Medical Marijuana Center Sales to Patients Presenting Documentation Obtained via the CPHE On-Line Medical Marijuana Registry System

Applicable Statues: (§ 12-43.3-402 (5) C.R.S.)

Applicable Rules: 1 CCR 212-1 M 402 & M 405

Tips:

  • As of January 1, 2017, Patients are able to generate legitimate Colorado Medical Marijuana Registry cards on personal printers. The Medical Marijuana Registry program is administered by the Colorado Department of Public Health and Environment (CDPHE) Medical Marijuana Registry.
  • When making a sale of Medical Marijuana or Medical Marijuana Product to a patient, Centers are expected to ensure that the Medical Marijuana Registry card presented is consistent with samples of the card provided by CDPHE and that the patient presents a valid photo ID in compliance with rule M 405 (B).   Center sales staff will find the registry number on the bottom left quadrant of the card, on both the self-printed cards and cards produced by the Colorado Department of Public Health and Environment (CDPHE).  
  • Using the new web-based system, patients are able to change their Caregiver or designate a Primary Center at any time and immediately print a new card.  This does not affect a Medical Marijuana Center’s mandate to follow rule M 402 (B); Centers shall not register as a patients’ Primary Center if the patient has designated another Center in the preceding 30 days.  
  • Centers may also accept new patient Medical Marijuana Registry applications that have been printed on personal printers. Again, Center staff is expected to ensure the documentation presented is consistent with samples of new patient applications provided by CDPHE. 
  • New patient applications may only be used to purchase Medical Marijuana and Medical Marijuana Products, within the 35-days immediately following submission of the application (M 405 (A) (2)).  An application submitted to CDPHE via the website will not require a certified mail receipt for purchase.  Use the patient’s registration ID number (found in the second line of the “Registration Information” section at the top of the first page of the document) to check the CDPHE webpage to ensure that the application has not been denied (https://www.colorado.gov/pacific/sites/default/files/CHED_MMR_List_Revoked_Cards-Denied_Apps_12-9-16%20.pdf). 
  • Patients may not use Medical Marijuana Renewal Applications to purchase Medical Marijuana or Medical Marijuana Products from a Center (§ 12-43.3-402 (5) C.R.S.). 
  • The CDPHE Medical Marijuana Registry System and the Colorado Department of Revenue Marijuana Enforcement Division Inventory Tracking System (Metrc©) are two separate and distinct databases.  Metrc© is NOT intended to be used as a patient registry card number verification tool.
  • Medical Marijuana Centers are not expected to purchase equipment to scan the barcodes printed on the registry cards.  There is no requirement that Centers obtain any information from the barcodes on registry cards.

Licensees are responsible for ensuring they are compliant with applicable statute and rules.  This Compliance Tip is not intended to be all inclusive and may not include all statutes and rules applicable to the Topic.  Further, the Division is not able to provide you with legal advice. If you have any legal questions, please consult with an attorney. 

3/15/2017