Department of Health Releases Applications for up to 24 Alternative Treatment Center Permits and Endorsements
On Monday, July 15, 2019, the Department of Health released the application for its Request for Applications “(RFA”) for up to 24 new alternative treatment center permits and endorsements in New Jersey. With the enactment of the Jake Honig Compassionate Use Medical Cannabis Act, this RFA provides potentially one of the last opportunities for an applicant to be awarded a cultivation endorsement or a vertically integrated permit over the next two years.
The Department of Health intends to issue the following endorsements and permits in each region in New Jersey:
North Region: 2 cultivation endorsements, 5 dispensary endorsements, and 1 vertically integrated permit.
Central Region: 2 cultivation endorsements, 5 dispensary endorsements, and 1 vertically integrated permit.
South Region: 1 cultivation endorsement, 5 dispensary endorsements, and 1 vertically integrated permit.
The Department will also be issuing a fourth vertically integrated permit based on best overall score and patient need at the time of the award. The region for the fourth vertically integrated permit will be determined at the time of the award.
No individual manufacturing endorsements will be awarded in this round.
There are some significant differences between this RFA and the RFA administered by the Department last August. For example, unlike the August 2018 RFA, applicants for a vertically integrated permit may only submit one application for a vertically integrated permit in one region. Applicants for cultivation and dispensary endorsements may submit more than one application; however, only one application for a cultivation endorsement is permitted, and an applicant cannot submit more than one application for an endorsement per region.
Unlike the August 2018 RFA, there is no Application Part B form. Applicants are to draft their own Part B based on the criteria set forth in the RFA. The other application materials – Application Part A, the Personal History Disclosure, Affidavit, Waiver, and Release – are nearly identical to the forms from the August 2018 RFA.
Due to the recent enactment of the Jake Honig Compassionate Use Medical Cannabis Act, this RFA may present one of the last opportunities to obtain a cultivation endorsement or vertically integrated permit for some time. The Act restricts the number and type of permits that may be issued within the first 18 months of the Act’s effective date. Thus, in the first 18 months of the Act, and with very limited exception, vertically integrated permits will not be issued, and the number of cultivation endorsements – including those already awarded – are capped at 28.
Applications for a dispensary endorsement will be due on August 21, 2019 by 3 PM. Applications for a cultivation endorsement and a vertically integrated permit will be due on August 22, 2019 by 3 PM.
Riker Danzig Cannabis Law Practice
Samuel P. Moulthrop, Partner
Mary Kathryn Roberts, Partner
Jason D. Navarino, Partner
Ryan M. Magee, Associate
Cristin M. Boyle, Associate
Hannah Greendyk, Associate