While regulating medical marijuana did present some challenges, it also presented opportunities.
But first, let me give you some context, within the Colorado Department of Revenue, there are four mission divisions: 1) the Division of Tax is responsible for assessing and collecting $11 – $13 billion a year; 2) the Division of the Lottery has contributed more than $3 billion to the state of Colorado; 3) the Division of Motor Vehicles issues more than 1 million licenses for drivers and more than 5 million vehicles a year, and 4) the Enforcement Division regulates and oversees the Gaming, Horse Racing, Automotive Dealers, Liquor & Tobacco, and Marijuana industries.
Interestingly, even though my Department was responsible and responsive for so much, the only thing most people wanted to talk about was marijuana regulation!
As a former regulatory attorney, it was fascinating to regulate medical marijuana – this is an emerging market with a product that is still illegal at the federal level. Medical marijuana legalization brought out very strong views from most people – they were either in favor of it or opposed to it. Very few people were ambivalent about it. But nonetheless, my team and I were responsible for regulating it, and regulating it well.
After I was appointed by the Governor as the Executive Director of the Department and the State Licensing Authority for, among other areas, medical marijuana in 2011, I had to take a deep dive into the requirements of regulating this industry and come up with the best method for doing so.
Schedule I or Schedule II?
One of the most interesting things I did as the State Licensing Authority was on December 22, 2011, when I sent a letter to the Drug Enforcement Agency (“DEA”) requesting reconsideration of medical marijuana from a schedule I controlled substance to a schedule II controlled substance, in recognition of its potential medicinal value. Click to read the reschedule request to the DEA.
It explained Colorado’s medical marijuana history and explained the Colorado Model of Regulation, which provided a rigorous licensing and compliance program complete with fingerprint-based criminal background checks and financial histories of those engaging in the operation of medical marijuana businesses.
On October 10, 2012, I received a response from the DEA stating that it would recognize my request as support for the petition submitted by Governors Gregoire and Chafee in their request, but that “Again, under Federal law, marijuana remains a Schedule I substance with no currently accepted medical use.” Thus, my request was denied.
Upon coming into the Department, I wanted to evaluate what was working and what needed to be tweaked. My style is not to come in to a new position and make changes for the sake of making changes, but rather to see how things are going and then see what needs to be changed.
When coming into a new organization, here are some of the things I evaluate:
- Bench Strength
- Process Improvements
- Customer Service
- Employee Morale
I will talk about these items in more detail in upcoming posts.
Lessons Learned
- When you come into a new organization, identify how you are going to evaluate the organization to determine what, if anything, needs to be changed.
- When coming into a new organization, here are some of the things I evaluate:
- Bench Strength
- Process Improvements
- Customer Service
- Employee Morale
Preview of Upcoming Discussions
Bench Strength, Process Improvements, Customer Service, and Employee Morale are important areas to evaluate when coming into a new organization. I will talk about them in more detail in upcoming posts and provide a list of lessons learned. Stay tuned!