Compassionate Use Rules Amended — Better, but still unreasonable.

In December 2015, the Department of Public Safety’s Public Safety Commission (PSC) approved reasonable rules to regulate the Texas Compassionate Use Program (T.CUP).

Recently, several proposed changes to those rules were put forward for consideration. The proposed changes were outrageous and would have killed the program. Here are the official comments MPP submitted relating to those unworkable proposals.

Today, the PSC met in Austin to reconsider. Thanks to the great work of advocates around the state, including the caregivers of patients who could benefit from the program, the agency rolled back the worst parts of the proposed rule changes.

The new/amended proposals are still some of the most burdensome in the country, but much better than they were. Here’s a recap. An official copy of the complete text will be available on the DPS website soon.

Licensing Fees:

Original License Application Fee: $6,000
Proposed Change: $1,300,000
Amended Proposal: $488,000

Original Licensing/Renewal Fee: $6,000
Proposed Change: $975,000
Amended Proposal: $318,000

Employee/Manager/Director Registration Fee: $150
Proposed Change: $5,000
Amended Proposal: $500

Seed Source Identification:

Original Rule: Silent on this issue.
Proposed Change: Licensee must disclose the source of their seeds. (This was a MAJOR problem.)
Amended Proposal: Licensees must sign a form that acknowledges federal and state laws about marijuana.

Misc. Notes:

DPS will not require a trooper on site at every location. They will, however, require cannabis businesses to be inspected several times a week. This is overkill, but better than the alternative.

DPS is still committed to only issuing three licenses. This is a disservice and probably the primary reason that the fees are still so high.

While the fees have been dropped significantly, they are still unreasonable. In our official comments to DPS, you’ll find a chart that outlines the fees in other states. As you’ll see, our fees are incredibly high, especially for a state that is only servicing patients with one medical condition and with only low-THC cannabis.

Thanks, everyone, for your advocacy and dedication to good policy in Texas!

 

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