Medical Cannabis Implementation Update September 2016

Implementation Timeline Office of Compassionate Use Established: July 1, 2014 Florida Administrative Code Chapter 64-4 Promulgated, Final Rule Upheld: May 28, 2015 Dispensing Organization Applications Accepted: July 8, 2015 Five Approved Dispensing Organizations Announced: Nov. 23, 2015 All Five Initial Dispensing Organizations Request Cultivation Authorization: Feb. 5, 2016 Governor Scott signs HB 307 (Chapter 2016-126, Laws of Florida) into Law: Mar 25, 2016 The Green Solution (San Felasco Nursery) Approved: Apr 6, 2016

6 Approved Dispensing Organizations Northwest Region: Trulieve (Gadsden) Northeast Region: CHT Medical (Alachua) The Green Solution (Alachua) Central Region: Knox Medical (Orange) Southwest Region: Surterra Therapeutics (Hillsborough & Leon) Southeast Region: Modern Health Concepts (Miami-Dade)

Implementation Timeline Dispensing Organizations Granted Cultivation Authorization: Surterra Therapeutics (Alpha Foliage) Feb 11, 2016 Trulieve (Hackney Nursery) Feb 29, 2016 Modern Health Concepts (Costa Nursery Farms) Mar 14, 2016 Knox Medical (Knox Nursery) May 13, 2016 CHT Medical (Chestnut Hill Tree Farm) May 22, 2016 The Green Solution (San Felasco Nurseries) July, 09, 2016 Dispensing Organizations Granted Dispensing Authorizations: Trulieve (Hackney Nursery) July 20, 2016 Surterra Therapeutics (Alpha Foliage) July 27, 2016 Modern Health Concepts (Costa) September 9, 2016 First Dispensing Organization Began Dispensing: July 23, 2016

What is a Dispensing Organization? The only entities in Florida that can grow, process, or sell cannabis. Vertically integrated: Dispensing organizations are vertically integrated businesses meaning they must cultivate, process, and dispense the low-THC and medical cannabis. Statewide dispensing: Dispensing organizations who have been granted dispensing authorization may dispense statewide.

Projected Dispensing Locations Northwest Region: Central Region: - Panama City - Pensacola - Quincy - Tallahassee - Daytona - Orlando - Palm Bay Southeast Region: - Miami-metro - Port St. Lucie - Fort Lauderdale - West Palm Beach Northeast Region: Southwest Region: - Gainesville - Jacksonville - Ocala - Orange Park Cape Coral Sarasota St. Petersburg Tampa

Who Qualifies? Patient Requirements: Low-THC Cannabis: Must be diagnosed with a qualifying condition (outlined below) Must be a Florida resident Must be a patient of the ordering physician for the immediately preceding 3 months Low-THC Cannabis: Cancer Epilepsy Chronic seizures Chronic muscle spasms Medical Cannabis: Terminal Conditions * Two physicians must certify that a patient’s condition will be fatal within one year, if it runs its normal course.

Who Can Order Cannabis? Only qualifying physicians may order low-THC and medical cannabis for patients Qualifying physicians must: Have an active, unrestricted license under Chapters 458 or 459, Florida Statutes Complete an 8 hour course and examination provided by the Florida Medical Association and Florida Osteopathic Medical Association Treat a patient for at least 3 months before patients registration in the registry Obtain voluntary, written informed consent from the patient/legal representative Maintain a patient treatment plan for each patient and submit the plan quarterly to the University of Florida School of Pharmacy Order no more than a 45-day supply for patients Medical Directors employed by a Dispensing Organization may not order cannabis for patients

How Does It Work? Step 1: A physician diagnoses a patient with a qualifying condition. Step 2: After treating a patient for at least 3 months, and obtaining voluntary, written informed consent, a physician enters an order for no more than a 45 day supply of low-THC, medical cannabis, or a cannabis delivery device into the Compassionate Use Registry. Step 3: The ordering physician must submit a patient treatment plan quarterly to the University of Florida School of Pharmacy. The patient treatment plan must be updated in the Compassionate and submitted to the UF School of Pharmacy within 7 days of any change. Step 4: A patient may fill his or her order at any dispensary operated by one of Florida’s six approved dispensing organizations.

Illegal Activity What is not authorized “medical use” Smoking cannabis (but vaporizer is allowed) Cannabis ordered by anyone other than a qualified physician, through the Compassionate Use Registry Cannabis dispensed by anyone other than one of the six approved dispensing organizations Transfer to anyone other than the qualified patient or their legal representative Use or administration of a low-THC or medical cannabis product on public transportation, in public, in place of employment, in correctional institutions, on the grounds of a school, on a school bus, or in a vehicle, aircraft or motorboat. Home Grows

Compassionate Use Registry All law enforcement organizations may request access to the Compassionate Use Patient Registry Law enforcement organizations may designate a “master user” that has the ability to create and manage users for their organization Law enforcement users may search for patients (and legal representatives) in the Compassionate Use Registry To perform a search, you must supply the first and last names of the person you wish to search for, and also their Date of Birth The patient results page will show you whether or not the person you searched for is authorized to possess cannabis, and a cannabis delivery devices

Potential Anticipated Violations “Dispensing” from any organization that is not one of the 6 approved organizations Physicians “ordering” outside of the confines of the Compassionate Use Registry Physicians “ordering” for patients not registered in the Compassionate Use Registry Physicians ordering more than a 45-day supply Medical Directors of the approved dispensing organizations may be subject to discipline for some or all violations committed by the dispensing organizations or their employees