chittenden County of kids over under 18 you know that could have avoided like that's where I mean that's where the you know there are people at the end of this you know I was just and I know this isn't kind of our problem to solve and it kind of ties into number five but I remember in our May 24th meeting we were hearing from patients whose doctors were not willing to sign the papers for people that were under 21 even if they had one of these qualifying patients I mean you're right I think that's a bigger problem than we can solve at least we could include opiate use disorder if it is a condition and how do we feel about sleep and anxiety sleep disorders I would just say historically it's been a non-starter but maybe in this new world we live in I think you know I just feel like again we got to kind of focus on what we can achieve this just and we have to kind of push everything through the lens of aligning with the adult rec program no more restricted than current and how do we protect patients during this time I think those are the kind of three pillars of the arguments we can make to the legislature that hold a lot of kind of you know good will and so if we try and go too far beyond that and we don't have we can't rely back you know fall back on those justifications that we're not going to be very successful on these more kind of contentious issues I think that makes sense I'm worried that the legislature might just say for sleep disorders and anxiety when can't they just go buy it on the red bar and how much do you versus us taking your battles I think I care more about the issue that we have then not to say anything against the medical conditions of anxiety or sleep disorders buying stretch but recognizing off points and there definitely could be some interplay between those right um reciprocity um reciprocity to me makes sense up until we decided to co-mingle the canopy for the dispense the dispensaries and the integrated licenses you know the the whole idea that why people are asking for reciprocity is really one you know the dispensaries wanted it because then they have a whole new patient base but if their canopy is going to be kind of fixed and it's going to be intermingled and it doesn't really matter whether they're selling their I mean as long as they maintain sufficient supply for the patients it doesn't really matter whether they're selling more to out of state or in-state patients or out of state patients or adult rec customers so that kind of to me eliminates the argument that they're making in favor of reciprocity at least in this early phase in the downside that I see the reciprocity really is that it continues to erode that three-month supply that's set aside for Vermont patients um you know someone from out of state is coming in buying tax-free for something that's been set aside for a Vermont patient and you know that you know the tax revenue that's being generated from the adult rec sale is being reinvested in Vermont I mean so it again kind of eliminates that revenue source for programs prevention programs after school programs and whatever else the money gets spent on so to me I don't like reciprocity it's nice for people that have second homes um in Vermont that are patients elsewhere but I just to me this isn't the top of my priority once we made that decision to allow the dispensaries to kind of commingle their inventory so just because it's lost in in my my mind because reciprocity to me means somebody can come do something here I can go do something there right you know what I mean so and I don't know maybe this is a question for Lindsay sorry keep putting Lindsay on the spot can can folks and I know we might not have any control over this given we don't have any jurisdiction beyond the supporters of Vermont but kind of medical patient from Vermont go to another state that has medical program if their state allows it if their state allows it and it's not contingent upon us having reciprocity with them it's that was my big question reciprocity may not be the right word because it's really not I'm thinking in terms of my tomorrow's right yeah um because that would be my my bigger concern here versus your your points where I'd like to I understand I mean I'd like to hear public comment on you know folks coming here more public comment on folks coming here and using their medical cards but recognizing that tax revenue will stay in Vermont and be reinvested into Vermont versus having tax recantilists folks that are not Vermont residents or not other Vermont medical registry you know I think that that makes sense but reciprocity is our rules list not our legislative request right I think that's right and so reciprocity also you know from a patient side you have anxiety it's that's a qualifying condition in Maine you go to Maine get your car there and then come purchase here in Vermont I mean you know it's a way to kind of loosen the program without actually having to kind of go through all these legislative steps so there are there are benefits to it you know I think there are patient benefits to it but again this this just I think you know is not high on my list of things that we need to do in phase one when we're literally just trying to make sure that patients are remain remain whole the current patients that are reliant they have come to rely on these medicines this is like an expansion of the program pretty significantly yes and if it's done by a whole that means that we have a little bit more control over when it happens right so if we decide we need to move on I mean if you look at our mission which is to maintain the integrity of Vermont patients and the Vermont medical program I don't know if this does rise to the top of the priority sheet just given that that mission itself how about the redefinition of registered caregiver I know