Back in February, we wrote about the new Compliance Tips section on the MED website.  Our team has continued to monitor this page and recently spotted two new tips that we wanted to bring to your attention.  Below are high level summaries, but please take a few minutes to read the tips in their entirety as well.

CDPHE Online Patient Registry and New Patient Documentation

On January 1, CDPHE launched a new online registry for patients in Colorado.  There have recently been reports of backlogs for paper based applications, so the online portal is a great option for tech-savvy patients.  However, there are a few important items to be aware surrounding this new system:

• Believe it or not, patients can actually print off legitimate patient registry cards on personal printers.  As a result of this change, make sure your staff is trained on the new designs.  Check out samples here.  Patient must present the card and a valid photo ID.

• Patients are able to change their Caregiver or designate a Primary Center using the online portal.  Educating patients about this process might be a great way to add some new patients to your list!

Failed Microbial Contaminant Testing

Back in October, we wrote about some potential changes to the MED rules, including options for utilizing solvent based extraction methods to salvage a batch of marijuana that has failed microbial testing.  As many of our readers aware, this rule made it through the rulemaking process and is now officially a rule.  The MED’s tip details some important items to keep in mind if you’re going to take advantage of this new rule.  Please read the tip in detail, and keep two important items in mind:

• The resulting concentrate that is produced from marijuana that failed microbial testing must be tested for both both microbials and residual solvents (unless the MIP is process validated for residual solvents).  Typically, solvent-based concentrates are only subject to residual solvent testing, so keep this added requirement in mind!

• Don’t forget to pay excise tax on this marijuana!

Our team will continue to monitor the MED Compliance Tips and will keep our readers updated!

Yours in Compliance,

Team Complia