Treatment center rules introduce concept of satellite locations for medical marijuana
The proposed rules for New Hampshire’s medical marijuana treatment centers introduce the potential for satellite establishments outside of the four regional locations outlined in the law passed last year, but additional regulations would be needed.
Introduced earlier this month, the draft rules indicate a potential $10,000 fee to open a satellite establishment and a $10,000 “annual satellite renewal fee,” but rules coordinator Michael Holt said that concept is preliminary.
“It’s an idea that we wanted to introduce to start a conversation about the potential need for satellite dispensaries in order to be able to service the entire state,” Holt said.
A satellite location might allow a treatment center to serve an area of the state where it would otherwise “not be viable” for one of the centers to operate, Holt said. The references to satellite locations will likely be removed during the formal rule-making process for the treatment centers, he said.
Under the draft rules released earlier this month, those seeking to operate dispensaries in New Hampshire could be looking at $80,000 to register a facility. Additional fees outlined in the document include $1,500 to submit a request for proposal and $250 for a name or administrator change, among others. If a treatment center changes owners or locations, according to the draft rules, “the fees for a new registration shall apply.”
Holt attributed the proposed amounts for the registration fees to the need to generate money for program staff and resources. It’s not funded through the Legislature, so its funding needs to come from other sources such as patient registries, caregiver cards and fees for the treatment centers.
The proposed rules – published on the Department of Health and Human Services’ website Aug. 13 and presented to the Therapeutic Cannabis Advisory Council – also address handling and storage procedures, patient privacy, advertising, staffing and record keeping at the facilities, among other considerations.
At least two “agents” must be present at the facility during operating hours, and the facilities are also barred from selling anything besides “cannabis, CIP, paraphernalia, and educational materials about cannabis.” Medical marijuana cannot be consumed at the centers, according to the draft rules.
The draft rules also require the operators of alternative treatment centers to “implement security measures” to limit access to certain areas of the facilities and to store the cannabis or “cannabis-infused products.” They do not at this point require the facilities to maintain security staff, though Holt said a question about such a requirement was brought up at a previous advisory council meeting.
The rules also do not allow for home delivery of medical marijuana. Holt said the “caregiver model contemplated in the statute” addresses concerns about access for those who might be unable to travel to an alternative treatment center on their own.
In researching the potential rules, Holt said officials looked at models from several other states – focusing on Massachusetts, Connecticut and Colorado, which seemed to be “tightly regulated.”
Feedback on the draft can be submitted to Holt via email at firstname.lastname@example.org or fax at 271-5590 by tomorrow.
The advance public comment period ends tomorrow, but residents will also be able to comment during the formal rule-making process in the months ahead. The formal public comment period will start Sept. 25, and a public hearing would be held Oct. 16, at the earliest, according to a tentative schedule provided by Holt. The Joint Legislative Committee on Administrative Rules meeting on the issue is scheduled for Nov. 20.
(Casey McDermott can be reached at 369-3306 or email@example.com or on Twitter @caseymcdermott.)