Reader Q&A with Fred Moosally
Fred Moosally, the Alcoholic Beverage and Cannabis Administration (ABCA) director, recently responded to a wide range of stakeholder questions regarding medical cannabis data security, licensing, social equity, and product availability in the District of Columbia. Below are ABCA’s responses.
Legal Liability & Data Handling
When individuals apply for temporary (3-day to 1-month) medical cannabis cards, what personal data is retained by ABCA, and for how long? How does the agency protect this data, especially for out-of-state patients or those concerned about federal disclosures (e.g., gun ownership)?
Program participant information is self-provided to ABCA and maintained securely by the agency in accordance with the District’s data and records retention policy. ABCA does not disclose personal data submitted by patients or caregivers to any government or private entity including licensed Retailers. Retailers complete product transactions using unique patient numbers through Metrc, which is ABCA’s seed-to-sale medical cannabis tracking platform. No personally identifiable information is used by or stored in Metrc. Additionally, face photos are no longer being included on digital or physical registrations.
Will ABCA consider allowing anonymous or pseudonymous registration for individuals hesitant to join the program due to privacy or data security concerns?
Patients and caregivers must present a valid government-issued photo identification that includes the name matching their registration to be able to purchase medical cannabis products from licensed Retailers in DC. Accordingly, program participants must register using their legal first and last name. Additionally, ABCA must be able to verify each applicant’s age and residency, and match healthcare recommendations if submitted. Patient information is securely maintained and protected by the agency and not shared with other District or federal agencies.
Agency Response & Program Operations
ABCA employs a team of highly trained and professional licensing specialists responsible for responding to email and phone inquiries. If a communication is overlooked, program participants should follow up on their initial inquiry by emailing ABCA.CannabisInfo@dc.gov or calling 202.442.4423.
Will ABCA consider waiving or reducing registration and renewal fees for D.C. residents, especially those applying for patient cards, to encourage greater participation?
Patient registration in the medical cannabis program is currently free for DC residents until November 6, 2025. Non-DC residents may register in the program for a fee ranging between $10-$100 based on the valid period they select.
Licensing & Compliance
Can a social equity license be transferred to another individual who also qualifies under the social equity criteria?
Yes, a license approved for a social equity applicant or an unlicensed establishment can be transferred three (3) years after issuance. If the
license is transferred to a non-medical cannabis certified business enterprise or non-social equity applicant, the new owner is required to repay any grants or loans provided by the District to the medical cannabis certified business enterprise or social equity applicant and pay ABCA any waived licensing and application fees.
Will ABCA provide clearer pathways for forming social equity collectives, particularly for cultivation and manufacturing operations where zoning and property constraints make multi-tenant use difficult?
The medical cannabis regulations currently permit separately licensed medical cannabis businesses to locate in the same building or space, provided they maintain separate books and records, maintain separate inventory, and ensure that they have their own secure and distinct premises that is separated at a minimum by a fixed boundary.
ABCA previously committed to allowing cultivators to obtain manufacturing licenses through endorsements. Will similar vertical integration pathways be made available to retailers to support brand development?
The Medical Cannabis Retailer Craft Preparation Endorsement Act of 2025 proposes to create a new endorsement type that would support brand development by allowing licensed Retailers to engage in some aspects of manufacturing. This includes licensed retailers being able to make prerolls, baked goods, beverages, chocolates, confections, lotions, soaps, ointments, and other products. This legislation was introduced at the Council of the District of Columbia on May 22, 2025.
Will ABCA extend conditional licenses (cultivation/manufacturing) that are set to expire in October 2025?
The two-year period for conditional licenses is established by statute and would require legislation adopted by the Council of the District of Columbia to be extended. ABCA will notify conditional license holders in the event that legislation is enacted that extends the existing two-year period.
What is the agency’s position on automatic or needs-based extensions of expiration dates?
The District’s medical cannabis laws contain both automatic and case-by-case extension provisions. ABCA is able to implement both automatic and case-by-case expiration date provisions.
Some patients receive multiple temporary (30-day) cards without being upgraded to a permanent 2-year card. Is there a fix or timeline for resolving this issue?
To address this issue, the valid period for temporary patient and caregiver registrations was extended from 30 to 90 days from the date of issuance, effective July 17, 2025. Temporary patient registrations issued on or after April 18, 2025, and prior to July 17, 2025, are now valid for ninety (90) days after the date of issuance, regardless of the expiration date printed on the temporary patient registration. Impacted patients or caregivers do not need to request an updated temporary registration.
