Medical Marijuana Facility Application Scoring Process

Through the state’s competitive bidding procurement process, a blind scoring vendor was contracted, on August 9, 2019, to score facility license applications in accordance with Article XIV and associated rules. Article XIV required that, in any case where there were more applications than licenses available, the department was to use a numerical scoring system to score and rank applications based on ten, specific categories. The rules established a comprehensive scoring system to implement this mandate, which included lists of scoring questions for each facility type, a detailed scoring rubric on which to judge the responses to those questions, question and topic values and weights, and strict parameters for an independent execution of the scoring system by scores who would have no access to the identity of the applicants whose applications they were scoring.

The excellence and independence of application scoring was a crucial element of the scoring system. As such, all scorers had professional backgrounds qualifying them to score their assigned questions, and many scorers had higher education degrees including masters, JDs, and PhDs. Every scorer completed training on the Missouri blind scoring process before they were allowed to score applications. Finally, the process was designed to be impervious to bias or conflicts of interest.

  • The state’s contract with the scoring vendor required the vendor to affirm it did not have any conflicts of interest before beginning services under the contract. All individual scorers were also required to sign confidentiality and conflict of interest statements, which they did. Any disclosure was a basis for removing the scorer from the blind scoring process, and in fact, one scorer did disclosure a potential conflict and was removed from the process before they scored any applications. The department investigated specific and general claims of such conflicts and, in all cases, found no evidence the blind scoring vendor had any relationships or business dealings that would have presented a conflict of interest under the contract.
  • The final rules showing final versions of the application questions and their weight/importance were not published until June of 2019. The draft rules showing the application questions that must be answered for Missouri’s facility application were first publicly posted May of 2019. The state issued its Request for Proposal to solicit a Blind Scoring vendor July 12, 2019.While some have questioned whether educational programs held by an affiliate of the scoring vendor could have created a conflict for the scoring vendor, these program were held before Missouri’s draft scoring system was posted in May, and the educational programs did not include training on how to write facility applications. These educational programs were not a conflict under the contract.
  • The blind scoring process included a strict redaction methodology for applicants to maintain anonymity for the scoring team.
  • No scorer had access to an entire application. Each scorer could access only the portion of the application assigned to them for scoring.
  • After licensure, the department investigated allegations of scoring inconsistencies and found no evidence that the scoring was done in anything but a highly professional, competent, and compliant manner by people with the expertise to do so.
  • The blind scoring vendor and their employees are prohibited by contract from providing consulting services to Missouri medical marijuana license or certification applicants or potential applicants for a period of two years after the term of the blinding scoring contract.
After all scoring was complete and prior to licensure, the department reviewed and assigned scores to ensure all scores were successfully transmitted from the blind scoring vendor. The department did not alter transmitted scores other than by applying the score adjustments outlined in the rules for geographic location.

The department has completed its review of all medical marijuana facility applications. The results of this review are listed below. Applications designated as "Approved" have been offered a medical marijuana facility certification and have been given five days to confirm acceptance of that certification. Notifications of approval have been sent to the email addresses of the individual who created the user account in the Medical Marijuana Registry Portal, the individual listed in the application as the Primary Contact, and at least one other individual identified in the application. Applications designated as “Denied” have not been offered a certification. Denials are issued for several reasons, including failure to meet minimum qualification, the results of an analysis for substantial common control, the results of application scoring, or application withdrawal. Notifications of application denial have been sent to the individual who created the application in the Medical Marijuana Registry Portal.

The department will be releasing copies of all facility application scoring sheets. Scoring sheets may be found at the link below and are posted by Facility ID number. Individuals interested in the scores for a particular application should refer to the “Key” document for the relevant facility type to determine that applicant’s Facility ID. Note the Facility ID listed is not necessarily the same Facility ID created by the applicant. The score sheets reflect the scores before any adjustments were made per 19 CSR 30-95.025(4)(C)6-8. The scoring scales, weights, and conversion factors applied in these scoring sheets can all be found here: Facility License Application Questions and Scoring Criteria - (updated 05/31/19).

Facility Scoring Sheets: