The cannabis license application is just the first of many steps in the process to becoming a licenced cannabis business. A business at the licensing process stage will already have had to build a fully operational site (e.g. a warehouse, greenhouse, or elsewhere), create and submit a site-evidence package, and submit additional supporting documentation. Once your application review process begins, additional measures may need to be taken. In cases where an application is incomplete, you may receive a Request for More Information (RMI) Notice or an Intent to Refuse (ITF) Notice. If you receive one of these memos, there’s no need to panic, the cannabis consulting team at GrowerIQ is here to help.
How Can our Cannabis Consulting Experts Help You Respond to RMI and ITF Notices?
- Review cannabis application submission to identify issues
- Strategize and prepare formal responses to RMI and ITF Notices
- Communicate with regulators and participate in teleconferences to support you
- Fill gaps like missing SOPs and make updates to documents
What are Request for More Information (RMI) Notices?
One or more RMI Notices may be issued by the regulatory authority if there is information in your application that is unclear or requires further details to show compliance with regulatory requirements. RMI Notices will require you to respond with additional information, amendments to your application, and/or clarifications that must be submitted as a formal response.
A response to an RMI Notice needs to be provided within a period of two to four weeks, but in some situations, you can get an extension if there is a good reason. The expert cannabis business and cultivation consultants at GrowerIQ can help you communicate with regulators and offers administrative support when communicating with stakeholders and/or authorities. We can also help craft your formal response. This process starts by assessing your application and filling in any gaps like missing SOPs and making updates to documents. We stand by you throughout the process of responding to notices.
Health Canada Requirements for Responses to RMIs
- Must respond within the specified timeframe
- Comprehensive responses must address all comments on each element noted
- May require document revisions or additional visual or written documentation
- May require submission of a tabular or report format document
- The response must be specific and comprehensive
What are Intent to Refuse (ITF) Notices?
In situations where regulating authorities cannot proceed with your application as-is, they may send an ITF Notice. ITF Notices are similar to RMI Notices in that the regulator will provide you with a timeframe to respond within and after that timeframe, a decision on refusal will be made. The most common reason for receiving an ITF Notice is an incomplete cannabis application. Once again, cannabis consultants can help you assess your existing submission and fill the gaps within the allotted timeframe. Our clients will always have our full support in crafting a response and communicating with regulators.
Working With GrowerIQ Cannabis Consulting Team
The team at GrowerIQ includes experienced cannabis consultants and quality assurance personnel. We have a deep understanding of regulations, including the nuances. While not all cannabis license applicants will opt to work with a consultant from the beginning of their application, you are welcome to reach out to us at any time in the licensing process if an issue does arise.
Health Canada. Application requirements for cannabis cultivation, processing and medical sales licences. Canada.ca. Published 2018. Accessed May 9, 2021.
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