Can ABCA provide a simple method for licensees to verify whether their licenses are in good standing and whether any fees are due?
ABCA plans to launch an online system powered by Salesforce in FY 2026 that will allow licensees to check on the status of their account with the agency. The new system will significantly enhance how business owners, program participants, and residents interact with ABCA.
Craft Cannabis & Endorsements
When will ABCA issue guidance on the Craft Cannabis Cultivation Endorsement?
The Medical Cannabis Retailer Craft Preparation Endorsement Act of 2025 was introduced at the Council of the District of Columbia on May 22, 2025. The legislation needs to be adopted by the Council and signed by the Mayor prior to taking effect. ABCA will issue guidance regarding this endorsement should the legislation be enacted by the Council and signed by the Mayor.
Social Equity Fund Implementation
ABCA and city leadership previously promised to establish and fund a social equity program. What steps are being taken to fulfill this commitment, and will the FY2026 budget include allocations for such a fund?
The District’s FY26 budget and the corresponding Fiscal Year 2026 Budget Support Act of 2025 eliminated the Medical Cannabis Social Equity Fund.
Accountability & Market Oversight
What safeguards exist to prevent grant recipients — particularly those with prior illicit market histories — from misusing public funding or diverting product to the unregulated market?
ABCA does not have a grant making or grant administration role or function.
In a limited market with only 7–8 cultivators, how does ABCA justify exclusive partnership agreements (e.g., first access to drops)? Will ABCA implement purchase quotas or equitable distribution rules to ensure a level playing field for all retailers?
A prohibition on partnership agreements or the implementation of purchase quotas would require the adoption of legislation by the Council of the District of Columbia.
Multi-State Operators
What is ABCA’s policy regarding the entry of MSOs (e.g., Cookies) into the D.C. market?
*Editors note: Cookies D.C. contacted the Outlaw to highlight that they have a brand licensing deal with Cookies. Cookies doesn’t supply or own part of the D.C. business.
ABCA supports a business environment that provides for a diverse variety of product options for licensed retailers to sell to meet the needs of registered medical cannabis patients.
Will MSOs be permitted to launch exclusive products with D.C.-based cultivators/manufacturers before the local market reaches stability and equity for small businesses?
Current district law does not prohibit licensed cultivation centers and manufacturers from entering into written agreements with other cannabis brands provided the cannabis product is cultivated and manufactured in the District of Columbia at the licensed facility.
Product Availability & Consumer Access
Will ABCA issue guidance or updates to support organic growers who meet health and safety standards?
ABCA does not currently plan to issue specific guidelines for organic cultivators. All licensed Cultivation Centers and Manufacturers regardless of niche are required to adhere to DC’s manufacturing laws and regulations including product testing requirements.
Is there a pathway for home growers to have their product tested and sold through licensed dispensaries, especially considering their foundational role in D.C.’s cannabis culture?
Not currently. There are several factors that preclude home growers from entering the licensed market including zoning restrictions, security requirements, seed-to-sale tracking requirements, and the need for ABCA investigators and other District agencies to be able to access grow facilities to conduct inspections without notice.
What steps is ABCA taking to improve product variety and affordability in medical dispensaries, particularly those that transitioned from the I-71 market? Many dispensaries are struggling due to lack of inventory diversity — how will ABCA address this?
The Medical Cannabis Retailer Craft Preparation Endorsement Act of 2025 was introduced at the Council on May 22, 2025 to help address this issue. The legislation helps to increase product variety by creating a new endorsement type that allows licensed Retailers to engage in some aspects of manufacturing. This includes licensed retailers being able to make prerolls, baked goods, beverages, chocolates, confections, lotions, soaps, ointments, and other products.
Can dispensary check-in areas or adjacent spaces be monetized as ancillary (non-THC) businesses focused on health and wellness? Is there an official list of non-cannabis products that medical dispensaries are permitted to sell (e.g., accessories, supplements, health items)?
The Alcoholic Beverage and Cannabis Board will be issuing proposed rules later this year that set forth the types of non-cannabis products that can be sold at licensed dispensaries. The proposed rules will be published in the D.C. register and undergo a 30-day public comment period that will provide an opportunity for businesses and the public to provide feedback to the Board.