we talked about expansion of the ratio but do we want this bifurcation I know that I can't quite remember the reasoning but I know that the Vermont patients Association Amelia and Jesse Land and Jeffrey and others really did not want this bifurcation to happen I just wonder if their rationale changes or if anyone's rationale changes if we are expanding the designated grower one to two and then having an unlimited number of these other types of caregivers that are administering the products to you know internal patient and again just they actually the legislature a few years back did expand the ratio of registered caregiver they didn't do this bifurcation for children under 18 just because sometimes they're living in two homes and they need two different caregivers so there is a recognition at the legislature that some people might need kind of more around the clock or kind of more access to people that can help administer the medicine but for I shall make sure I understand so for children under 18 like the dome that that testified to us he was growing right but then that child potentially has two parents would they have three caregivers no so he he just because I watched the video yeah he actually had to give up his caregiver card his caregiver authority to dad at a certain point when they kind of had two houses okay so and does that mean he cannot so he couldn't do anything lately for that patient anymore okay I think that patient also stopped using he would I mean we don't have to go well it just doesn't for instance there isn't a pretty easy scenario where someone might need more than two or three yeah is it going to be confusing to people if we have two separate it will be confusing definitions of the word caregiver yes I'd like to hear more of a comment on it before I kind of yeah I would rather increase the care or advocate for increasing the caregiver number than just leave the definition alone and increase the overall ratio yeah yeah okay sure maybe somebody in the audience will give us some thoughts on that yeah Bren is there anything that we're missing that you and I have been talking about that you can remember um from the any of the subcommittee hearings or anything that I missed on this kind of immediate phase one needs did you talk about the amount that a dispensary can provide to a patient at any given time did you all right at any given time or on a monthly on a monthly you know there that required that two miles limitation for months right yes and that's right here purchase caps right so um right I think the purchase caps two ounces per month I think you know that should just go by the wayside we should just peg whatever purchase caps we have on the adult rec side to the medical side just in keeping with that kind of directive should we leave it for products that are specific to the dispensary or have a certain amount I don't want people to buy products of the dispensary that can only be purchased there the special products have an opportunity to move them into the or is it okay well it's interesting because I don't actually think that you know one thing that we heard over and over again is that there's no like comparable chart so like two ounce limit also means two ounces of concentrates which is much more than two months is worth of flour you know so I don't know about the answer to that why don't we focus right now first yeah on the easier question is to the per visit area I don't think there needs to be you mean the per month limit let's do just like per visit per transaction limit which I think on the adult rec side we said one ounce or the statute says one extra visit and the statute says two ounces for patients for patients so I'm fine with two ounces it puts them in a little bit of legal limbo with kind of an overzealous police officer who might want to pull you over and say why do you have two ounces it's a civil violation the likelihood of that happening is probably pretty minimal so we can do two ounces per visit sure and then how about month any monthly caps that we care about okay except for products that are prohibited on the adult rec market or is that overly prescriptive where we get to like well I don't think it's overly prescriptive for now I know that we've recommended some changes to the adult use market so maybe it doesn't make sense to do that well you know those are the those actually are the products that I'm most concerned about because the patients can't get those other places and if someone if they've got a three month supply set aside for the remote patients you know one patient says well I might just buy a year supply right now just so I don't have to come back to this dispensary for the entire year and then that wipes out that entire three month supply for the entire registry maybe it makes sense yeah yeah that's concerning I don't think people should be able to walk out of the truck of so it does tie into the question about do we want to get into a comparable chart or like kind of a uh like how much how much of I think we heard from the dispensaries that they would like a comparable chart as long as I'm not responsible for that math I think that's fantastic and that probably exists somewhere I'm sure we know some folks that can help us out so why don't we think a little bit more about this and give you a recommendation Brynn for next week okay does that sound all right I hope some other state has a nice chart that you can but I think the basic thing is if it's prohibited on if it's a prohibited product in the adult rec side that there should be some sort of monthly purchase cap yes I think that's what we're saying yeah okay I think that makes sense so why don't I why don't I bring the comparable chart to the next meeting okay all right and we'll probably need that for the adult rec side anyway right yeah do you