Waivers to Facilitate Safer Patient Access
In response to Executive Order 107, and to facilitate safer patient access to ATCs, the Department of Health (DOH) issued a waiver to all ATCs granting relief from several regulations.
First, the DOH issued a waiver to allow for curbside delivery to ATC patients. This waiver was subject to the following terms and conditions:
- For the purposes of dispensing only, an ATC can dispense to qualified patients and caregivers in their cars outside the premises at the address listed on the ATC’s permit. This includes parking lots and adjacent sidewalks.
- All orders are to be placed in advance, and the products are to be labeled inside the ATC prior to dispensing.
- ATCs must provide pick-up times to reduce traffic.
- While the ATC must still conduct an in-person visual verification of a patient’s registry ID card prior to dispensing, this can take place without handling the ID card, e.g., through a car window.
- The ATC is still responsible for logging the transactions in the registry and inventory in accordance with state regulations.
- All transactions must be conducted in a secure and monitored manner in accordance with state regulations.
- The ATC must notify the local police department of its intention to dispense to patients on the exterior of the premises.
- The ATC must first submit to the DOH its standard operating procedures for (a) taking orders, verifying registry ID and authorization, and taking payment; (b) logging the transaction in the registry and ATC inventory; and (c) the security it will need to facilitate curbside delivery.