Not long ago, the Michigan Department of Licensing and Regulatory Affairs(LARA) established a newmedical marijuana facility licensing and regulationprogram. As such, LARA also issued an advisory bulletinsetting forth requirements for the transition from medical marijuana caregivers/patients to facility license holders and employees.
Under the Medical Marihuana Facilities Licensing Act(MMFLA), grower and processor facility licensees must have at least two years’ experience as a caregiver or have an active employee with two years’ experience as a caregiver. However, a licensed grower or processor cannot be simultaneously registered as a caregiver and must not employ a registered caregiver.
As a result, LARA requires that, upon being licensed, any caregivers affiliated or employed by a grower or processor must submit a Withdrawal Formto cancel their caregiver status within five business days. New employees also have five business days to submit the caregiver cancellation form. If you are a caregiver who wants to withdraw from the Michigan Medical Marihuana Program(MMMP), be sure to complete the Withdrawal Form and submit it to the MMMP in a timely manner.
Note, however, the MMFLA does not prohibit grower and processor facility licensees from being registered as patients under the MMMP. In addition, such facilities are not prohibited from employing registered patients.
When it comes to secure transporters, the MMFLA requires that to be eligible for a secure transporter license, an applicant and any investors cannot be registered patients or caregivers. This means that applicants for a secure transporter license (and those affiliated with the applicant as investors, direct/indirect owners, partners, officers, directors, managers or members) are required to withdraw from the MMMP registry as caregivers or patients. This must occur before applying for a secure transporter license. If you are a caregiver or patient who now wants a secure transporter license, be sure to submit the Withdrawal Formin a timely fashion.
Meanwhile, the MMFLA does not prohibit provisioning center and safety compliance facility licenses from being registered as patients or caregivers. Nor does the MMFLA prohibit these facilities from employing patients or caregivers.