FY2020
Annual Report
Maryland Medical Cannabis Commission
Our mission
. . . to provide a safe, effective and consumer-friendly
medical cannabis program for qualifying patients.
Our vision
. . . a high quality, equitable and compliant medical
cannabis program that serves as a nationwide model.
Table of Contents
1
FY2020 Annual Report
Message from the Executive Director 2
Introduction 3
Message from the Chair 4
Our Patients 6
Program at a Glance 8
Diversity 10
Compliance 11
New Compliance Enhancements & Guidance 12
Budget 13
COVID-19 Measures 14
Policy and Legislative Accomplishments 15
Regulatory Progress 17
Moving Forward 20
A Tribute to Fakiza Rahman
“This Fiscal Year 2020 Annual Report is dedicat-
ed to our friend and colleague Fakiza Rahman.
Ms. Fakiza Rahman was the Maryland Medical
Cannabis Commission’s Director of Operations
until she passed away on March 12, 2020, sur-
rounded by her family and many friends after a
nearly two year battle with cancer. Fakiza was the
most hard-working, compassionate, and generous
colleague, and the MMCC and the State of Mary-
land are forever changed for the better because of
her efforts on behalf of seriously ill and injured
Marylanders. She cared immensely for the Maryland Medical Cannabis Program and for
each of the patients who sought relief in it.
Fakiza started with the MMCC in April 2017 – the same week the patient registry
opened – and was instrumental in building the Program from the ground up. Over
the past three years, Fakiza helped tens of thousands of Marylanders register to ob-
tain medical cannabis to treat severe and chronic pain, seizure disorders, cancer-as-
sociated pain and nausea, glaucoma, post-traumatic stress disorder, and many other
life-threatening or serious medical conditions. Fakiza also administered the State’s
medical cannabis seed-to-sale tracking system (METRC) and agent registration system
(Complia), and supervised nearly two dozen employees. She did everything at MMCC.
If anyone – a Commission member or employee, patient, caregiver, provider, or licensee
– had a question, Fakiza was the one we so often went to for an answer. Simply put, she
was the best of us. The best coworker, manager, mentor, and friend.
Fakiza was also the embodiment of a selfless public servant. She gave everything she
had to the MMCC and to the patients of Maryland; working nights and weekends, and
always volunteering first whenever anyone needed assistance. Fakiza continued to
assist patients while she was in the hospital fighting for her life. In her honor and with
gratitude, we pay tribute to Fakiza Rahman.”
Will Tilburg, JD, MPH
Executive Director
2
A Message from the Executive Director
3
About us
The Maryland Medical Cannabis Commission (MMCC) is an independent
commission within the Maryland Department of Health. The MMCC oversees
all licensing, registration, regulation development, inspection, and testing
measures pertaining to the medical cannabis program, and provides program
information to patients, providers, licensees, and other stakeholders. The MMCC
is devoted to performing all its regulatory activities in accordance with our
Mission and Vision, with patient safety at the forefront of everything we do.
Who we are
The MMCC is comprised of 13 Commissioners and 52 full-time staff members.
Commissioners are responsible for governing the Maryland Medical Cannabis
Program. They oversee the regulatory, administrative, educational and re-
search, and reporting activities of the MMCC. All major programmatic decisions
must be voted on and approved by the full Commission during a public meeting.
To ensure that adequate time for deliberation and subject matter expertise is
given to all decisions, there are five standing committees upon which
Commission members serve.
Introduction
Commission staff support seven major departments – Enforcement and
Compliance, Communications, Finance, Information Technology, Policy
and Government Affairs, Scientific Support, and Quality Assurance. These
departments provide day-to-day support for MMCC operations, and act as the
liaison between stakeholders and Commissioners.
• Executive Director – William Tilburg, JD, MPH
• Deputy Director – Lori M. Dodson, MS, MT(ASCP)
Executive Committee
Chair Brian Lopez
Sandy Washington
Liz Hines
Tiffany Randolph
Nancy Rosen-Cohen
Compliance Committee
Chair Phil Cogan
Obi Onyewu
Scott Welsh
Finance & Budget Committee
Chair Obi Onyewu
Konrad Dawson
Phil Cogan
Policy Committee
Chair Tiffany Randolph
Charles LoDico
Liz Hines
Scott Welsh
Megan Dingus
Research & Education Committee
Chair Charles LoDico
Jinlene Chan
Ehsan Abdeshahian
Konrad Dawson
Chair’s Message
A message from our chair
4
O
n behalf of the
Maryland Medi-
cal Cannabis Commis-
sion (MMCC) and with my
fellow commissioners, it is
my honor and pleasure to
report on our substantial
accomplishments during
FY2020, as well as the
changes made to further
our mission.
