December 21, 2020

Medical Cannabis Industry: Ensure More Effective & Efficient Compliance with Clearview Group

Clearview Group

3

Minutes to read

The medical cannabis industry is rapidly growing across the nation as legalization continues to increase state by state. The industry’s three main segments include: growers, processors (for oil-based products), and dispensaries that all operate within strict inventory control requirements to monitor the movement of product throughout the process.

Growers, or “grow facilities,” grow the medical cannabis plants. Rather than growing each plant from seeds, often there are “mother plants” that have a small branch trimmed off and are replanted to start the medical cannabis plant growing process. The mother plants receive light 24 hours per day, which prevents flower (the end medical cannabis product) from growing. Once the plants begin to grow, they are moved to a different grow area where they receive a unique tag number, which is used to monitor the product until the flower is harvested and individually packaged for sale.

From there, the processors refine the medical cannabis flower into oil, which is used for a variety of vaping and edible products. The medical cannabis oil processing often takes place in the same facility as the growing. Once the flower is processed into oil, the batch of oil receives a new unique tag number that stays with that batch of oil until it is individually packaged or processed into other products. Individually packaged medical cannabis products are given unique tag numbers before issued to dispensaries where medical cannabis patients can purchase the products.

This year in the State of Maryland specifically, along with the Maryland Medical Cannabis Commission (MMCC), additional security and inventory control requirements for the medical cannabis industry have been implemented and include additional video surveillance and inventory controls to prevent theft and diversion. Following these protocols, medical cannabis growers, processors, and dispensaries are now required to maintain video surveillance at the entrance to and within each area where medical cannabis is trimmed, processed, packaged, stored, or dispensed. These licensees must retain video surveillance recordings for a minimum of 90 calendar days. Any evidence of theft or diversion must be reported to the MMCC in addition to the Maryland State Police within one business day from an event. Within 30 business days of discovering the theft or diversion, the licensee shall complete an investigation, amend the licensee’s standard operating procedures if necessary, and send a report of the investigation to the MMCC. Prior to dispensing medical cannabis to a qualifying patient or caregiver, each dispensary must verify that the qualifying patient or caregiver is currently registered, a certifying provider has issued a valid written certification to the qualifying patient, and the amount of medical cannabis that has already been dispensed pursuant to the written certification.

The medical cannabis industry is maturing the processes and controls to safeguard the industry from abuse and ensure product and all medications are properly tracked and accounted for throughout the revenue cycle. Helping clients navigate this ever-changing landscape ensures they comply and are in good standing with state regulators. Clearview Group understands the regulatory requirements from licensing to various segments of production and distribution through working with growers, processors, and distributers through prior engagements. Clearview can assist an organization within the industry by hardening internal controls to comply with the MMCC’s requirements.

In the event of a MMCC inspection or investigation, the due diligence provided by Clearview will assist the organization’s efforts to resolve the matter and avoid any penalties or associated risk.

To learn more about maneuvering the licensing and operating stages and to ensure compliance is more efficient and effective within your medical cannabis operation, contact us.

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