ID Scanning for Missouri Cannabis Dispensaries: 19 CSR 100-1.180
The first day of recreational cannabis sales in Missouri was February 3, 2023. Medical cannabis has been legal since 2018. The compliance landscape for cannabis dispensaries in Missouri is rapidly evolving to meet the needs of a changing consumer base.
In an effort to better regulate and control both medical and recreational marijuana facilities, the Division of Cannabis Regulation has proposed new guidelines, 19 CSR 100-1.180, which requires ID scanning for cannabis dispensaries in Missouri.
What Does 19 CSR 100-1.180 Say?
There are multiple new regulations, but pertaining to ID and medical marijuana card scanning in Missouri, here’s what your dispensary needs to know.
“On May 1, 2023, the Department extended the January 20th waiver regarding 19 CSR 100-1.180(2)(D)2.D which requires dispensary licensee to scan Department-issued IDs using a barcode scanner. The waiver has been extended to May 31, 2023.
The aforementioned rule outlines the requirement for dispensary licensees, at the time of sale or distribution, to scan department-issued identification card barcodes in order to adequately track purchases in the statewide track and trace system (METRC) for transactions involving a qualifying patient, primary caregiver, or personal cultivation purchase.
For a dispensary licensee to be in compliance with this rule, a licensee must use a barcode scanner to record the department-issued identification card information into the statewide track and trace system at the time of the sales transaction. A licensee would not be in compliance if the number from the department-issued identification card is manually recorded into the statewide track and trace system at the time of the sales transaction.
The intent of this rule is to ensure that a department-issued identification card number is accurately recorded into the statewide track and trace system to minimize errors involving patient, primary caregiver and personal cultivation purchases and allotments.”
What Does This Mean?
Simply put, you will now be required to scan the ID of every medical patron (possibly every patron regardless of recreational or medical) using a barcode scanner before completion of the sale. This is in an effort to ensure all transactions are recorded in METRC. The IDs must be recorded via an ID scanner to ensure accuracy and eliminate human error and typos.
The language around ID scanning mostly references scanning the ID of a patient or caregiver, which implies this new regulation might only be applicable to medical customers. Our team is actively working to achieve clarity on this regulation.
There is some speculation as to whether the rule is only applicable for medical customers or all customers. The language around ID Scanning mostly references scanning the ID of a patient or caregiver, so at this time, we believe it is only for medical patients. That being said, we are actively working to confirm or deny this assumption. In the event that the regulation speaks only to scanning of MMJ cards, this would be the only state in the country that requires MMJ card scanning, but not government-issued IDs.
How to Remain Compliant
Step one to ensuring compliance is purchasing an ID scanner capable of reading the 2D barcode present on a Missouri medical cannabis card. These same ID scanners will also be capable of scanning and performing 2D barcode security on government issued IDs and driver’s licenses. The options below are our top recommendations that other dispensaries across the country currently use successfully.
The E-Seek M280 is a unique scanner because it is multipurpose. Not only can it scan state driver’s licenses, government-issued IDs, and medical cards, but it can also capture images of these and other documents that fit on the flatbed portion of the device. Physiscal documents can be scanned on the scratch-resistant glass and saved under a specific customer profile using the combination of the M-280 and VeriScan Enterprise visitor management platform.
*If your customers typically use an MMJ card on their phone then the E-Seek M280 may not be the best choice, as it has difficulty scanning a barcode on a screen.
The Unitech PA768 is the newest handheld scanner to join our ranks. The rugged, heavy duty design protects the device against things like dust, water spills, moisture, and even drops. This handheld device scans both IDs and passports, as well as other forms of identification such as military ID cards, permanent resident cards, and state issued IDs. The versatility in the types of identification that can be scanned on the PA768 make it an excellent choice for those dispensaries with a large number of international customers.
The Unitech PA768 features a 5100mAh rechargeable battery with a run time of about 20 hours, more or less, between charges. It runs in conjunction with our VeriScan Enterprise application that allows the users to scan IDs, check for validity, and even tag customers as frequent customers or problem patrons.
The Thales AT10K is a full page passport and document reader is arguably one of the best on the market. The desktop scanner is perfect for those dispensaries needing to capture and authenticate all North American drivers licenses, state-issued IDs, and read and parse data from MMJ cards, global passports, and other types of identity documents.
The AT10K is efficient from a business perspective, but also a customer perspective. With built in LED “landing lights”, customers are easily guided to proper placement of documents upon the scanner, as well as a green signal when they are able to remove their document from the scanner. The anti-glare technology is able to reduce document reflections and ambient light so that the images are captured with as much accuracy as possible.
We are monitoring the changes in the Missouri marijuana regulations constantly, and will continue to update our comprehensive guide to ID scanning laws for dispensaries. The deadline to obtain your scanning device to ensure compliance is May 31, 2023.