Our fundamental motiva-
tion at the Commission is to ensure medical cannabis is available to
qualifying patients in a safe and effective manner. The Commission
carried out a series of activities during FY2020 (July 1, 2019 to June
30, 2020) that address priority issues focusing on our mission:
• Quality Assurance – Patient application turnaround time was
reduced from 30 days to 10 days and our IT infrastructure has
been greatly enhanced to improve usability and reduce system
down time.
• Enforcement and Compliance – 19 pre-approved applicants
received full licensure across the State to grow, process, or
dispense medical cannabis.
• Policy and Government Affairs – Created and established
regulations to safely manufacture and dispense edible canna-
bis products, as well as developed advertising guidelines for our
licensees.
• Patient and Provider Growth – Our patient population
nearly doubled – growing from 54,939 to 102,459 patients during
FY2020 – and the number of registered medical providers
certifying patients increased from 1,468 to 1,894 certified
providers.
• Education and Training – The Commission developed a
standardized education curriculum for certifying providers and
dispensary agents.
A Message from the Chair
Chair’s Message
5
In June 2019, the Commission launched its application process to
award four additional grower and 10 additional processor licenses.
Despite some initial technical difficulties with the technology, the
application process produced more than 200 applications with the vast
majority (approximately 90 percent) being submitted by minority and
women-owned businesses.
The medical cannabis industry in Maryland is robust and we look
forward to the coming year. As we continue to strengthen every aspect
of our program, we will remain focused on the following goals:
• Continued and improved diversity in ownership – We look
forward to announcing the pre-approvals of our license applica-
tion process and finding new and creative solutions for providing
minority ownership amongst our licensees.
• Continued Growth – The Commission awarded a procurement in
July 2020 to conduct a market analysis on the medical cannabis
industry in Maryland. The analysis will assess current capacity
and future needs.
• Standardized and consistent regulatory enforcement and
compliance – Consistency across the State is important to all of
our stakeholders.
• Expanded Research and Education - Explore research
opportunities with our institutions and engage with our
stakeholders in order to provide educational opportunities to all
of our stakeholders
We look forward to another year of continued growth and complex
policy and legislative issues. We expect a year of new challenges and
the opportunity to continue making Maryland’s Medical Cannabis Pro-
gram the best in the country.
Brian Lopez
Commission Chair
6
Our Patients
Patient Population
Medical cannabis patients are central to all aspects of the Maryland
Medical Cannabis Program (the Program). The number of patients
continues to grow as a steadily increasing number of individuals seek
the therapeutic benefits of medical cannabis.
As of July 2020, the MMCC had registered 106,758 patients. Of that
total, 183 were minor patients, and 520 were hospice patients. In
addition, as of July 2020, the MMCC had registered 8,079 caregivers to
assist patients with the administration of medical cannabis.
The MMCC receives over 200 applications per day from patients seeking
to register with the Program. The average amount of time to process
these registrations has decreased from 30+ days to 10 days, even in the
wake of the COVID-19 pandemic. Central to this decrease in process-
ing time are our Quality Assurance staff, who work tirelessly to ensure
that all patient requests and questions are answered in a timely man-
ner. The recently established MMCC call center has also greatly helped
to improve service to patients, by connecting them directly with health
and other experts. The call center receives 200 – 250 calls per day.
120,000
100,000
80,000
60,000
40,000
20,000
0
2017 2018 2019 2020 (as of July)
11,489
54,643
93,265
106,758
Number of Certified Patients
Who is eligible to become a medical cannabis
patient in Maryland?
Any individual living in Maryland whose certifying medical cannabis
provider recommends medical cannabis as a treatment option for a
qualifying medical condition is eligible.
What are medical cannabis caregivers?
