Medical Cannabis Operators and Caregiver Facilities
MRTA Article 3, Sections 33, 34, 35, 36
These sections govern who may assist certified medical cannabis patients, how Registered Organizations (ROs) operate, how medical operators register with the State, and what reporting is required to remain compliant.
This is the operational framework for New York’s medical cannabis supply chain.
What This Covers
- Designated caregiver facilities and their limitations
- What Registered Organizations are authorized to do
- How medical cannabis operators register or amend registration
- Ongoing reporting and disclosure obligations for ROs
Jump To
- Designated Caregiver Facilities (Section 33)
- Registered Organizations (Section 34)
- Registration of Registered Organizations (Section 35)
- Required Reporting by Registered Organizations (Section 36)
Designated Caregiver Facilities (Section 33)
This section allows certain facilities to assist certified patients with medical cannabis.
A designated caregiver facility may:
- Assist with handling, storage, and administration of medical cannabis
- Serve only certified patients
To operate, a facility must:
- Apply for approval through OCM
- Maintain secure storage and handling procedures
- Ensure assistance is provided only to certified patients
- Train staff in accordance with OCM requirements
Facilities may not administer or store cannabis unless they are formally approved and registered with OCM.
Registered Organizations (Section 34)
Registered Organizations are the medical cannabis operators authorized by the State.
An RO may:
- Cultivate cannabis
- Process and manufacture medical cannabis products
- Dispense medical cannabis to certified patients and caregivers
An RO must:
- Be registered with OCM
- Comply with all medical program requirements under Article 3
Registration as an RO does not authorize participation in the adult-use market without separate approval under adult-use licensing provisions.
Registration of Registered Organizations (Section 35)
This section defines how an RO becomes registered or amends an existing registration.
Applicants and registered ROs must submit:
- Ownership and True Party of Interest information
- Facility and operational plans
- Security procedures
- Compliance documentation
ROs must report and seek approval for major changes, including:
- New or modified locations
- Ownership or control changes
- Business restructuring
- Management or operational changes
Failure to update OCM constitutes a violation of medical program requirements.
Required Reporting by Registered Organizations (Section 36)
This section requires ongoing reporting to maintain compliance.
ROs must submit reports covering:
- Cultivation and processing activity
- Sales and dispensing data
- Inventory tracking
- Pricing and product information
- Financial and operational data
- Incident and security reports
These reports allow OCM to monitor compliance and ensure the integrity of the medical cannabis program.
What Operators Usually Miss
- Caregiver facilities must be formally approved
- RO registration does not include adult-use authority
- Ownership and control changes must be reported
- Reporting obligations are ongoing, not periodic only
When This Comes Up
- Registering or amending a medical cannabis operation
- Adding facilities or changing ownership
- OCM audits or compliance reviews
- Medical-to-adult-use transition planning
What Happens If You Ignore This
- Registration violations
- Enforcement action
- Suspension or revocation of registration
- Loss of authority to operate under the medical program
Related Pages
Source Material
- Cannabis Law (MRTA), Article 3, Sections 33, 34, 35, 36
