The state Health Department today announced that it has held up approximately 4,200 medical-marijuana registry applications while it investigates possible fraud.

The department, in a news release, said it began looking into the applications after hearing from law enforcement agencies that marijuana-seeking patients at two clinics were being seen by someone other than a doctor. The department said the scrutinized applications all contained medical marijuana recommendations from "certain identified physicians."

The department did not name the doctors or say how many are under review. Under Colorado medical-marijuana law, only a doctor can recommend marijuana to a patient. Doctors must have a "bona fide" relationship with patients to whom they recommend marijuana and that recommendation must come after a thorough physical exam.

"The exposure of this fraud should lead marijuana registry applicants to take care to ensure that they are seen and examined by a physician if they intend to apply to the medical marijuana registry," Dr. Chris Urbina, the Health Department's executive director, said in a statement.

The department is in the process of contacting the doctors listed on the suspect forms to verify that the doctors personally conducted the exams, said Health Department spokesman Mark Salley. The department will then either approve or deny the applications. If the department denies an application, the patient must wait six months before applying again to the registry.

Salley said the department may also reject the applications — essentially treat them as if they are incomplete. If that is the case, those patients could immediately reapply to the registry.

Patients in an initial batch of 2,600 delayed applications should know the outcome by Dec. 23, Salley said. Patients in another batch of 1,600 applications will know by the first of the year, he said.

There are currently about 88,800 patients on Colorado's medical-marijuana registry, according to Health Department statistics. That is a more than 30 percent drop-off from the registry's high point of nearly 129,000 patients in June.

Inclusion in the registry — which currently costs $90 and will drop to $35 at the beginning of 2012 — is needed for a patient to shop at a dispensary and also provides stronger legal protection against prosecution. However, a doctor's recommendation for marijuana is all that is needed to argue a medical defense successfully at trial.

John Ingold: 303-954-1068 or jingold@denverpost.com.

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