Caregivers are registered individuals, aged 21 or older, who are
permitted to purchase medical cannabis on behalf of a patient, and
assist with that patient’s administration of medical cannabis. A
registered adult-patient may designate up to two caregivers. All regis-
tered minor-patients must have a caregiver who is the minor-patient’s
parent(s) or legal guardian(s). At most, a minor-patient may have four
caregivers: two of whom are parents or legal guardians, and two of
whom are additional designated adults.
Who is Eligible to Provide a Certification for Medical Cannabis?
A health care provider licensed and in good standing in Maryland
from any of the following provider categories may register with MMCC
to become a certifying provider: physicians, dentists, podiatrists,
certified nurse practitioners, certified nurse midwives, and beginning
October 1, 2020, physician assistants.
The MMCC currently has 1,894 certifying providers located throughout
the State who are registered to provide patient certifications.
What is a Qualifying Medical Condition?
A certifying provider may recommend medical cannabis as a treatment
option for a patient experiencing a chronic or debilitating disease or
medical condition that results in:
Our Patients
• Being admitted into hospice
or receiving palliative care,
• Cachexia,
• Anorexia,
• Wasting syndrome,
• Severe or chronic pain,
• Severe nausea,
• Seizures,
• Severe or persistent muscle
spasms,
• Glaucoma,
• Post-traumatic stress disor-
der (PTSD), or
• Another chronic medical
condition which is severe
and for which other treat-
ments have been ineffec-
tive – also referred to as
the “other” category in the
chart below.
7
8
Program at a Glance
The Maryland Medical Cannabis Program became operational on
December 1, 2017. In its nearly three years of operation, the Program
has experienced immense growth in all areas, from patient population
to dispensary sales to number of the MMCC staff members.
As of July 1, 2020, the MMCC has licensed:
• 17 medical cannabis growers, who are responsible for cultivating
the medical cannabis.
• 17 medical cannabis processors, who are responsible for
processing the raw medical cannabis flower into various
products, such as tinctures and oils.
• 91 medical cannabis dispensaries, who are responsible for the
sale of medical cannabis to patients and caregivers.
Program at a Glance
The average price per gram has fallen significantly, since a high of
$15.97 in January of 2018. During the past 2 ½ year sales period, the
average price per gram has largely leveled out, remaining relatively
stable throughout 2019 and 2020.
FY2020 Average Price Per Gram
As demonstrated below, severe or chronic pain is the most common
qualifying condition affecting our patient population, a number of whom
are seeking an alternative to opioids and other prescription medication.
Wasting Syndrome
Severe Nausea
Seizures
PTSD
Other
Muscle Spasms
Glaucoma
Severe/Chronic Pain
Cachexia
Anorexia
0 10,000 20,000 30,000 40,000 50,000 60,000
8,407
1,076
3,337
25
Patient Numbers by Condition
37,635
5,362
711
78
237
50,617
9
Program at a Glance
$45,000,000
$40,000,000
$35,000,000
$30,000,000
$25,000,000
$20,000,000
$15,000,000
$10,000,000
$5,000,000
$0
Monthly Dispensary Sales
Nov 2019
Oct 2019
Dec 2019
Jan 2020
Feb 2020
Mar 2020
Jun 2020
Apl 2020
Sep 2019
May 2020
Aug 2019
Jul 2019
$22,477,947
24,367,816
23,065,282
23,034389
25,624,003
27,534,247
29,948,588
27,567,518
33,577,732
34,009,285
38,562,744
37,578,953
Average Price per Gram
Jan Feb Mar Apl May Jun Jul Aug Sep Oct Nov Dec
$15.97 $15.61 $13.92 $12.77 $12.66 $11.63 $10.44 $10.21 $9.79 $9.53 $9.67 $9.52
$9.59 $9.63 $9.55 $9.14 $9.57 $9.55 $9.39 $9.52 $9.75 $10.01 $9.83 $9.94
$11.87 $10.77 $10.54 $10.57 $10.80 $10.74
$18
$16
$14
$12
$10
$8
$6
$4
$2
$0
2018
2019
As of July 2020
$500,000,000
$450,000,000
$400,000,000
$350,000,000
$300,000,000
$250,000,000
$200,000,000
$150,000,000
$100,000,000
50,000,000
$0
Year-to-Year Sales - Medical Only
2018 2019 2020 (projected)
Maryland $96,314,260 $241,886,978 $450,000,000
Massachusetts $96,700,000 $165,000,000 $220,000,000
New Jersey $52,000,000 $90,000,000 $150,000,000
5
10
Diversity
The MMCC is committed to promoting diversity and the
participation of diverse groups within the medical cannabis industry, in-
cluding small, minority, and women-owned businesses. The MMCC’s goal
is for the medical cannabis program to reflect the broad race, gender,
ethnicity, and socioeconomic diversity of the State of Maryland.
