The Dept. of Licensing and Regulatory Affairs (LARA) released two advisory bulletins today to inform and advise potential licensees of the Bureau of Medical Marihuana Regulation’s (BMMR) intention regarding (1) the transition from medical marihuana caregivers and patients to facility license holders and employees and (2) local and state license fees. The bulletins are for advisory purposes only and are subject to change.
Caregivers and Patients: Transition to Facility Licensee or Employee
The Medical Marihuana Facilities Licensing Act (MMFLA) requires grower and processor facility licensees to have at least two years experience as a caregiver, or have an active employee with such experience. However, a licensed grower or processor – or their employee – must not be registered as a caregiver. LARA intends to require that, upon licensure, any caregivers affiliated or employed by a grower or processor must submit the form to cancel caregiver status within 5 business days. New employees have five business days to submit the caregiver cancellation form.
The MMFLA requires that – to be eligible for a secure transporter license – an applicant and its investors cannot be registered patients or caregivers. Therefore, applicants for a secure transporter license – and those affiliated with the applicant as investors, direct/indirect owners, partners, officers, directors, managers, or members – must withdraw from the Michigan Medical Marihuana Program (MMMP) registry as caregivers or patients prior to applying for a secure transporter license.
The MMFLA does not prohibit provisioning center and safety compliance facility licensees from being registered as patients or caregivers under the MMMP, nor does it prohibit such facilities from employing patients or caregivers.
A patient or caregiver who wishes to withdraw from the MMMP registry must submit a completed Withdrawal Form directly to the MMMP according to the instructions on the form.
Fees under the Medical Marihuana Facilities Licensing Act
The MMFLA requires BMMR to collect two separate fees: