Patient Records being Sent to the DOR

[canaguy27]

Was talking to an MMC manager yesterday who was preparing her patient's paperwork to be sent in to the DOR for their records. Any others hear this first hand? She said it was her patients only and not just people shopping.

Maybe this is going to be how they get around the "confidential" database. If you shop at an mmc, the database can be shared with whoever.

 

[DoobyScoo]

To tie the plant auditors #'s to the allowed numbers for the MMC. They have to have their 'patients' sent to the DOR, would be my guess.
Otherwise how would MMED auditors know HOW MANY plants these MMCs can have?

I wouldn't be to worried, unless you make the MMC your caregiver, and don't want a Dept. of Rev. with that info? Trust me, the Government gets moving when money is involved. Taxes feed it, they want to make sure they get every Red Cent from these MMCs.

Now, moving info from the MMR to the DOR, would be a violation of the Constitution. They have pushed, but I don't think they will push THAT hard, not without someone crying bloody murder. [Edit: Someone respectable]

 

[eyecandi]

an updated patient list must be sent to the DOR each and every month (rediculous since they now only allow the patient to move a new MMC every 120days) from every MMC. it will also keep people from playing the 'sign up with an MMC of the day' game ... this screws the plant counts badly when the center isn't informed and can really bone things up. this has nothing to do with sales, as they will be tracking those #s through the software (wet weight, dry weight, trash, trim, product ... every fricken gram) ...... they want to eliminate those buying 2oz at one location and then hitting another for 2 more ...

 

[SoCoMMJ]

Was talking to an MMC manager yesterday who was preparing her patient's paperwork to be sent in to the DOR for their records. Any others hear this first hand? She said it was her patients only and not just people shopping.

Maybe this is going to be how they get around the "confidential" database. If you shop at an mmc, the database can be shared with whoever.

Really ? I call bullshit on this one.

MMC's aren't required to send their patients paperwork to the DOR.
The registry remains confidential and in the hands of the CDPHE.

Why are you trying to instill fear in an already nervous community?

 

[Texas Kid]

But that is exactly what the MMC are going to have to do ultimately, how else do you think the DOR is going to be able to track your plant count and on hand wieght? it will have to be reconcilled against your registered patients on a regular bases for sure...they are adding additional requirements every day, it is a living breathing thing now that has to be fed.

One thing I think is goin to be intersting is the dry wieght deal, 2oz per patient is not that much in the big scheme of growin. If you had 60 patients with their 180 plants in flower, you could still only have 7.5lbs on hand at any given time between your grow and despensary, so if you pull down a 8k grow your goin to get your max with every 8-10 plants you pull down, most of these places have 30-40k burnin so they will have a ton more sittin around screwin up their wieght. Even if the patients pick up an oz a week thats still under 4lbs a week or 20lbs a month out the door and in order to sell any eccess like the pervebial 30/70 rule says, you have to sell it out your door first, so if you are actually sellin the 20lbs a month you could possibley be allowed to sell 6lbs of that to other MMC provided your sales volume supports it. If you really start to put the numbers to it as far as grow output, patient count, plant count, etc...it makes no since at all, I mean one plant is goin to easily give you your dry wieght max for three patients at a time....I don't know, we'll see...

Tex

 

[Texas Kid]

Here is the latest I have recieved from the attorney core..they are starting to get alot of this ironed out now and the rules keep a comin....this is the July 1st mandate

Please find an attached copy of the interim forms that the Medical Marijuana Enforcement Division (MMED) has provided for all medical marijuana businesses to use until their final systems are in place. Please note that THE ONLY FORM THAT MUST BE USED IS THE TRAVEL MANIFEST, as many people have internal systems in place to meet the reporting requirements. Please review the attached as soon as possible and let us know if you have any questions. Please note that MMED indicates in the document that they will be performing inspections soon and have emphasized the following as “some of the areas of concern that investigators will be focusing on”:

Limited Access Areas Identified (Proper signs posted)