To assist in these efforts, the MMCC tracks program diversity through the Annual
Minority Disclosure forms that each licensee must submit by June 30 each year.
On October 1, 2020, the MMCC awarded three grower license preapprovals and
eight processor license preapprovals. Majority ownership (e.g. 51% or more) of
each newly preapproved entity is held by disadvantaged minority and women
owners. As a result, six out of 21 licensed/preapproved growers and 14 out of
26 licensed/preapproved processors are majority-owned by minority and women
owners.
Program Diversity
Diversity within the MMCC
Licensed and
Pre-Approved
Growers
As of July 1, 2020
12 out of 18 have
women and/or minori-
ty owners
3 out of 18 have
>50% ownership
interest held by
women and/or minori-
ties
Licensed
and
Pre-Approved
Processors
As of July 1, 2020
11 out of 18 have
women and/or minori-
ty owners
6 out of 18 have
>50% ownership
interest held by
women and/or minori-
ties
Licensed Medical
Cannabis
Dispensaries
As of July 1, 2020
61 out of 91 have
women and/or
minority owners
36 out of 91 have
>50% ownership
interest held by
women and/or
minorities
Commission
Members
As of July 1, 2020
10 out of 13 Commis-
sion members are
women and/or
minorities
MMCC Staff
Overall
As of July 1, 2020
41 out of 52 staff
members are women
and/or minorities
MMCC Staff
Leadership
As of July 1, 2020
8 out of 10 staff
members in senior
leadership roles are
women and/or
minorities
5
11
Compliance
The MMCC’s compliance efforts are critical to ensuring product
and patient safety and form the backbone of the Maryland Medical
Cannabis Program. The integrity of the Program depends on the
strength of its compliance operations, which are handled by two
departments:
• The Bureau of Enforcement and Compliance (BEC), which is
responsible for overseeing the inspection and discipline of
licensed growers and dispensaries to ensure conformity with
Maryland’s medical cannabis statutes and regulations, and
• Scientific Support (SS), which is responsible for overseeing the
inspection and discipline, as well as the standards of care and
testing protocols for licensed processors and registered indepen-
dent testing laboratories to ensure conformity with Maryland’s
medical cannabis statutes and regulations.
These two departments are responsible for ensuring that all medical
cannabis licensees comply with product safety and quality assurance
requirements. The MMCC staff conduct pre-licensing inspections, ran-
dom unannounced compliance inspections, and inspections in response
to product safety or quality complaints.
The chart below details the inspection activity for FY2020.
Compliance
Inspection Activity SS – FY2020 BEC – FY2020
Routine 22 438
Complaint 1 80
METRC Audits 4 34
Virtual Audits* 22 15
Full Licensing 0 6
* As a result of the COVID-19 pandemic
5
New Enhancements
New Compliance Enhancements and Guidance
The MMCC is foremost a regulatory body charged with protecting
public health and safety. As such, the MMCC continually works to find
new and innovative ways to enhance its compliance activities.
Technical Authority for Independent Testing
Laboratories
With the assistance of a Laboratory Testing Workgroup, the MMCC
has established a technical authority reference guide for independent
testing laboratories to follow when analyzing medical cannabis. Testing
of medical cannabis for safety and potency is essential to minimizing
the risk of patient exposure to harmful microbials, heavy metals and
other contaminants, as well as quantifying the cannabinoid profiles
and potency to assist patients and providers with product selection
and dosing. This reference guide will help improve and standardize the
quality and accuracy of testing.
