Patient Records being Sent to the DOR

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Texas Kid

Texas Kid

Some guy with a light
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The one thing that you should realize is that they have empowered the MMED officers as actual "peace officers" of the state, they carry guns, badges, and most are ex Denver narcotics officers, so all they have to do is pick up the phone and call the CDHPE and ask your name and address as it correlates to your registry number, just like the police can if they want to varify your participation in the program. DOR, MMED, and Police will all have essentially the same powers when it comes to gettin information on individuals and enforcing the laws of the land.

There are definately despensary owners and emeloyees out there minimizing or even denying that these intrusions are happening, or even possible for that matter, to thier patient base. My guess is to keep them coming through the door and buying their product. I have personally heard them even demonize the entire caregiver program in favor of their despensary model to their patients...misinformation is definately flyin all over.

Simple truth is that if you shop at a despensary, your activity is goin to be tracked......period...that is the sole purpose of this program

Go buy a few to many oz's in one day and see how confidential your identity is, they will correlate your name with the registry number and come a knockin at the despensary or possibley reject your membership to the registry all together and pull the despensary liscence. Hell, they will probably ask ya to work for them in a sting on other despensaries or something.

Nothing about the registry is confidential, they do give you a unique ID number to use instead of your name but that is in no way confedential. Confidential means nothing you own, say, or do identifies you to being involved or participating in the group. Just having to tell people your in a confidential group destroys the confidential nature of the thing doesn't it? And having to prove that you are part of of a "confidential" group violates the very concept of confidentiallity right?

July 1st will be the start of the fun, I really expect to see some folks doin the perp walk on tv about then, should be entertaining for sure.

Tex
 
sky high

sky high

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Simple truth...if you own, work for, are anyway connected to, or shop at a dispensary...

You are aiding the STATE in reeling in this entire program in for the profit of a few.

If you can't see that, you are a part of the problem. (the problem being a loss of constitutional rights to create and support your monopolized money scheme at the expense of all patients)

Hopefully the Fed will adddress all of this soon.

wot a mess...

s h
 
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mendel

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Hopefully the Fed will adddress all of this soon.

yea thats what we need, some fed regs to go on top of the state regs.............:sign0065:

Govt cant fix the problem, unless they commit suicide.
 
Unit541

Unit541

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While I do hope this is the only time I see these two names together, there are waves being made at the federal level:

Rep. Barney Frank (D-MA) and Rep. Ron Paul (R-TX) will introduce "bi-partisan legislation tomorrow ending the federal war on marijuana and letting states legalize, regulate, tax, and control marijuana without federal interference," according to a press release from the Marijuana Policy Project that just hit my inbox.
http://reason.com/blog/2011/06/22/barney-frank-and-ron-paul-will
 
sky high

sky high

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yea thats what we need, some fed regs to go on top of the state regs.............:sign0065:

Just so i'm clear....I'm talking about the DEA making their presence known to end the commercial side of this (DOR) equation (as threatened)...not more regs.

no sympathy here. Fuck em all.

be well, bro

s h
 
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DoobyScoo

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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.

It looks good on paper.
Costs a lot of money (er, "creates jobs").

In Government that = 'Successful Legislation'.
 
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DoobyScoo

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You are aiding the STATE in reeling in this entire program in for the profit of a few.

If you can't see that, you are a part of the problem.

And, I'd like to add.
Those that can but don't try to grow their own.
To many people these days confuse the definition of 'won't' with that of 'can't'.
Dispensaries, the ones in the know, knew this. They watched it for years in Cali., but got cockblocked when they figured it out.
Now guess what is happening, here?

It's like having to see a doctor, then get a permit (wait 30 days), and now you can go into Applejack Liquor.
:slowclap:
 
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canaguy27

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Not calling you a liar by any means, but check you facts before you spread them around.

I am in 50-70 mmcs a month talking to employees and owners. Most do not know exactly what is going on. Others say it is no big deal, and when I ask them if their patients know, they say they "don't want to scare them."

Here is what is happening:

1: Patients will be recorded on camera breaking federal laws. These cameras are tied into the DOR who can access them 24/7 and share with whoever they want.

2. Patient purchases will be tracked and logged. They will know how much you buy and from where. Remember, MMJ is still federally illegal.

