We have reviewed latest Qualified Patient/Primary Caregiver Rules released by DHSS and have a list of suggestions we believe the the department should pursue. You can read the preliminary rules here, and you can email your suggestions to MedicalMarijuanainfo@health.mo.gov
(2) Missouri Identification Number should be sufficient to fulfill the Constitutional mandated requirements for residency in the state.
Suggestion
Revamp the home inspection rules
Patient privacy rights are paramount, and it’s imperative that the department set policies that follow basic civil rights protections. Policies that include reasonable suspicion, 24 notice for suspected minor infraction violations, and DHSS retains control of the home inspection. In some cases, patients are in treatment for long periods of time, immediate access will not be possible.
2 (B) 6 A and B
Suggestion
Delete
A signed statement coupled with the doctor’s recommendation should suffice as proof that the person is the caregiver to the minor child.
(3)(B) B
Suggestion
Allow for 14 days for a patient to provide any missing documentation.
3)(B) C
Suggestion
Replace revoked with suspended
(3)(B) E
Suggestion
Delete Felony Disenfranchisement from the guidelines. Medical Marijina use is a right under the Missouri Constitution.
(3)(B) G
Suggestion
Revamp the home inspection rules
Patient privacy rights are paramount, and it’s imperative that the department set policies that follow basic civil rights protections. Policies that include reasonable suspicion, 24 notice for suspected minor infraction violations, and DHSS retains control of the home inspection. In some cases, patients are in treatment for long periods of time, immediate access will not be possible.
(3)(B) H
Suggestion
“timely manner” is vague and can lead to confusion. 7 days is a reasonable amount of time for a patient to discover his card is lost or stolen.
(3)(B) J
Suggestion
Good cause is vague. Outline what behaviors will result in a card being suspended.
4(7) C
Suggestion
Allow the patient 14 days to notify the department. Oftentimes this will be family members grieving over the loss of a family member.