The delays in implementing New Hampshire’s medical marijuana program have been very frustrating for patients. Fortunately, the state finally appears to be making progress toward the adoption of alternative treatment center (dispensary) rules. The Concord Monitor reported some details of the rule-making process this morning.
You can read the first draft of the proposed rules here. The Department of Health and Human Services will accept comments as part of an “advance comment period,” which ends tomorrow. After that, the department will enter its formal rule-making phase, which will include a public hearing and additional opportunities for public comment. The department released a timeline indicating that it hopes to secure final approval of the dispensary rules by November 20.
You can read the comments being submitted by MPP here. While we have identified a number of issues with the rules, we think the most troubling provisions are the onerous application fee of $80,000 and the annual renewal fee of $80,000. We understand that the law requires the Department to set fees that cover the costs of administering the program, but it is unclear whether New Hampshire will have any qualified applicants who wish to enter this heavily restricted dispensary market with fees this high.
For information on how to submit comments, please visit the department’s website for the “therapeutic use of cannabis” program.