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Illinois Responsible Vendor Case Study
State-Mandated Industry Compliance Training
As the legal medical and recreational cannabis industry expands across Illinois, companies within this new marketplace notice a lack of professional quality training to educate their workforce and maintain compliance. Illinois’ “Cannabis Regulation and Tax Act” provides for the controlled legalization of adult use cannabis in the state.
And the Illinois Department of Financial and Professional Regulation (IDFPR) is charged under the Act with implementing and administering multiple aspects of the “Adult Use Cannabis Program,” including the licensing and oversight of dispensing organizations, dispensary agents, and agent education providers.
Recently, Green CulturED partnered with Elevated Education bring to market the Illinois Responsible Vendor training, the first-ever comprehensive training program required for cannabis industry workers in the state. Elevated Education came to Green CulturED with an idea to create an accredited compliance training for industry workers to meet government regulations easily and efficiently.
Disjointed Cannabis Laws & Industry Guidelines
The piecemeal, state-by-state nature of cannabis legalization prohibits the development of overarching federal laws to regulate the industry. The novelty of the cannabis industry and shifting public opinion about cannabis means that there are more “mainstream” people obtaining jobs in Illinois, increasing the need for government compliance training, which may have been largely ignored in the past.
This is becoming a problem for dispensary owners, managers, and staff. From growers (who may have started as enthusiasts) to retail Dispensary Technicians (who may have been hired for their customer service or retail experience), the need for consistency compliance training across the industry is becoming apparent.
Whether cannabis companies blaze through the challenges or go up in smoke trying, the cannabis industry provides an insightful case study for Illinois employers who must meet the Responsible Vendor annual compliance training requirements.
More often than not, substantial training and development programs are being required to meet compliance requirements as the cannabis industry becomes legalized. With no national standards or “best practices,” owners of cannabis businesses must look to state laws for worker training requirements, if any exist. Some states require employee registration; others require education on specific topics, like patient confidentiality. Still, other governments have no guidelines or compliance training at all.
Cannabis Industry “Training Gap” Study
A research study by Cannabis and Cannabinoid Research called “Training and Practices of Cannabis Dispensary Staff” published by Nancy A. Haug, Dustin Kieschnick, James E. Sottile, Kimberly A. Babson, Ryan Vandrey, and Marcel O. Bonn-Miller.
The study revealed just over half (55%) of dispensary employees have had any formal training regarding medical cannabis and only 20% had any type of specific medical or scientific training. Of that same group, 94% reported that, even though untrained, they provided advice, guidance, or counsel to patients.
In addition, research found recommendations in response to a patient’s symptoms and conditions are frequently counter (or opposite) to existing empirical literature of recommended cannabis use/dosages for disorders. Unfortunately, consumers look to dispensary agents for cannabis advice than qualified physicians when making decisions.
Elevated Education Case Study
Project Sponsor: Elevated Education
Elevated Education is a woman and minority-owned firm dedicated to providing high quality, instructional sound training, and educational content. With over years of experience creating courses and curriculum for corporations, colleges and universities, the military, and a wide variety of industries, they have worked closely with clients to identify and fulfill their compliance training requirements.
The Illinois Department of Financial and Professional Regulation (IDFPR), Division of Professional Regulation, Cannabis Control Section approved Elevated Elevation as an approved Responsible Vendor training provider. This designation authorizes them to deliver training for Dispensary Agents, including Dispensary Technicians (aka “Budtenders”), Managers and Agents-in-Charge.
The Responsible Vendor training provides Dispensary Agents with compliance training on the following topics:
- Checking Purchaser Identification
- State Law Compliance & Dispensing Cannabis Rules
- Identifying Impairment Signs
- Understanding Cannabis Physiological Effects
- Implementing Security Measures
- Addressing Cannabis Consumption Health Concerns
The Responsible Vendor compliance training requirements include topics similar to the service-industry education required for serving alcohol called “TIPS” (Training for Intervention ProcedureS) but is tailored to the Illinois cannabis regulatory structure. All cannabis dispensing agents currently working in Illinois must receive training from an approved provider to ensure they have been trained before agents can legally make sales to customers.
Elevated Education’s Business Problem
A rapidly changing legal landscape in Illinois resulted in immense growth in the cannabis industry, creating an education and skills gap that required instructional product development. An eLearning compliance training course was developed by Elevated Education as an ideal solution to effectively train state-wide, with consistent, auditable, and accurate information that’s needed in Illinois’ industry.
The legalization of cannabis meant new retail infrastructure, new distribution rules, new licensing rules, and a transition to a new legal framework for growers. Seeing an opportunity to help their clients maintain compliance with regulatory laws and framework, Elevated Education became one of the first accredited cannabis compliance training companies in the state of Illinois.
Their team wanted to create an eLearning course that they could sell to their clients, to train frontline customer service staff and management in the retail cannabis marketplace. Elevated Education partnered with Green CulturED for the entire instructional product development and valued their team’s ability to deliver:
- Expertise in developing custom eLearning solutions for the cannabis industry.
- Ability to pull together a project team to execute and deliver the project within a strict time frame.
- Flexibility to respond quickly to changing circumstances created by the emerging legislation.
Elevated Education’s Training Constraints
As Elevated Education needed to develop the compliance training while the regulations were still being drafted, this created several constraints:
1. The first constraint was determining what would be in the compliance training. It’s hard to determine the length of a course, the instructional activities, or how long it would take to develop that course when you can’t clearly identify the specific content required (since the new regulations hadn’t been drafted at the time). Using our ingenuity, we researched and drafted initial content, making it easier for the internal experts to vet information.
2. A second constraint was the limited availability of internal technical staff to contribute to the instructional design and product development. The demand for their expertise was extraordinary for Elevated Education’s work as they were required to meet the impending legalization date.
3. A third constraint was that Elevated Education did not have an operational Learning Management System (or LMS). We had to get up to speed on the inner workings of what Illinois required in the compliance training since every LMS influences the overall course structure and experience. As this was a government regulated training product to be sold by Elevated Education, we also needed to pay very close attention to the user experience to keep future support costs down to maximize profitability. In addition, there were government reporting requirements to validate the learner’s identity, their training records, and digital certificates.
eLearning Project Objectives
IDFPR is Responsible for Enforcing Registration & Oversight of Cannabis Dispensary Compliance Training to Provide Comprehensive & Efficient Training for Workers Who Require Cannabis Industry Knowledge.
1. Rapidly Changing Landscape
A rapidly changing legal landscape resulted in immense growth in the cannabis industry and created an education and skills gap. Green CulturED was engaged by Elevated Education to design and create an eLearning solution to train Dispensary Agents in the retail cannabis marketplace. Through our partnership we had the expertise in developing custom instructional products, and for our ability to pull together a project team to execute and deliver the project within a strict time frame.
2. Custom Solution Developed
The Responsible Vendor compliance training was developed with Articulate Storyline by the Instructional Design team and delivered via Learning Management System (LMS). The compliance training also includes government regulation-based assessment to confirm learning. As a self-paced course, it allows individuals to prepare themselves to work in the rapidly growing industry and allows companies to invest in training for their staff without the cost of developing it themselves.
3. Project Outcome
Elevated Education has been able to establish a strong position in the marketplace, building on its first-mover advantage in the space. After receiving approval from the Illinois Department of Financial and Professional Regulation (IDFPR) for the course they have been able to market and sell the Responsible Vendor compliance training to new and existing industry workers.
4. Elevated Education Feedback
“Green CulturED was a lifesaver. They stepped in at the last minute when it seemed as though we weren’t going to be able to complete our curriculum on time. Their team provided guidance and offered out of the box solutions that not only delivered our project on time but provided us with a product that we are proud of. Their expertise, professionalism, and general know-how was a breath of fresh air.”
Instructional Design Process
Background Story
Elevated Education has been able to establish custom training programs for clients and continues to build out their curriculum, based on their industry insights and expertise. The growing demand for the Responsible Vendor training provides a solid revenue opportunity for Elevated Education and by partnering with Green CulturED was able to bring their in-person classroom compliance training 100% online.
During this initial accreditation process and as a result of past successes, Elevated Education engaged Green CulturED, to take on the development of this as an additional eLearning project. These additional compliance training types are much larger and more technical in nature to develop the Responsible Vendor training, yet all the courses had the same deadline and were completed on time and on budget.
Elevated Education had to be honest about their available bandwidth (infrastructure, expertise, and staff) to successfully create certified or credentialed eLearning content. This type of eLearning requires many extra steps, so they took a critical look at their staff availability, expertise, and knowledge for tackling this project in-house and that’s when they decided to partner with Green CulturED.
1. Engage & Analyze
As with all our projects, in collaboration with Elevated Education, we established guiding principles to help us meet the project goals within the constraints. For example, “What are trade-offs we could and couldn’t make?” and “What would govern our decisions?”
We ascertained that the timeline was critical, and the information had to be precise, ensuring correct interpretation and application of the regulations within the legal framework. We also created a list of non-critical enhancements that could be made post launch. The project could be delivered on time meeting Elevated Education’s objectives, while some value-added features could be included in a later release.
