April 30, 2014

On March 28, 2014, the Colorado Department of Public Health and Environment (CDPHE) held a town hall meeting with medical
marijuana stakeholders, at which time a procedure to establish medical necessity was introduced to address issues raised by the
Office of the State Auditor. As a result of stakeholder input and the potential of conducting medical marijuana research on various
topics, including dosing, CDPHE has modified its procedure on medical necessity, effective April 30, 2014.

CONTINUING RESEARCH TO ESTABLISH STANDARDS
Insufficient research currently exists to empirically establish appropriate dosing of medical marijuana. The Department supports
Senate Bill 14-155 which creates a medical marijuana research grant program to provide the framework for funding research to
determine the general medical efficacy and appropriate administration of marijuana. Should this bill pass, CDPHE will convene a
Medical Marijuana Scientific Advisory Group to assist in overseeing the grants program and review research as it is made available.

MEDICAL NECESSITY DOCUMENTATION NOT REQUIRED
Medical necessity documentation will no longer be required for patients with increased plant/ounce count recommendations,
however; submission of this information may provide helpful data for establishing treatment trends and standards of care. The
Department is developing a comprehensive, confidential data repository, which includes clinical, medical, provider, and anecdotal
data on what may constitute medical necessity regarding medical marijuana. While CDPHE has not received published peer review
studies as of April 1, 2014 on the appropriate dosing of medical marijuana and how that relates to plant/ounce counts, we will
collect and review any such studies submitted to the Department, in addition to any medical documentation for those patients who
choose to share their records to increase public health knowledge. These medical records will remain confidential and will only be
reviewed by CDPHE physicians. Deidentified, aggregate data and information from stakeholders may also help guide the Medical
Marijuana Scientific Advisory Committee once it is established.

Additionally, as the Department currently has no regulatory framework to assess and verify medical necessity for increased
plant/ounce counts, the Registry will not report plant/ounce counts to law enforcement. Patients with plant counts higher than the
standard of six plants and two ounces are encouraged to keep a copy of their applications, physician certifications and other
documentation submitted to the Registry. Per the Colorado Constitution, Article XVIII, Section 14, paragraph 4(b) For quantities
of marijuana in excess of these amounts, a patient or his or her primary care-giver may raise as an affirmative defense to charges of
violation of state law that such greater amounts were medically necessary to address the patient's debilitating medical condition.

Medical Marijuana Centers are still required to collect the CDPHE physician certification form from patients requesting additional
plant counts pursuant to 12-43.3-901 (2)(II)(e) C.R.S. Failure to do so may result in disciplinary action by the Department of
Revenue against the Medical Marijuana Center.

We appreciate the valuable feedback from more than 150 stakeholders who provided input through the town hall meeting, the
Medical Marijuana Regsitry (MMR) blog, and directly to the Departments physician review team by email and phone calls. Your
feedback strengthens our ability to ensure a high-quality, effective statewide program for legal access to medical marijuana. If you
have any questions about this change in our review process, please email physicianreview@state.co.us.

Regards,



Larry Wolk, MD, MSPH
Executive Director and Chief Medical Officer
Colorado Department of Public Health and Environment