Enrolment in Health Canada’s personal cultivation program has nearly doubled in less than three months, according to new figures from the agency. To handle this, Health Canada’s Office of Medical cannabis recently hired 17 new employees to help with processing and responding to questions.
As of May 1, there are now 4,480 Canadians with active registrations for personal or designated cultivation under the agency’s medical cannabis access program. The regulator says the average wait time is now ten weeks, although many patients still report waiting four months or more in some cases. Under the program, Health Canada authorizes registered patients to grow their own cannabis or choose a designated grower.
Enrolment is up significantly from figures Health Canada provided to Lift earlier this year, showing 2,554 individuals allowed to grow their own cannabis or designate someone to do so, with average processing time being about seven weeks.
In response to a request from Lift, Health Canada has provided an update on their personal and designated cultivation licensing program. Lift has been covering this issue since February, looking at wait times that have, according to several patients and physicians, been several months.
Gary Scott Holub, Media Relations Officer for the Government of Canada, says the wait times are dependent on the amount of applications received, as well as if the applications are processed properly by the patient and physician. The agency says they have provided expanded instructions for patients on filling out the associated forms.
Examples of commonly encountered issues include:
medical documents that do not appear to be original;
discrepancies between information in the medical document and the application form;
documents that are not signed by the applicant, or are signed incorrectly; or
the incorrect person is identified as the designated producer.
Holub says Health Canada began accepting applications for personal or designated cultivation in August 2016 and had 15 full time employees working on processing applications for home growing and designated growers during the 2016-2017 fiscal year (ending March 31), out of 74 employees at the Office of Medical Cannabis. They have recently hired 11 new client service representatives to help process applications, and six new client service representatives to respond to questions from Canadians about how to apply, or the status of their application.
Health Canada’s 2017–18 Departmental Plan says they intend to address gaps in regulatory programs like the medical cannabis program and “restore legislative and policy capacity.” Spending for Health Canada has been increasing.
You can read the Q and A below. It has been edited for clarity.
Q1: What are the most current figures for Licenses issued for personal cultivation and for designated production under the ACMPR?
A1: As of May 1, 2017, there were 4,480 individuals with active Health Canada registrations under the Access to Cannabis for Medical Purposes Regulations. This includes 4,148 individuals authorized to produce limited amounts of cannabis for their own medical purposes and 332 individuals who have designated someone to produce it for them.
Q2: How many staff are involved in the personal cultivation approval process?
A2: The Office of Medical Cannabis (OMC) in Health Canada is responsible for developing and implementing legislation, regulations, policies and operational programs that support access to cannabis for medical purposes. As part of these responsibilities, OMC issues registration certificates to Canadians who are authorized by their health care practitioner to produce a limited amount of cannabis for their own medical purposes or on behalf of another individual.
During fiscal year 2016-17, OMC employed 74 individuals, 15 of whom worked full-time on the review of applications and issuance of registration certificates since the new program’s inception on August 24, 2017. Health Canada has recently added 11 new client service representatives to the registration team to increase the team’s capacity to process new and renewal applications from Canadians in a timely manner.
Q3: Lift has been consistently hearing reports of patients waiting several months to get their paperwork approved by Health Canada. Are there specific reasons why such approvals could take several months? What does the approval process entail once a patient's paperwork makes its way to Health Canada?
A3: On average, the processing time is 10 weeks, depending on the complexity of the application. In some cases, the application is processed more quickly or, as you have noted, it can take longer.
The time to review an application and issue a registration certificate is highly dependent upon the number of applications received, and the quality or the completeness of the applications. It also depends on the response time of applicants or health care practitioners, who may be contacted by our client service representatives to verify information or to request additional clarification.
To ensure the requirements specified in the regulations are met, Health Canada must validate the information on the application and the medical document. For example, our client service representatives verify that an original medical document has been provided, that it has been signed by a healthcare practitioner who is authorized by, and in good standing with, a provincial regulatory authority, and that the medical document has not been altered or falsified in any way.
For the benefit of your readers, who may also be applicants, examples of commonly encountered issues include:
- medical documents that do not appear to be original;
- discrepancies between information in the medical document and the application form;
- documents that are not signed by the applicant, or are signed incorrectly; or
- the incorrect person is identified as the designated producer.
To assist patients, the Department has posted a guidance document that provides instructions on how to correctly complete the registration form. In response to patient feedback, Health Canada has also recently updated the sample medical document that individuals can take to their health care practitioner to be completed as an original medical document. Both documents can be found here: www.canada.ca/en/health-canada/topics/production-cannabis-for-your-own-medical-purposes.
As indicated above, Health Canada has recently added 11 new client service representatives to the registration team. An additional 6 client service representatives have also joined the call centre to help respond to questions from Canadians about how to apply or the status of their application.
Health Canada will continue to work with patients and patient advocates to identify and act on opportunities to improve the processing of applications from individuals authorized to produce cannabis for their own medical purposes. We are committed to taking additional measures as necessary to ensure all applications are processed as expeditiously as possible.
Q4: Once a patient has authorization to purchase starting materials from a licensed producer, how often may they purchase their limit in clones or seeds based on their grams-per-day authorization from their doctor? (assuming crop failure, etc.).
A4: Only those individuals who have registered with Health Canada to produce a limited quantity of cannabis for their own medical purposes or to designate someone to produce it for them are permitted to purchase starting materials (plants and seeds) from licensed producers. A designated person is not permitted to register with a licensed producer to purchase starting materials.
The registration certificate provided by Health Canada will indicate the number of cannabis plants that an individual or their designated person, if any, can produce, and this number will determine how much starting materials the registered individuals can purchase. For example, the total number of plants you order from a licensed producer cannot be more than the number authorized on your registration certificate. If you want to order seeds, you may order 3 marijuana seeds for each authorized plant. For example, if you are authorized to produce 5 plants, you may purchase a maximum of 15 seeds. Also, you can order plants and seeds more than once. If your crop is not successful, you can place another order with the same licensed producer for more plants or seeds, but you cannot have more plants at your site than the number identified on your registration certificate.
In addition, the regulations enable individuals, once registered, to obtain an interim supply from a licensed producer while they wait for their plants to produce harvestable product. Individuals registered with Health Canada can become clients of a licensed producer by using a copy of their Health Canada registration certificate to register. Individuals may also continue to access cannabis from a licensed producer while producing their own plants as long as the possession limit of the lesser of 150 grams or 30 times the daily quantity of dried marijuana (or the equivalent in products) is not exceeded. Individuals can only use a Health Canada registration certificate to register with one licensed producer to access interim supply.