BioTrack · 3 min read
Four Records to Reconcile in a Florida MMTC
Florida's tracking requirements involve the licensee's internal seed-to-sale system, the Department's STS Tracking System, patient/order data in the MMUR, and product physically on hand. Treating those records as one reconciliation view is a useful operator control; the rules define system and data requirements rather than a fixed “four-way” worksheet.
The four record views
- Internal STS and POS: the licensee's operational inventory and sale records. Rule 64-4.222 allows an internal STS to also serve as the POS.
- Department STS: the state tracking record for inventory and reported events.
- MMUR: the patient's active certification, order, route, and supply-limit information used for dispensing.
- Physical stock: the count and location of the product at the facility.
Section 381.986 requires the Department's system to trace marijuana from seed to sale and provide the Department real-time, 24-hour access. Rule 64-4.221 defines full integration as real-time connection and communication through an API.
Keep package and product IDs separate
Use the Department STS inventory identification number to follow a particular inventory record. Use the unique product ID to identify a product type. Under Rule 64-4.221, an MMTC assigns that product ID to each type of usable product or delivery device; a SKU may serve if it is unique to the type. A product ID is not a substitute for a package-level inventory identifier.
Reconcile the event, not only the balance
For a dispensation, compare the package and quantity, the internal and Department STS event, and the applicable patient order and route. For a transfer or adjustment, compare the source record, location, and destination status. Record which view first diverged and verify the correction across the affected records.
Sources:
- Florida Statutes § 381.986(8)(d), (e) — Department tracking system and MMTC duties.
- Fla. Admin. Code r. 64-4.221 — integration and unique product ID.
- Fla. Admin. Code r. 64-4.222 — STS procedures and inventory identifiers.