Inspection and Reporting
MMCC has improved and streamlined the inspection and report-
ing processes to achieve higher quality results and to continue to
ensure patient safety. Further, the MMCC recently promulgated
regulatory changes to enhance its inspections and enforcement capabil-
ity. The regulations strengthen video surveillance of licensed grower,
processor, and dispensary premises; establish mandatory reporting
whenever a licensee finds evidence of theft or diversion; and require a
licensee to enter timely and accurate data into METRC to better track
the licensee’s stock of medical cannabis.
12
5
Budget
Budget
The MMCC’s operating budget comes from its own special fund. This
means the Program is 100% self-funded, and receives no money from
taxpayer dollars or the State’s General Fund. Rather, all funding for
MMCC program operations are from dollars generated by the Program
itself. As shown in the chart below, the MMCC’s main source of funding
is from licensing and patient ID card fees.
13
FY2017 FY2018 FY2019 FY2020
Licensing Fees $4,170,700 $2,633,400 $5,901,400 $5,898,835
Agent ID Cards $9,800 $389,830 $486,044 $756,000
Patient ID Cards $53,500 $452,800 $3,796,650 $4,045,450
Interest/Fines $0 $32,464 $187,383 $167,339
Total Revenue $4,234,000 $3,508,494 $10,371,437 $10,867,623
Personnel Cost $1,351,280 $1,809,155 $2,981,972 $4,015,151
Contract & Services $1,189,050 $2,580,612 $2,626,834 $3,249,444
Total Expenses $2,540,330 $4,389,767 $5,608,806 $7,264,595
5
COVID-19 Measures
COVID-19 Emergency Measures
Along with the rest of the State, the MMCC was propelled into action
in response to the COVID-19 pandemic. Since March 2020, the MMCC
has made significant programmatic adjustments to ensure patients
continued access to safe and effective medical cannabis. This includes
issuing 10 COVID-related bulletins that recommended State and CDC
precautionary safety measures, reduced patient-employee interactions,
and authorized telehealth measures.
Since March, the MMCC has increased access to medical cannabis and made
access safer by authorizing dispensaries to dispense cannabis via
drive-through and curbside pickup, expanding delivery of medical
cannabis to facilities and residences where patients and caregivers reside,
allowing telehealth visits between certifying providers and patients,
and suspending patient and caregiver attestation and signature
requirements. Furthermore, the MMCC implemented licensee social
distancing requirements and clarified operational best practices at
licensed facilities during the COVID-19 pandemic to ensure that
potential for exposure is as limited as possible.
Despite the unprecedented and rapidly evolving landscape of COVID-19,
the MMCC operations remain largely uninterrupted. This outcome can
be attributed in large measure to the immense work by the MMCC’s
staff, who remain devoted to ensuring continuity of programmatic
operations, in conjunction with the hard work and cooperation of
medical cannabis licensees.
Given the success of certain COVID-19 measures, the MMCC
approved regulations authorizing drive-through dispensing to remain in
place. “Drive-through dispensing” is a method of dispensing
medical cannabis through a window or other opening in the exteri-
or wall of a dispensary. This type of dispensing enables a registered
dispensary agent to provide services to a qualifying patient or registered
caregiver who drives a vehicle to the dispensary without a registered
dispensary agent leaving the dispensary service area or qualifying patient or
registered caregiver leaving his or her vehicle.
The MMCC is engaged in communications with medical cannabis
licensees, patients, and other interested stakeholders on the potential
14
5
Policy & Govt Affairs
merits of continuing a number of the MMCC’s COVID-19 emergency
measures. Licensees, patients, and caregivers alike have reaped
benefits from some of the temporary measures currently in place, such
as telehealth visits and medical cannabis deliveries to patient and
caregiver residences and facilities, among others, and expressed a
desire for these activities to continue.
Policy
The Maryland Medical Cannabis Program has benefited from a
number of important legislative and regulatory milestones during
the past year. As illustrated below, the MMCC has or is in the
process of implementing notable policy changes to continue improving the
medical cannabis program, and to ensure safe, high-quality medicine is
available for the patients we serve.
