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Regulation 2 E: WTF #1
Regulation 2(d) 60 day renewal issue
Significant Responsibility: Regulation 2(iii)

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5 CCR 1006-2

Regulation 2 E: WTF #1

The first WTF moment comes with Regulation 2(e).  It says that patients may change their primary care-giver or primary MMC every 30 days.  Yes it really says every 30 days.  This is in direct contradiction 1.200 of the MMED rules. When questioned about this contradiction MMED indicated that "both rules apply."????

Regulation 2(d) 60 day renewal issue

Regulation 2(d) indicates that patients should not renew their registry card sooner than sixty days prior to the expiration date.  If they do, CDPHE considers it a request for a replacement card and NOT a renewal.  They keep you money and make you reapply, and pay again, when the card expires.

Significant Responsibility: Regulation 2(iii)

One of the first things that jumps out, and something that had to be expected, is that the Department adopts the basic caregiver standards from People v Mentch in Regulation 2(iii).  Mentch is a California case that decided that a caregiver needs to provide more services to their patients than medical marijuana. 

5 CCR 1006-2

5 CCR 1006-2 is a Colorado Department of Health regulation.  It can be found on our "MMED AND CDPHE FORMS" page or at the CDPHE website.   These regulations have gone largely unnoticed but will have a major effect on patients, caregivers and MMCs.
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