Properly displayed license(s) [local & state-issued medical marijuana licenses and sale tax license(s), as well as any other required license(s)]

All employees displaying proper MMED-Issued credentials

MMED investigators will be making observations regarding on-premise use of cannabis by patients and/or employees

Security Alarm System, which is compliant with MMED rules

Commercial-grade, non-residential locks, which is compliant with MMED rules

Video surveillance of all required areas, including areas where marijuana is possessed, stored, grown, harvested, cultivated, cured, sold, as well as entrances and exits with logging and limited access to equipment, which is compliant with MMED rules

List of all licensed employees

Diagram of licensed area

Proper record-keeping of patients and inventory related to patients (both plant count and finished product). Ability to demonstrate compliance with 70%-30% rule

Proper record-keeping of all sales (both to primary patients and other sales to non-primary patients)

Employees conform to hygienic practices

Preparation areas; surfaces, utensils and equipment are adequately cleaned and kept clean

Inspection of cleaning compounds, sanitizing agents, pesticides and insecticides to ensure that no banned and / or hazardous chemicals are on the premise

Waste is stored and secured in a manner which is compliant with MMED rules

Waste that is rendered unusable should be ground with non-consumable solid waste and disposed of, which is compliant with MMED rules

All product is properly labeled and identified for retail sales

Labeling standards from 7/1/11 rules must be met

Complete all sales between 8:00AM and 7:00PM (7:05PM is not acceptable)

Do not transport Medical Marijuana without a MMED approved Manifest in place


Tex

 

[Texas Kid]

More from the core

Q&A with Nick King head of MMED

From Nick King:



Below are some key questions regarding the new forms that we submitted to Dan Hartman for clarification. His answers are in blue. Hope this helps.

1. 70-30 compliance/check report - Is this for prior year (7-1-10 to 6/30/11) or current year moving forward? Calendar year or Fiscal? Rules say calendar year

2. Daily Patient Sales Report - Does this report need to be created every day? or only upon request? everyday, If you do it every day you will have the information to put on the Monthly report

3. Monthly Sales Report - Do these reports need to be submitted monthly or filled out and ready upon request? filled out and ready

4. Wholesale Purchase Reports - Do these need to be filled out daily as 0 if we did not wholesale any product? no, but may be helpful to know you didn't have any

5. Transfers from Grow Report. - Do these need to be filled out daily as 0 if we did not transfer any product from the warehouse? no, but may be helpful to know you didn't have any

6. Monthly transfers from grow and wholesale purchases - Does this need to be submitted to the department of revenue monthly? or available upon request to the DOR? filled out and ready

7. If POS system prints a report that contains the data the DOR is looking for but not in the exact same format, does it have to transferred to these forms? no, the forms are only a guide

 

[Texas Kid]

Once you go to a MMC all those privacy things are out the door...

The CDPHE registry is confidential but only for the stand alone patient that grows for himself, thats it, anything other than that ie..naming a caregiver in any way, weather its an individual or MMC you are out in the public domain..

Again, they way I see it, the only person in the program that can maintain some sort of confedintiality at all is the stand alone patient with no caregiver named what so ever. That is really the only scenario where the pure language of AM20 applies, all others seem to waive that right once you jump into the DOR system in any way.

Tex

 

[Texas Kid]

Here are the actual forms that are currently being required by the DOR/MMED and these are subject to change many many more times....

 

[Texas Kid]

And the rest

Tex

 

[canaguy27]

Really ? I call bullshit on this one.

MMC's aren't required to send their patients paperwork to the DOR.
The registry remains confidential and in the hands of the CDPHE.

Why are you trying to instill fear in an already nervous community?

What does she gain by lying to me? Hopefully you are not calling me one. most patients have no freaking clue on what is really happening. If they did and when they do, the mmcs wil start dropping like flies. The original registry may still be confidential, but the new one will be open. The mmcs gave up everything instead of fighting, and now they are getting fucked.

