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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!

Friday, May 20, 2011

Colorado State Occupational Licensing

Well, we all knew that the Department of Revenue: Medical Marijuana Enforcement Division was going to require occupational licenses for employees working in this industry. They finally released the application and I urge all medical marijuana businesses to being submitting these occupational license applications for all employees.

If you have any questions or concerns please contact your attorney!

Here is the link to the applications:

Tuesday, May 3, 2011

Moratorium Extension stripped from Colorado Bill!

Great news for those trying to get their foot in the door in the Colorado medical marijuana industry. The Colorado Senate has stripped the provisions in HB1043 that would have extended Colorado's moratorium on new businesses for another year.

This would have meant that only those businesses that were licensed by their local jurisdictions by July 1, 2010 would have been able to continue the application process. During this application process, those businesses are allowed to remain open and available to their patients.

With the extension stripped, the moratorium on new medical marijuana businesses will expire on July 1, 2011. We still need to see if HB1043 passes, but if it does, then it is open season for new medical marijuana businesses!

If you are interested in opening a medical marijuana business, contact the Law Office of Craig Small and let's get going!

Wednesday, April 20, 2011

New Department of Revenue Regulations and Deadlines

I have completely slacked off on posting information in this blog. It is high time I get back to disseminating information you need to stay compliant with Colorado's medical marijuana program.

First off, the Department of Revenue: Medical Marijuana Enforcement Division (MMED) bond is due by May 1, 2011. For all businesses that have a Medical Marijuana Center or Infused Product Manufacture application pending with the MMED you MUST download their bond form, obtain a surety and file the bond with the MMED. No exceptions!

Second, the MMED has released 77 pages or regulations that go into enforcement on July 1, 2011. Know these regulations! They are very complicated and I highly suggest you have an attorney formulate policies and procedures to ensure compliance. These policies and procedures will go a long way towards showing good faith compliance should you fall on the wrong side of the line!
Law Office of Craig Small