remember anything else from just any of our conversations that we haven't discussed um I from what I heard the you all discussing I think you've hit it all okay anything else that you either do you think that we need to kind of think about for a phase one kind of overall not at this point okay some some comments I'm sure we'll hear some of that next a couple days do we want to think about a phase two right now or should we kind of just keep our eyes set on what our most immediate goals are I think we should do the most immediate goals okay right because we have rules you have rules to write yeah okay we're being the royalty all right well then um that's the end of our agenda other than public comment so why don't we go ahead and move to public comment um let me just uh get rid of this screen share so if you've joined via the link and you'd like to make a public comment please we'll start with the people that joined by the link please raise your virtual hand oh why don't we start with the people that are uh that joined us at our physical location okay okay well then we'll start with we'll move to the people on the list uh they're joined by the link and then we'll move to the people that joined by a phone um so Amelia first yeah hi guys so a few thoughts but I'll try to keep it quick um first just responding to the most recent thing that uh gave me pause no after hearing all of this I still do not support bifurcating the definition of a caregiver um I don't think that that is going to help patients I don't think that that is going to help caregivers I think that that's just going to create unnecessary confusion and I think that even if we allow two caregivers per patient and we up the patient plant counts it's it's unnecessary to bifurcate the definition of caregiver my solution or my suggestion I would say to kind of helping with this caregiver quandary and the patient to caregiver ratio etc um I briefly spoke about it the other night during the public comment meeting uh but I've had a few days kind of get my thoughts together about it and talk to Jeffrey um who just kind of helped me solidify what I'm thinking of I would like to propose an additional medical license type that can be made available to somebody with a pre-existing license and this license would allow somebody who already has you know one of the uh grill licenses to provide for up to five patients it would increase their plant count per patient and they would be able to either sell at a at a much lower cost than the dispensaries or give for free medicine to the patients and that is how I see us not creating an unnecessary regulatory burden on existing caregivers and we don't have to change the existing definition of a caregiver. Amelia can I ask you a quick qualifying question when you said somebody who already has a license are you referring to somebody who has a caregiver license or are you thinking somebody who might have an adult use cultivation license somewhere down the road that might be able to get a supplemental license to then sell as a caregiver from their their adult use cultivation license? I'm thinking a supplemental license to the adult use licenses which I feel like you know given that one of your missions is that you want to keep adult use in mind as much as possible as you move forward with this medical regulation I think that makes sense to me um and I know that part of part of the discussion around all this and part of the confusion is how are we going to expand the caregiver patient ratio while also keeping in mind patient safety quality control all of these things if we look at what is being proposed for these adult use cultivation licenses there's already regulations in place for safety for testing for your environment and those places in my opinion are the safest environments for us to be then handing over patients to be um you know cared for and grown for so that that's just my thought it's not fully fleshed out it's something I've only just thought about in the last couple weeks but I think it is a really good solution to giving patients greater access to caregivers giving caregivers greater access to patients by upping that ratio and ensuring product safety and product quality all at the same time and we have so many adult use licenses but we only have like two different medical licenses and that's either you're a caregiver who provides product for free to one patient or you're an integrated dispensary license and I think that there is somewhere in the middle where we can meet where we have these extremely talented craft cultivators who I've I've spoken to so many of them they want to help patients they're willing to help patients and if the infrastructure is there for them to lean on to help patients they're going to take advantage of it and they're going to become a part of the system we just have to give them some way to participate um so that's where all of this came from and I know it's not perfect and I know that it needs more discussion but I think it is a way we can move um to kind of come up with a solution to this problem of wanting caregivers to have access to more patients wanting patients to have greater access to caregivers and to higher plant counts in a medicine that is clean and regulated um without creating an unnecessary regulatory burden on moving back to the existing definition of a caregiver I still firmly believe that a medical patient should be allowed to have three cultivating caregivers so upping the ratio from one to three and caregivers should be able to have multiple patients now I understand that having the security of clean regulated safe medicine is hard the more patients you give a caregiver I understand that that's part of the problem here so I don't know that it needs to be five patients per caregiver but I think that one to three is fair and valid it just it's all about creating more affordable access to medicine that's the bottom line that's all we're trying to do and I think like you guys all agree with that too um so yeah that's just where I am on that rant um my other point was I actually was the one who proposed eliminating the uh need to renew a medical card if you have a chronic illness and I propose that because I have multiple chronic illnesses um two of which are incurable the the language that needs to be changed I think and I understand what you're talking about James when you say that if we just allow a doctor to decide doctors might just decide not to do it I get that I think the language change that could be made there is instead of having a list of conditions that qualify you for a card a list of symptoms where if your condition falls within this list of symptoms that qualifies you for a card I think that makes more sense because we have things that cannabis are proven to alleviate the stress in symptoms of appetite insomnia pain you know we have these conditions and the reason that we've singled out certain conditions is because they have these symptoms so the reason that cancer patients are allowed access to cannabis is because it helps with appetite insomnia pain you know so I think that just kind of moving forward a language change that we can make in the proposed regulation is instead of saying allow a healthcare professional to provide a card for any condition is allow this set of or allow any condition with this set of symptoms or with one of these symptoms to qualify you for a card um and yeah I think that's it for now if I think of something else I'll get in the queue at the end thanks Amelia next we have Ben Mervis hi everybody happy friday um I just wanted to share some comments from the point of view of the retail experience um you know as as you all know we my business partner Craig and I are interested in entering retail and also delivery um and so just looking for clarification in in along the way with regards to this idea of medical products versus adult use products and also hoping that medical patients will be able to purchase adult use products and have the taxes waived on those products um also in in the same line of thinking when we think about reciprocity I will say it is one of those rising tides that raises all ships on a recent trip to Maine I was with a friend who does have a medical card from Massachusetts Maine provides reciprocity um you know we may not have even gone into a store if it weren't for that fact that my friend was able to purchase and have taxes waived um and we even then separated our purchases even though we could have had her purchase everything just out of fairness um myself and another friend purchased of our own volition paid our taxes to the state and so the retailer was able to get three purchases one untaxed two taxed out of that as opposed to what might have been zero purchases if reciprocity was not a factor there um so that's just something that we hope for and again clarification on this idea of medical specific products which I know there will be specific medical products but we do believe medical patients should have access to the adult use products and have the taxes waived and that's all I want to share today thank you so much for your work thanks Ben uh next is Jeffrey Pizzatillo good afternoon can you guys hear me okay yep yeah all right thank you um I want to say thank you for adopting some of our concepts and policies in this medical cannabis discussion not all but some of them really appreciate it especially around access um I want to point out just two quick points I would urge that for if you guys take a two phase approach um I would urge you include an increased plant count in that phase one I think that is vitally important um we've been stuck with two plants since about 2009 uh so we are way past due it is a top priority for the medical cannabis community and I would just like to point out we currently have for mantras in the state getting arrested still guys for cultivating more than two plants and some of them are registered patients and caregivers um this is still currently going on albeit it's no longer maybe a top priority across the state but I want you to be aware of this and so it is a priority to increase the plant count we are suggesting 10 mature plants uh from the Vermont cannabis equity coalition which includes Jesse Lynn Dolan at the Vermont cannabis nurses association and Amelia as you guys know so that is our recommendation we would urge you to adopt that in phase one my second point is a couple months ago uh when you guys were having a medical cannabis discussion before the board uh there was talk about the future oversight committee and uh my organization was named and I think you guys raised an excellent point which was avoiding specifying enumerating a specific organization an entity in rule and statute I would ask that you apply that to the Vermont cannabis trade association uh please we urge you keep that standard for that you apply to grassroots trade associations and keep that and apply that consistently to the corporate trade association statements thank you very much thanks Jeffrey uh next is Tito Bern hi everybody um so um I like what Jeff was just talking about and also I have to second what Kyle said earlier about the makeup of the medical board the only member of this Vermont cannabis trades association as far as I know is Champlain Valley dispensary and the biased decision making was glaringly clear at the subcommittee meeting that I attended but my main point that I really have to talk about is that I was really upset that I didn't hear anything on this whole meeting about the vape tax either from the marijuana symptom or grief oversight committee or the board this is a serious