3. Some MMCs have been actively lobbying against caregiver rights (MMIG, Josh Stanley, and Budding Health specifically) and have basically killed off caregivers. Some other MMCs I spoke to were happy that caregivers are being trampled on. This limits patients access to medicine, especially in areas with bans.

4. Patient records are being sent to the DOR. My money says they are saving this info, thus creating a "database" with patient info.

With law enforcement, CBI, DEA, etc having access to this information at their will, nothing good can come from that.

If patients knew this, I doubt there would be 140k on the registry. All 5 of my previous patients had to be talked into being on the CDPHE's registry. They are not renewing.

We are now hearing about people getting "knock and talks" who are caregivers. A friend of mine was pulled over and the sheriff said "Where is the weed, I know you have a red card." We are LUCKY that the THC DUI bill did not pass. I bet they will try again next session.

The DEA has pulled building plans on most MMCs in the state. Another guy told me there is now a camera watching his MMC grow. This camera is on a telephone poll in the alley.

From what I have read and heard, you probably run a good shop. But things are a bit different up here in Denver. There is too much competition and greed.
 
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SoCoMMJ

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1: Patients will be recorded on camera breaking federal laws. These cameras are tied into the DOR who can access them 24/7 and share with whoever they want.
Chances are that they were being recorded before. Most every liquor store, 7-11, or gas station does it too. This is nothing new. Security Cameras they call them. Yes the DOR can log into the cameras [someday if they can ever figure it out], but do you really think they care you are buying cheeba chews and 4 grams of bud? If you walk with 4lbs then maybe you should have concern of who is watching.

2. Patient purchases will be tracked and logged. They will know how much you buy and from where. Remember, MMJ is still federally illegal.
Logged to your patient ID, not your name. Again, if you aren't rolling out with a suspect volume of bud who is going to care. Yes it's illegal federally. Having a red card offers no protection at that level. Nothing new there. You can do time for a doobie in a national park...red card or not.

3. Some MMCs have been actively lobbying against caregiver rights (MMIG, Josh Stanley, and Budding Health specifically) and have basically killed off caregivers. Some other MMCs I spoke to were happy that caregivers are being trampled on. This limits patients access to medicine, especially in areas with bans.
Yes, there are douche bag lobbyists. I don't think that they represent the majority of dispensaries by any means. We just have no way to shut them up. Not sure why they would be happy about caregivers getting the shaft. We're all in the same muck together. It's actually representative of the ENTIRE ISSUE WITH THE MARIJUANA MOVEMENT. NO TWO PEOPLE CAN GET PAST THEMSELVES ENOUGH TO MOVE FORWARD ON COMMON GROUND. It's sick, and not just a little. Personally, I support and advise numerous caregivers. Maybe that's not the norm...

4. Patient records are being sent to the DOR. My money says they are saving this info, thus creating a "database" with patient info.
You keep repeating this, but I haven't seen anywhere that it is required.

With law enforcement, CBI, DEA, etc having access to this information at their will, nothing good can come from that.
This is another unsubstantiated myth.

If patients knew this, I doubt there would be 140k on the registry. All 5 of my previous patients had to be talked into being on the CDPHE's registry. They are not renewing.
I don't know why most of the people with red cards are on the registry. Colorado has decriminalized 2oz of Marijuana. You would have to get caught in possession several times to break even with the doctor and CDPHE fees. More power to them, if they have a reliable underground source for their meds.

We are now hearing about people getting "knock and talks" who are caregivers. A friend of mine was pulled over and the sheriff said "Where is the weed, I know you have a red card." We are LUCKY that the THC DUI bill did not pass. I bet they will try again next session.
This is impossible with today's system. The only way he could have known is if the sheriff saw him leave a dispensary, or had personal knowledge from a prior encounter, or your friend reeked like a freshly soiled Twister.

The DEA has pulled building plans on most MMCs in the state. Another guy told me there is now a camera watching his MMC grow. This camera is on a telephone poll in the alley.
I understood it to be EL Paso county offices providing the data to DEA. Have not heard of it being state wide. I checked my phone poles.... no camera :) But that was a commercial grow, not a patients or caregiver's house.

From what I have read and heard, you probably run a good shop. But things are a bit different up here in Denver. There is too much competition and greed.
I don't think you will find anybody that denies that there are people in the business that should be in it for better reasons. Like any business the right ones will survive the tempest and the others will fall to despair. Caregivers are not always followed by a giant halo... I've heard more than a few stories from patients.

