The number of Canadians registering to purchase cannabis for medical purposes from licensed producers has been declining since legalization, while the number registered to grow their own medical cannabis or assign someone to do so on their behalf has increased.
The newest figures from Health Canada show the number of medical client registrations with federally licensed sellers fell 9% from 292,399 in March 2021 to 264,686 in September 2021. In the same timeframe, the number of individuals registered with Health Canada for personal and designated cultivation of cannabis for their own medical purposes increased 19% from 39,525 to 47,147.
Although the number of active registrations has fluctuated since the legalization of cannabis for non-medical purposes in October 2018, the overall trend has shown a decline in active medical client registrations and an increase in registrations for personal or designated production.
In October 2018, there were 345,520 active client registrations with a federal licence holder, peaking at 377,024 in September 2020.
There were 25,945 active personal/designated production registrations in October 2018, peaking and 47,147 as of September 2021.
The majority of the increase in registrations for personal/designated production is from three provinces; Ontario with an increase of 2,287 registrations, Quebec with an increase of 2,155, and British Columbia with an increase of 2,028, all compared to March 2021.
Canadians have been able to access cannabis for medical purposes from licensed producers since 2013 (MMPR) and have been able to grow their own or designate someone to do so on their behalf for even longer (MMAR). Although this personal and designated production allowance was discontinued in 2014, it was successfully challenged in court and implemented in 2017 (ACMPR).
A “concerning” trend
Although the average daily prescribed amount of cannabis under the medical cannabis program is about 2 grams, the average daily amount authorized by health care practitioners for individuals who are registered with Health Canada for personal or designated production was 45.3 grams per day.
Health Canada argues that this discrepancy can, in some cases, undermine the integrity of the system that many patients and health care practitioners rely on for access to medical cannabis.
While there were 7,464 health care practitioners associated with registrations made in the past year with federally licensed sellers, only 1,963 health care practitioners (hcp) were associated with active personal/designated production registrations.
Of these hcp’s associated with personal or designated production registrations, 424 authorized amounts equal to or above 25 grams per day, and 35 authorized amounts equal to or above 100 grams per day.
The majority (97%) of health care practitioners having authorized amounts equal to or above 100 grams per day were located in British Columbia and Ontario.
In order to address these differences, Health Canada began sharing data on the number of health care practitioners and the daily amounts authorized with the provincial and territorial medical regulatory authorities in May and June 2019.
As one example of enforcement from a provincial agency, in 2020 the Saskatchewan College of Physicians and Surgeons levied a $15,000 fine and disciplinary action against a Saskatchewan doctor found to have prescribed cannabis to nearly 1,000 patients over six weeks in 2017 while working in Saskatoon.
Processing times slowed due to COVID-19
Prior to COVID-19 measures implemented in March 2020 that redirected many of Health Canada’s resources, more than 90% of licence applications were processed within 8 weeks.
That number dropped significantly in April 2020 to only 12%, down to 0% in July 2020, before picking up speed again by January 2021 (45%). By September 2021 that number was up to over 82%.
Import and Export of medical cannabis
The amount of cannabis exported from Canada has seen significant increases in the past few years, from only 20kg in November 2018 to 3,170.24kg in September 2021. Health Canada only allows export of cannabis into jurisdictions that have a similar federal regulatory system as Canada and currently that only applies to medical cannabis.
Health Canada also allows very limited imports of cannabis into the country for limited research or medical purposes. Around 25kg have been imported for these purposes since October 2018.