problem we have to separate cannabis from tobacco this legislation tries to muddy the water and include everything in both both things in this tax law and it wasn't intended for cannabis it's intended for tobacco vapes we have to get some language separating these two things um furthermore right now the current dispensaries are not required to pay the taxes on the same exact items that everyone else is required to pay the taxes on for the exact same items I mean it just it just doesn't make sense and then you know I ask the question you know will future dispensaries in October will they automatically be exempt from this tax um I just I gotta hear some some more talk about it um and I was disappointed to not hear anything so that's all I just wanted to say that thank y'all so much thanks Dio next is Francis Jenick Fran hello everyone thank you for having me to speak today first of all I'll second what Amelia said I do think that we should go from three to five patients if we can this allows somebody who's getting a license to actually have a small business so that they can charge a reasonable rate to patients but pay for their expenses I think that if we expand that then we will also increase the availability in this transition where you're concerned about availability for medical patients um secondly what you discussed today with removing fees for all registered patients I think that's very important most of your patients here are low income uh as I had spoken to you before myself included I had dealt with that issue so I don't see that when we can give away 300,000 here and 400,000 there from the medical program as we have previously that we should continue to charge patients in this manner now I've sent you guys um a little bit of a a note earlier today and as I listened to the advice given today I reflect on the history of our medical cannabis program where Monique and Colliff opened Vermont Patient Alliance in Montpelier I was glad to be there to share my experience and expertise in creating safe effective and affordable cannabis therapy products a group of medical patient growers including myself advised on growing cannabis and taught the first grower how to make RSO for cancer patients and others with severe disease over the years I've been informed by both employees of the integrated licensees and the patients who had chosen to rely on this limited system both groups have reported and I have witnessed extremely disturbing events as I had informed you in a recent public comment meeting there were documented instances of willful disregard for patient safety and violations of both MJ program rules and state and federal laws including possible criminal action by principal officers of then Champlain Valley and southern wellness although these issues were reported by legislators to the Department of Public Safety in a timely manner no action was taken to remove the licensees due to a lack of effective can of an affordable and most important safely safe cannabis therapy products small caregivers who share legally have become the backbone of our cannabis therapy program serving far more patients than those who have cards some registered patients have gone as far as Canada and Maine to acquire needed cannabis therapy I testified before House committees on this matter it is my hope that we recognize the important contributions that small caregivers have and continue to provide in Vermont in need to Vermonters in need so thank you for taking my comments today thank you next is Dave Silverman good afternoon everyone I'm going to go a little off topic I want to give you some very broad initial feedback on rules one and two that were that were released and I'll keep this very high level and you know of course we'll get you very detailed feedback in the coming weeks this is based on initial discussions with some of my cultivation clients I think that a lot of what you've written specifically in section 1.4 and section 2.2 the all of the individual things you know they make sense I understand where you're coming from but when I take a step back when my clients take a step back and look at the totality of what will be required I think we're really far cry away from what Kyle described when you guys were all on on Vermon edition as an application that could be done without consultants and lawyers this isn't that and there's just in the aggregate the burden will be very very great and I've already heard from clients saying wow I may just stay on the black market and and that's that's not what any of us want so I guess that the feedback that I want you to take right now is but you know you have this 904a authority to grant waivers and exemptions and accommodations to the small growers the the tier one growers and I would hope that while you're waiting for public comment and while you're waiting for this rulemaking process you know to kind of play out that that you each take a little bit of time and think about how it is that you can exercise that 904a authority a little more aggressively so that this market can truly be welcoming to the folks that I know each one of you want to welcome into the market so I'll leave it with that thank you very much thank you Dave and Amelia I see your hand up we're trying to limit the public comments to just one per person otherwise this could just turn into a discussion among people in the public but we do have a if you could just either email Nelly or the board members your comment or put it through our portal we appreciate you know all the comments that we receive and consider them so if there's anyone that joined via the phone and you'd like to make a public comment please hit star six to unmute yourself okay then I don't have anything left on the agenda and so I will adjourn this meeting thank you everyone for for joining thank you Julianne