It's all good though.... as messed up as we are, it still isn't freaking Oklahoma ! :)
 
Unit541

Unit541

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SoCo, You're putting a lot of good faith in the powers that be. You're simply assuming that because it's not written down somewhere, that it's not going to be done. For example, when CannaGuy says:
Patient records are being sent to the DOR. My money says they are saving this info, thus creating a "database" with patient info.
You reply with
You keep repeating this, but I haven't seen anywhere that it is required.
Why on earth do you think they've spent all this time and money developing daily, monthly, etc. logs and reports to be submitted to the state? It's not to use up a bunch of unwanted paper, that's for sure.

Sure, gas stations and liquor stores all have security cameras. There's a big difference however, between security and surveillance. The government is not watching you buy a six pack or 8 gallons of gas and a big gulp. Nor is the government mandating that the clerk at the gas station send a report to the DOR including your "gas card ID", along with which grade and how much you purchased. And if you really think that anyone in the enforcement division has to "figure out" how to view your feeds, then you're in for a very big surprise, as are your patrons.

Do you really think your state is going to have your back when the DEA wants all records, including patient records, from you, from the DOR and from the CDPHE? Texans thought the state had their back in the whole TSA situation too. How'd that turn out? Fact is, states crumble when the feds swing.

You seem convinced, that nobody will ever, abuse their position to match up a patient ID and a name, address, ssn. Is that just because nobody in government or law enforcement has ever abused their position or the power that comes from it?

Unfortunately, the fact that these rules are detrimental to patients and caregivers alike, cannot be argued away. Nor can the fact that the same rules are a boon to the centers, thus, dividing the cannabis culture in Colorado. Do you not see the agenda there? If we're not a single voice, we don't get any say. Centers are responsible for making this all about money. Well, more like ignorant, greedy center proprietors. They turned MMJ in Colorado into a gimmick, and were too ignorant to see that once the gimmick becomes about profit, that the gov is going to wring it for all it's worth, with absolutely no regard for who gets squeezed out.

The only silver lining for patients, is that the cannabis market is self regulating to an extent, in that the black market will simply ebb and flow with these regulations. 1284 put tons (literally) of premium medication on the street, there's the supply. These new regs mean no caregivers to pay for all these renewals, and patients that won't renew anyway. There's the demand. Sure, it's not $25 an eighth, but it's not ditch weed either, and nobody is on tape buying and selling.

I for one, am astonished that anyone was willing to stay in business as a center after 1284. I mean, :sign0065: !! You're selling massive quantities of a schedule 1 controlled substance. The state says you have to commit your daily multiple federal felonies on camera, and you think that's no big deal?

ALL centers, are going to feel completely different about all this, just a couple of years from now.
 
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SoCoMMJ

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Why on earth do you think they've spent all this time and money developing daily, monthly, etc. logs and reports to be submitted to the state? It's not to use up a bunch of unwanted paper, that's for sure.
Two reasons: They want to prevent patients from scooping up vast quantities from multiple dispensaries then pushing it into the black market. Secondly, they want to account for where product is going out of MMCs to prevent them from selling excess into the black market. Do you really think the DOR gives a shit about the patient picking up an ounce or 2 per month? No they don't.

Sure, gas stations and liquor stores all have security cameras. There's a big difference however, between security and surveillance. The government is not watching you buy a six pack or 8 gallons of gas and a big gulp. Nor is the government mandating that the clerk at the gas station send a report to the DOR including your "gas card ID", along with which grade and how much you purchased. And if you really think that anyone in the enforcement division has to "figure out" how to view your feeds, then you're in for a very big surprise, as are your patrons.
The feeds from the centers do not provide patient detail. No close up shots of red cards or other identifying data. Just a long shot of the sales counter and entrances. IF they happen to see giant boxes of weed moving out the door, they might have some interest in what's happening. Other than that, do you really think that anybody cares ? Remember, under 2oz is a only petty offence in colorado.

Do you really think your state is going to have your back when the DEA wants all records, including patient records, from you, from the DOR and from the CDPHE?