I am trying to educate patients on what is really going on instead of pulling the wool over their eyes like most mmcs. Several mmc owners tell me the same thing you did, which is unfortunate for the patients because they could really get screwed in all this. And for mmcs to purposely hide the info because the don't want to lose a sale is CRIMINAL.

 

[Unit541]

Really ? I call bullshit on this one.

MMC's aren't required to send their patients paperwork to the DOR.
The registry remains confidential and in the hands of the CDPHE.

Why are you trying to instill fear in an already nervous community?

If you look at the required reports that TK posted, you'll clearly see that yes, they are in fact required to send patient records to the DOR.

The daily report really bugs me. They just don't need to know how much of what particular strain a particular patient purchases on a particular day.

 

[sky high]

grow and share, folks.

Friends don't let friends buy (tracked) meds @ Centers!

question authority and rebel against it or be a slave to it!

Fuck the DOR. Fuck those in bed with the DOR.

wot a mess...

 

[putembk]

Good info, thanks Tex.

 

[coloradochem]

I used to work for a mmc so i signed them up as my caregiver, well i no longer work there or care to help them out. My question is, to revert back to self as caregiver, do i simply send in a new form or is there something else that needs to be done?

 

[ganjherbsmoke]

Soco u run an mmc and don't know this? How does that work...

 

[canaguy27]

I used to work for a mmc so i signed them up as my caregiver, well i no longer work there or care to help them out. My question is, to revert back to self as caregiver, do i simply send in a new form or is there something else that needs to be done?

fill this out and send it in. use blue ink and dont cross anything out.



If I were you, I would request the copies of my info that mmc had on file for you and destroy them.

 

[putembk]

Since an individual growing for themselves is the only thing not tracked and counted by the state I wonder how many lawmakers are dreaming up the next house bill to screw with them. I can just see a lawmaker at home at night sipping their tonic and gin. Probably thinking of how they can track our sales of nutes at the grow store.

 

[SoCoMMJ]

If you look at the required reports that TK posted, you'll clearly see that yes, they are in fact required to send patient records to the DOR.

The daily report really bugs me. They just don't need to know how much of what particular strain a particular patient purchases on a particular day.

Look at the form. there is no patient identifying information required. Only the patient's ID number.

The DOR cant violate confidentiality. No personally identifying information means no violation of privacy. Using the card numbers only they can track who belongs where and keep it discrete.

But, yes the reporting is retarded. WTF does it matter if they had maui wowie or AK to the state? They can't even print out an employee badge in less than 4 hours. How the hell are they ever going to look at this data.

 

[SoCoMMJ]

What does she gain by lying to me? Hopefully you are not calling me one. most patients have no freaking clue on what is really happening. If they did and when they do, the mmcs wil start dropping like flies. The original registry may still be confidential, but the new one will be open. The mmcs gave up everything instead of fighting, and now they are getting fucked.

I am trying to educate patients on what is really going on instead of pulling the wool over their eyes like most mmcs. Several mmc owners tell me the same thing you did, which is unfortunate for the patients because they could really get screwed in all this. And for mmcs to purposely hide the info because the don't want to lose a sale is CRIMINAL.

Not calling you a liar by any means, but check you facts before you spread them around. There is so much shit flying around now that nobody knows what is happening.

The DOR can not violate patient confidentiality. Period. Only the patient ID number is used. There is no patient info tied to that except in the department of health database, and by our constitution they cant share that.

However if a patient card number is pulling a pound a week from numerous dispensaries the DOR could relay that info back to the CDPHE. The CDPHE would then deal with the patient and revoke the card if deemed excessive. I suppose that could happen, but it still doesn't violate patient confidentiality.

I don't understand how you think that the patients are "getting screwed in all this" and what is is that they need to be warned about.

Perhaps you don't believe it, but everything is not about making a sale.

I think you may be going a bit overboard in your depiction of MMC's "pulling the wool" over on patients.

Can you even define what it is you are saving them from? Back it up with some of the regulations that define what you are claiming. I'll give you a hint... they don't exist. I have read them all, repeatedly.

So what is it.. what's "Really going on"?

:)