Learning objectives for each program were also established, making sure that the approach focused on the application of the new knowledge acquired by the learner. The goal of the Responsible Vendor compliance training was to provide comprehensive and efficient training to staff who require basic knowledge of cannabis, its effects, standard operating procedures and the regulations within the Illinois laws that they must adhere to when working in the industry.
2. Instructional & Creative Design
A challenge with compliance-oriented training can be the amount of legalese and, do’s and don’ts they contain, so significant focus was placed on creating engaging instructional activities relevant to the compliance information.
It was essential that the learner understand why it was important to learn the information that was in the course. The knowledge couldn’t just be because they “had to” – a common challenge with compliance-oriented training. They had to see the importance of their work in the grand scheme of the new legalization.
As a result, several scenarios were included that showed the potential consequences and personal impact on industry workers of not following procedures and regulations, rather than solely focusing on the punitive consequences of the legislation. A storyboard was created that included:
- Content Sequence
- Narrative Story Writing
- Topics & Story Arc
- Learning Activities
3. Build, Test & Modify
Without any draft regulations to work from, subject matter experts identified likely topic areas and wrote the content in each of the identified areas, such as standard operating procedures for retail distribution. A series of training modules were outlined along with associated learning activities and content.
As further information became available the structure of the outlined modules needed to change. Some topics were condensed, others expanded and elaborated upon, and a narrative approach was created that followed a new employee through their learning journey. Partway through the build phase, the development of retail or adult-use cannabis was legalized and, the Illinois Department of Financial and Professional Regulation (IDFPR) was responsible for creating completely new regulations.
Consequently, the approach taken was to focus on the common areas across all state regulations and note exceptions as they occurred. For example, the legal age of consumption was consistent across the entire state of Illinois, and in cases where more substantive differences existed, links to specific information on the respective state regulations were created. As the project progressed multiple rounds of versions or builds were created which were each reviewed and modified accordingly following feedback from Elevated Education and Subject Matter Experts (SME’s).
4. Responsible Vendor Training Launch
The Responsible Vendor online training was successfully delivered and launched on time. As part of the launch Green CulturED worked with Elevated Education to develop a video highlighting the breadth of information covered, and the interactivity and applied nature of the course to support sales.
We provided support in the development of a promotional video sharing screenshots and video excerpts of the training.
Summary
The Illinois Responsible Vendor compliance training was very well thought-out, but the client faced many challenges – not just in coordinating the accredited content, but also in entering an emerging market – Illinois’ new cannabis industry – that recently became legal due to law changes established in the state.
Providing the value of continuing education credit was tricky, however, due to the sensitive nature of the cannabis topic. So, Elevated Education applied to the state to become accredited and establish a long-standing relationship with the Illinois Department of Financial and Professional Regulation (IDFPR) to coordinate and manage the accreditation details.
Thanks to our extensive in-house Instructional Design expertise and knowledge, Green CulturED partnered with Elevated Education to overcome the challenges and successfully launched the compliance training. Thus, Green CulturED has become responsible for knowledge management since we helped guide the process during the Instructional Design process after Elevated Education received its accreditation.
The curriculum has also been very well-received by Illinois’ cannabis industry workers. Not only have we had strong enrollments, but we have also received favorable feedback from learners about the content.
Frequently Asked Questions
You'll Find Questions that Are Frequently Asked & Answers Provided From the Illinois Department of Financial & Professional Regulation for Informational Purposes ONLY & Not Legal Advice.
Who can apply?
A person must be hired by a dispensing organization before they can apply for a dispensing organization agent identification card.
What do I need to apply?
Applicants must complete attestation and submit a photo, proof of residence, and government identification, they will also be asked to provide disposition forms for any previous criminal offenses.
Who needs to receive training from a Responsible Vendor?
All owners, managers, employees, and agents involved in the handling or sale of cannabis or cannabis-infused products employed by an adult-use dispensing organization or medical cannabis dispensing organization as defined in the Compassionate Use of Medical Cannabis Program Act.
When must individuals receive the training from a Responsible Vendor?
Within 90 days before or after the first day of employment at a dispensary, whichever is later. Training received outside of the 90-day window will not meet the training requirement imposed by the Cannabis Regulation and Tax Act.
How often must individuals receive training from a Responsible Vendor?
Training must be received annually, so every one (1) year.
What topics must be covered in the Responsible Vendor training?
Responsible Vendor Training modules must include education on:
- Cannabis Use Health and Safety Concerns
- Driving Under the Influence Laws and Regulations
- Minor Sales Prohibitions
- All Relevant Illinois Laws and Rules
- Acceptable Identification Forms
- Safe Cannabis Storage
- Inventory Tracking Compliance and Regulations
- Waste Handling, Management, and Disposal
- Dispensary Health and Safety Standards
- Records Maintenance
- Security and Surveillance Requirements
- Permitting Inspections by State and Local Licensing and Enforcement Authorities
- Privacy Issues
- Packaging and Labeling Requirements
Can a Responsible Vendor provide all eight (8) hours of the training required?