Legislative Accomplishments
The MMCC proudly supported the following legislation championed by
our legislative partners:
Administration of Medical Cannabis on School Grounds
Groundbreaking legislation was enacted in which Maryland
became one of a handful of states in the U.S. to authorize school
personnel to administer medical cannabis to qualifying students on school
property, at school-sponsored activities, and on a school bus in accor-
dance with guidelines developed by the Maryland State Department
of Education and the MMCC, starting in 2021. Furthermore, effec-
tive June 1, 2020, caregivers of students who are qualifying medical
cannabis patients may administer medical cannabis to students on
school property, during school – sponsored activities, and on a school
bus. A parent or guardian of a minor qualified patient may designate
up to two additional adults to serve as caregivers, allowing a minor
qualified patient to have up to four caregivers.
15
5
Policy & Govt Affairs
Prior to enactment, caregivers of students who are qualifying
medical cannabis patients had to remove the student from school
property in order to administer their medicine, causing an often untenable
disruption to the student’s class time. By facilitating the student’s
continuity of care and access to education, this law ensures that
medical cannabis patients will be able to attend school and partic-
ipate in school activities while continuing their treatment which
cannot reasonably be accomplished outside of school hours. See House
Bill 617/Senate Bill 604 (2020) sponsored by Delegates Steve Johnson,
Nicholaus Kipke and Mary Ann Lisanti and Senator Brian Feldman,
respectively.
Certifying Providers
Beginning October 2020, physician assistants will be permitted to
register with the MMCC as certifying providers. This will help increase
patient access to certifying providers, many of whom are presently
clustered in areas of the State such as Baltimore City and Montgom-
ery County. See House Bill 378/Senate Bill 304 (2020) sponsored by
Delegate Nicholaus Kipke and Senator Chris West, respectively.
The Fakiza Rahman Act – Compassionate Use Fund
This legislation provides a funding mechanism for the Compassionate
Use Fund in order to make medical cannabis available at a reduced cost
to Maryland Medicaid recipients and veterans. The bill was named in
honor of Fakiza Rahman, the MMCC’s former Director of Operations
who passed away in March 2020 after a spirited battle with cancer.
Ms. Fakiza Rahman’s impressive work at the MMCC was influential in
successfully launching the medical cannabis program, and her indelible
legacy will shape its trajectory for many years to come.
Since the inception of the Maryland Medical Cannabis Program, many
patients, caregivers, providers, and other constituencies have voiced
concerns over the cost of medical cannabis for low-income and other
vulnerable populations. This legislation is a step toward addressing
and ameliorating those concerns.
16
5
Policy & Govt Affairs
The MMCC is required to establish the program by:
• Setting a structure to assess fees on licensed growers, processors,
and dispensaries to provide funding for reduced-cost cannabis
through the Compassionate Use Fund.
• Establishing a procedure to collect fees on licensed growers,
processors, and dispensaries.
• Reimbursing licensed dispensaries for the reduced-cost medical
cannabis.
The MMCC expects the Fund to be operational by mid-2021. See House
Bill 870 (2020) sponsored by Delegate Joseline Pena-Melnyk.
Regulatory Progress
Clinical Director
Effective November 1, 2020, all licensed dispensaries must appoint
a Clinical Director with specialized training in medical cannabis
scientific research, risks and benefits to be available to any patient
onsite or electronically. The Clinical Director will be able to help
patients and caregivers better understand potential drug-to-drug
interactions, including interactions with alcohol, prescription drugs,
non-prescription drugs, and supplements; possible side effects or
contraindications of medical cannabis use; the potential for
differing strengths and effects of medical cannabis strains; and different
methods, forms, and routes of medical cannabis administration.
Patient ID Card Fee Waiver
Given that medical cannabis is not currently covered by insurance,
patients must pay out-of-pocket, which represents a financial hardship
for many patients and their families. In order to help alleviate some of
the cost burden and help increase access, the MMCC has waived the $50
patient ID card fee for Maryland Medical Assistance Program recipi-
ents and Veteran’s Affairs Health Care System enrollees. For existing
patients, the fee will be waived upon renewal.
17
5
Policy & Govt Affairs
Edible Medical Cannabis Products
The highly anticipated implementation of regulations allowing for the
manufacture and sale of edible medical cannabis products is expected
to take place in Fall/Winter 2020.
Over an 18-month period, the MMCC held workshops and conducted
outreach to a broad group of stakeholders, including legal, medical,
public health, laboratory, and industry experts, to establish a regu-
latory framework for the oversight of the processing and distribution
of edible cannabis products. The result is one of the most comprehen-
sive regulatory frameworks for edible medical cannabis products in the
country.
