On May 13, 2019, the New Jersey Department of Health (NJDOH) announced amendments to the state’s medical marijuana rules aimed at expanding access to the program, which implements New Jersey’s Compassionate Use Medical Marijuana Act. Perhaps most significant among the adopted amendments is the creation of a separate permitting system for cultivation, manufacturing and dispensing marijuana for medical purposes. Previously, the program was vertically integrated, i.e. all three were packaged together under a single licensing process. This, coupled with the fact that the legislature did not take action on either the medical expansion bill or the adult use bill, fuels speculation that additional Requests for Applications (RFA) may be coming soon from the NJDOH.
The rule changes follow the NJDOH's recommended regulatory actions in response to Governor Phil Murphy's issuing Executive Order No. 6, in which he ordered a 60-day review of all aspects of New Jersey’s current program, “with a focus on ways to expand access to marijuana for medical purposes.” In response to Executive Order No. 6, NJDOH released its EO 6 Report on March 23, 2018, which proposed significant changes to the existing medicinal program. In an effort to create greater patient access, the state immediately put into effect some of the recommended changes, including cutting registration and renewal fees and expanding qualifying conditions.