Yes. Provided the training meets all the requirements of the Cannabis Regulation and Tax Act.
Does the training provided by a Responsible Vendor count toward the eight (8) hour annual training required by law?
Yes. For example, if the Responsible Vendor training is for two (2) hours, a dispensing organization would still be required to provide six (6) hours of additional training per year. In any case, a dispensary agent, agent-in-charge, and principal officer must receive training on the following topics as required in the Cannabis Regulation and Tax Act:
- How to Effectively Operate the Point-of-Sale (POS) System and State’s Verification System
- Proper Inventory Handling and Tracking
- Specific Uses of Cannabis or Cannabis-Infused Products
- Regulatory Inspection Preparedness Instruction and Law Enforcement Interaction
- Legal Requirements Awareness for Maintaining Agent Status
Are all Principal Officers required to receive training from a Responsible Vendor?
The only agents that are required to receive the Responsible Vendor compliance training is those involved in the handling or sale of cannabis or cannabis-infused products. However, all agents, including all Principal Officers, must meet the eight (8) hour training requirement found in the Cannabis Regulation and Tax Act.
Can medical cannabis dispensing agents serve purchasers at a secondary site?
Only if the secondary site is owned by the same entity as the medical cannabis dispensing organization at which the agent works. The Illinois law provides a dispensing organization agent shall only be required to hold one card for the same employer regardless of what type of dispensing organization license the employer holds.
Can I be an agent-in-charge of more than one dispensary?
An agent-in-charge must be a full-time employee of the dispensary, but an agent-in-charge cannot be the agent-in-charge of more than one dispensary. However, the agent-in-charge of a Medical Cannabis Dispensing Organization may serve as the agent-in-charge for an Adult-Use Cannabis Dispensing Organization operating at the same site.
Can medical cannabis dispensing organization agents serve non-medical purchasers at the same site?
Yes. Agents with medical cannabis dispensary agent identification cards can serve purchasers at an Adult Use Dispensing Organization License located at the same site as the medical cannabis dispensary.
Can an adult use dispensing organization agent serve medical cannabis patients at a medical cannabis dispensary if the medical cannabis dispensary does not have a license to sell adult-use cannabis at the same site?
No. The definition of "dispensing organization" in the Cannabis Regulation and Tax Act only includes dispensing organizations with the same site or adult-use dispensing organization licenses. The definition does not include medical cannabis dispensing organizations that have not obtained the same site license. Because medical cannabis dispensing organization without the same site license is not a "dispensing organization" under the Cannabis Regulation and Tax Act does not authorize the licensing of any individuals to work at medical cannabis dispensing organization.
What is the process for the fingerprint-based background check and criminal history record information?
According to the Cannabis Regulation and Tax (Act) and Regulations, applicants for an Adult Use Cannabis Dispensing Agent Identification Card must have a fingerprint-based criminal history record information background check. The Illinois Department of Financial and Professional Regulation (IDFPR) will comply with the rules and regulations concerning a criminal background check. It requires fingerprint vendors to confirm the identity of the individual seeking to be fingerprinted. This identity verification form must be completed for individuals applying for consideration for licensure in the State of Illinois. The out-of-state fingerprint vendor or Illinois live scan vendor chosen to take the out-of-state resident’s fingerprints must be completed as written confirmation that a valid government issued driver’s license or State identification (ID) was presented and that the identification provided belongs to the individual being fingerprinted.
Message From Our Founder
Evan Erickson
Chief Training Officer & Founder
Be honest… How would you describe your cannabis industry training?
Underwhelming? Disorganized? Under-Trained? Over-Worked? Non-Existent?
Well if you said anything other than, “A well-oiled machine,” you’ve come to the right place. Assuming you are apart of a team, it’s likely a loosely assembled group, all scrambling around completing tasks, updating workers on new regulations, running in-person training, completing compliance requirements, and doing their best to “figure it out”…without anyone necessarily knowing what anyone else is doing.
Read More
They’re busy. And they try hard. But are they really getting anything done? Is their work making a MEASURABLE difference to your company? When I asked this question about my own company, I didn’t like the answer. That’s why I created Green CulturED.
As a partner, you’ll be able to grow a dedicated, COORDINATED team of cannabis industry rock stars. And best of all, critical (but time-consuming) tasks such as recruiting, training and retaining top talent will become effortless, and you’ll finally have a team all moving toward the same goal…
…growing YOUR company! So if you like the idea of transforming your ordinary (or non-existent) training into a well-developed eLearning solution, then reach out to us today!