Ownership and Control of Medical Cannabis Licenses
An individual or entity may only have an ownership interest in, or
control over, one grower license, one processor license, and up to four
dispensary licenses. In order to ensure the MMCC can adequately
regulate licensees and remain abreast of any changes in ownership and
control of licenses, the MMCC implemented the following regulatory
changes, which took effect on May 8, 2020:
• The restriction on the sale or transfer of ownership of a license
has been extended from two to three years.
• All licensees must submit an annual disclosure of organization,
ownership, and control to the MMCC by July 1 of each year, or
upon request.
• Commission approval is now required for a transfer of any
ownership interest to an individual or in a privately held entity,
and for a transfer of five perent or more ownership interest in
publicly held entity.
• Commission approval is now required for a transfer of control of
a license to a third party (i.e. a management company).
Oversight of Advertising Restrictions
The MMCC has increased oversight of medical cannabis advertising
as a result of legislation enacted by the Maryland General Assem-
bly in 2019 that imposed specific restrictions on medical cannabis
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5
Policy & Govt Affairs
advertising. The new law contains a number of advertising restrictions,
that include safeguarding against false or misleading advertising and
requiring that therapeutic or medical claims associated with medical
cannabis must be supported by substantial clinical evidence or data
and include information on the most significant side effects or risks
associated with use.
The MMCC has promulgated regulations and provided guidance
to licensees to help clarify the restrictions on advertising, and to
guide compliance. The MMCC accepts complaints and reports of
advertisement violations, and will review and investigate, if necessary.
Furthermore, the MMCC accepts proposed advertising materials from
licensees who wish to receive feedback from MMCC staff or a formal
advisory opinion from the full Commission as to whether a proposed
advertisement complies with State law.
Dispensary Agent Training
The MMCC developed a training curriculum as on online resource
to assist dispensary agents with understanding and complying with
medical cannabis sales laws. This training is expected to be available
on the MMCC website in FY2021.
Patient Education Materials
The MMCC developed training materials to address frequently-asked
questions by patients and providers. The materials address: 1)
MMCC and Program overview; 2) How to become a medical cannabis
patient; 3) Laboratory testing and medical cannabis products;
4) Bureau of Enforcement and Compliance responsibilities; and 5) Medical
cannabis advertising requirements for licensees, certifying providers
and third-party vendors. The materials will be made available via our
website and by request in hardcopy.
19
Looking to the future, the MMCC has many exciting initiatives planned and
currently in progress for FY2021. Such initiatives include the processing and
distribution of edible medical cannabis products, measures to help reduce and
streamline administrative processes for medical cannabis businesses, and the issu-
ance of a grant for the data collection and evaluation of health outcomes of medical
cannabis patients. The MMCC also plans to standardize Program best practices across
jurisdictions through collaboration with regulators across the country.
In light of continued programmatic growth, and the potential for
legalization of adult-use cannabis on the horizon, the MMCC awarded two competitive
procurements to analyze and report on: 1) the health and public safety effects
of legalizing adult-use cannabis, and the impact legalization may have on the
Program; and 2) the current and future size of the Program, and the economic
impact of legalizing adult-use cannabis in Maryland. These reports will assist the
MMCC in analyzing Program strengths and gaps, refining a regulatory framework
that will enhance public health goals, minimizing the opportunity for diversion to
the illicit market, and making other recommendations for overall programmatic
improvement.
The MMCC greatly appreciates the strong commitment demonstrated by the
Maryland General Assembly, industry partners, and the community through
ongoing efforts to support us in providing a high-quality, accessible medical
cannabis program in Maryland. We hope that this FY2020 Annual Report illustrates
the success of the Maryland Medical Cannabis Program to date, and emboldens us
to move forward with continued progress on behalf of the patients we serve.
Moving Forward Together
20
Operating Principles
. . .Transparency
. . . Communication
. . . Compliance and Quality
. . . Education
. . . Equity
Maryland Medical Cannabis Commission
849 International Drive, 4th Floor, Linthicum, MD 21090
410-487-8100 mmcc.maryland.gov
