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Thursday, August 4, 2011

DOR Issues New Forms Packet

Last night I attend ACT4CO's open meeting with Barbara Gold, MMED Auditor. Barbara is the Department of Revenue's drafter of the MMED Forms that we are all struggling to understand and complete.

Barbara was a fantastic speaker and provide a ton of good information as we all take part in this evolution of a new industry. There are few particular points from last night I want to share with the medical marijuana community.

First, most of the forms are voluntary! You do not have to use the DOR forms to track the data points they are requiring you to track. If you want you can create your own forms or modify your own POS systems to track this information and spit it out in a report if you are audited.

One form that is mandatory is the Transportation Manifest. This form must be filled out, sent to the DOR and approved by the DOR before transporting any medical marijuana from one business to another. The DOR approval staff is a little overworked and their response times are uncertain. It is to your benefit to submit requests for transportation at least 4 days before you actually plan on transporting mmj.

One work around to this delay is to regularly send in Transportation Manifests whether you actually transport the mmj or not. Barbara specifically stated that there is no penalty for cancelling an approved transportation run. Sorry Barbara for the extra work but some business are devastated when their Transportation Manifests are not approved in a timely manner.

As always, I hope this information is helpful but it is no substitute to seeking the advice of counsel as we participate in the greatest industrial revolution of our generation!

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