You seem convinced, that nobody will ever, abuse their position to match up a patient ID and a name, address, ssn. Is that just because nobody in government or law enforcement has ever abused their position or the power that comes from it?
If the Colorado Department of Health releases patient information from red cards, they are in violation of the constitution and risk exposure to being sued. DOR can not build a database with anything more than card numbers to assign plant count etc.

Unfortunately, the fact that these rules are detrimental to patients and caregivers alike, cannot be argued away.
Please clarify the detriment being imposed on patients. You have the exact same processes just to buy Claritin-D at Walgreens.

Nor can the fact that the same rules are a boon to the centers, thus, dividing the cannabis culture in Colorado. Do you not see the agenda there? You mean the agenda to regulate the industry? I don't think there is any hidden agenda except for cleaning up the input into the black market from the med grows.

If we're not a single voice, we don't get any say. Centers are responsible for making this all about money. You would be hard pressed to find more than a couple of dispensaries that really support this shitstorm. Between HB10-1284, HB11-1043, and DOR regs, there are over 200 pages of mostly retarded regulations. The mythical coalition of MMC established to crush caregivers does not exist. Yes, there are a couple of MMC owners that lobby for their personal interests, but they do not support the general voice of MMCs. The regs come from the state, not MMCs.

Well, more like ignorant, greedy center proprietors.
We're all greedy and ignorant. And you are a bigot. Are we graduating to name calling now?

They turned MMJ in Colorado into a gimmick, and were too ignorant to see that once the gimmick becomes about profit, that the gov is going to wring it for all it's worth, with absolutely no regard for who gets squeezed out.
It was the state legislators, Romer more specifically.

I for one, am astonished that anyone was willing to stay in business as a center after 1284. I mean, :sign0065: !! You're selling massive quantities of a schedule 1 controlled substance. The state says you have to commit your daily multiple federal felonies on camera, and you think that's no big deal?
The decision to move from caregivers for 25+ patients to becoming an MMC took some serious consideration. Do we boot our patients in need to the curb, or commit to regulation and step up and become an MMC. I feel ok with the choice so far. You make it sound like underground cultivation and sales is "no big deal". That is also a felony remember. I feel that there is more protection with a license than without. Time will tell on that one I suppose.

ALL centers, are going to feel completely different about all this, just a couple of years from now.
Because ? Or is this just one of those "the world is ending on May 12" predictions.

Honestly, the whole shitstorm has reached the point where the general populace, MMCs, Caregivers, and patients have had enough with the state. They will vote toward legalization in 2012 and cut the whole med mess out of the regulatory scope.

Like I've said before, if legalization puts every MMC, caregiver and black market dealer out of a job, then so be it. NOBODY needs to go to jail for any of this.

The problem preventing legalization is that no 2 factions can agree on anything regarding marijuana. The whole mess spends all the energy bashing each other. In the end, nothing gets done.

Think about what you are projecting when you put things like this this post out there... you are just fueling the fire that prevents progress.

:)
 
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DoobyScoo

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Seriously, if I owned an MMC, I might be hanging around too. Just to see if the thinning process continues. Then your center is worth bank (if the registry continues to grow, which it probably will in the long term), you got a one year moritorium, and then another bill after that will probably just be moritorium extensions.
Convenience is King, in America!

The State has basically Okayed recreational Marijuana, they just were learning from Californian lawmakers when they did their 'fact finding' missions, that the biggest problem with 'non-profit' models, is that the State has a much harder time getting their greasy fingers into the pot.
 
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SoCoMMJ

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The State has basically Okayed recreational Marijuana, they just were learning from Californian lawmakers when they did their 'fact finding' missions, that the biggest problem with 'non-profit' models, is that the State has a much harder time getting their greasy fingers into the pot.

Well kinda... While possession of under 2oz is a petty offense, if you get caught growing or selling you nuts are in the felony wringer.

We have a ways to go, and won't get there if the best we can do is hate on each other.
 
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DoobyScoo

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No hating there.
It is a prudent business decision.
Learn from Cali.

Good luck.

The problem you have with this investment, and any investment, is the Governmental/Regulatory Risk.
This one is strife with it, the reason a lot of us bitch, a lot.
 
Unit541

Unit541

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You've got a rosey way of looking at things don't you. Unfortunately, you're mistaken about a few things too.

Originally Posted by Unit541 View Post
Why on earth do you think they've spent all this time and money developing daily, monthly, etc. logs and reports to be submitted to the state? It's not to use up a bunch of unwanted paper, that's for sure.
Two reasons: They want to prevent patients from scooping up vast quantities from multiple dispensaries then pushing it into the black market. Secondly, they want to account for where product is going out of MMCs to prevent them from selling excess into the black market. Do you really think the DOR gives a shit about the patient picking up an ounce or 2 per month? No they don't.
You're right. And I really don't care what the DOR does anyway. However, I do have a concern or two, about who else may, at some point in the future, want to go rummaging through all the data they've collected on the subject. You know, like the DEA stepping in, and simply working off of this handy list of folks who have been committing federal crimes.

Originally Posted by Unit541 View Post
Sure, gas stations and liquor stores all have security cameras. There's a big difference however, between security and surveillance. The government is not watching you buy a six pack or 8 gallons of gas and a big gulp. Nor is the government mandating that the clerk at the gas station send a report to the DOR including your "gas card ID", along with which grade and how much you purchased. And if you really think that anyone in the enforcement division has to "figure out" how to view your feeds, then you're in for a very big surprise, as are your patrons.
The feeds from the centers do not provide patient detail. No close up shots of red cards or other identifying data. Just a long shot of the sales counter and entrances. IF they happen to see giant boxes of weed moving out the door, they might have some interest in what's happening. Other than that, do you really think that anybody cares ? Remember, under 2oz is a only petty offence in colorado.
Its the principal of the matter. If I'm going to commit a federal crime, I'd much rather not do it on video tape. Again, we know there's no problem at the state level, but unfortunately, CO has already proven that when the feds get involved, they're going to step aside. It's just a matter of the feds becoming involved, and that is just a matter of time. When that time comes, I'd prefer not to be on tape committing the crimes that they're looking to prosecute.


Originally Posted by Unit541 View Post
Do you really think your state is going to have your back when the DEA wants all records, including patient records, from you, from the DOR and from the CDPHE?

You seem convinced, that nobody will ever, abuse their position to match up a patient ID and a name, address, ssn. Is that just because nobody in government or law enforcement has ever abused their position or the power that comes from it?

If the Colorado Department of Health releases patient information from red cards, they are in violation of the constitution and risk exposure to being sued. DOR can not build a database with anything more than card numbers to assign plant count etc.
When a subpoena from the federal government shows up, they're going to do whatever it says. Period. Our legislators don't even know what the 10th amendment says, let alone stand up for it.


Originally Posted by Unit541 View Post
Unfortunately, the fact that these rules are detrimental to patients and caregivers alike, cannot be argued away.
Please clarify the detriment being imposed on patients. You have the exact same processes just to buy Claritin-D at Walgreens.
Requiring medical patients to commit federal crimes on video tape, can be described in no other way than detrimental. I can by Claritin-D at Walgreens without even a photo-ID, and the security cameras are not feeding to anyone but Walgreens, for the express purpose of security, not surveillance. If I'm mistaken, please point me in the right direction so that I can get my allergy card.

Originally Posted by Unit541 View Post
Nor can the fact that the same rules are a boon to the centers, thus, dividing the cannabis culture in Colorado. Do you not see the agenda there? You mean the agenda to regulate the industry? I don't think there is any hidden agenda except for cleaning up the input into the black market from the med grows.
The agenda is not to regulate the industry. It is to monetize the industry, pure and simple. "Cleaning up the input into the black market from the med grows."? Seriously? 1284 put more medical pot on the street than A20 did. This latest round of regs is putting the patients back on the street.


Originally Posted by Unit541 View Post
If we're not a single voice, we don't get any say. Centers are responsible for making this all about money. You would be hard pressed to find more than a couple of dispensaries that really support this shitstorm. Between HB10-1284, HB11-1043, and DOR regs, there are over 200 pages of mostly retarded regulations. The mythical coalition of MMC established to crush caregivers does not exist. Yes, there are a couple of MMC owners that lobby for their personal interests, but they do not support the general voice of MMCs. The regs come from the state, not MMCs.
Didn't really expect any different view from you on this one. And you are right. The regs come from the state, but they come because of the MMCs.


Originally Posted by Unit541 View Post
Well, more like ignorant, greedy center proprietors.
We're all greedy and ignorant. And you are a bigot. Are we graduating to name calling now?
Don't cry Nancy. You find spider mites this morning or something? It's quoted several times, and the original post is still there. You can clearly see, I never said "all", and I never said "you" either. Prior to your response, I considered you one of the good ones. I mean, you're here at the farm, your posts are thoughtful and and generally respectful. I wasn't calling you ignorant or greedy, but it seems like maybe you see yourself in that group more than I did.


Originally Posted by Unit541 View Post
They turned MMJ in Colorado into a gimmick, and were too ignorant to see that once the gimmick becomes about profit, that the gov is going to wring it for all it's worth, with absolutely no regard for who gets squeezed out.
It was the state legislators, Romer more specifically.
Is Romer's half naked twirly sign girl advertising $25 eighths?


Originally Posted by Unit541 View Post
I for one, am astonished that anyone was willing to stay in business as a center after 1284. I mean, !! You're selling massive quantities of a schedule 1 controlled substance. The state says you have to commit your daily multiple federal felonies on camera, and you think that's no big deal?
The decision to move from caregivers for 25+ patients to becoming an MMC took some serious consideration. Do we boot our patients in need to the curb, or commit to regulation and step up and become an MMC. I feel ok with the choice so far. You make it sound like underground cultivation and sales is "no big deal". That is also a felony remember. I feel that there is more protection with a license than without. Time will tell on that one I suppose.
Yup, both felonies. It's just for one, you're committing your crimes on video, with all kinds of tangible, physical records of all your daily crimes, and the other, well , you're not. Therefore, I feel safer without a "license" than with.


Originally Posted by Unit541 View Post
ALL centers, are going to feel completely different about all this, just a couple of years from now.
Because ? Or is this just one of those "the world is ending on May 12" predictions.
You think this is the end? Really?


Honestly, the whole shitstorm has reached the point where the general populace, MMCs, Caregivers, and patients have had enough with the state. They will vote toward legalization in 2012 and cut the whole med mess out of the regulatory scope.

Like I've said before, if legalization puts every MMC, caregiver and black market dealer out of a job, then so be it. NOBODY needs to go to jail for any of this.

The problem preventing legalization is that no 2 factions can agree on anything regarding marijuana. The whole mess spends all the energy bashing each other. In the end, nothing gets done.

Think about what you are projecting when you put things like this this post out there... you are just fueling the fire that prevents progress.

You and I agree on the rest... mostly. As a patient and (former) caregiver, I feel that it's the MMC's, and the reckless abandon with which they descended on our state, shafted me and my patients. Don't get me wrong, I see it as an unintended consequence.
 
iscrog4food

iscrog4food

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Personally I think we need to form a caregiver/patient insurgency! Get a group of people together to systematically sabotage the MMCs who are lobbying against caregivers. Seriously drop spidermites on employees of budding health. Or bring in a sac of pollen and let it fly inside the store ect. I mean would any of those things be a crime?
 
sky high

sky high

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Spend your time in your garden honing your craft and securing the best genetics you can rather than worrying about a group of folks who will soon be assfucking each other in prison.

don't drop the soap, >>licensee<<!
 
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OneRedCup

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All in favor of skyhigh, say 'ere

Could not agree more. Worry about your own garden and not what others are doing. Grow fire.
 
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SoCoMMJ

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You and I agree on the rest... mostly. As a patient and (former) caregiver, I feel that it's the MMC's, and the reckless abandon with which they descended on our state, shafted me and my patients. Don't get me wrong, I see it as an unintended consequence.

Your response leans toward the DEA busting patients. There is no way in hell they would do that. Sorry, but it isn't going to happen. Owners maybe, but the DEA would never take the heat on busting patients.

We'll never really agree, and we don't have to. At least understand that stirring friction between the factions will not do anything to further our collective cause.
 
Jarofunk

Jarofunk

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All in favor of skyhigh, say 'ere

Could not agree more. Worry about your own garden and not what others are doing. Grow fire.

Gotta say, SH seems more concerned with people "getting theirs" than with growing fire. All I hear is resentment and bitterness.

It's true, they are keeping track of us. The gov't tends to do that when a lot of $$$ is involved. The bright side for all you Caregivers is that the gov't doesn't have hardly any $$$ to investigate/prosecute anybody these days. Shit, they have only been able to process 60 people a day down at the MMED. State budget cuts across the board have agencies of all types just scraping by. I think they have created more rules than they can enforce.
 
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