Industry / heroes / medical discounts — verification cadence + audit-trail

WAC 314-55-095 governs cannabis-business-employee discounts in Washington. The rule has three teeth that operators routinely overlook:

• **Verification per visit, not per customer.** A budtender from a Spokane shop who walks in once a month has to be re-verified each visit. The first-time verification doesn’t carry forward. Most POSes get this wrong by storing ‘verified industry-discount eligible’ as a customer-row flag — that’s a 314-55-095 cite waiting to happen.
• **Acceptable verification = current pay stub OR current employee badge from a WSLCB-licensed cannabis business.** Driver’s license isn’t enough; word-of-mouth isn’t enough; ‘she’s been here before’ isn’t enough. The verification has to tie the customer to a current cannabis-licensee employer.
• **Discount cap = 50% off retail.** Above 50% the WSLCB starts asking whether the ‘discount’ is actually a kickback or a structured-employment perk. Most shops cap at 30-40% to stay clear of the 50% line; we cap at 30%.

1. 1**Customer requests the discount.** ‘Hey, I work at [shop], do you guys do industry?’ That’s the trigger; nothing happens until they ask.
2. 2**Budtender asks for verification.** ‘Got a current pay stub or a badge?’ Phrasing matters — we’re not interrogating, we’re documenting. ‘Yes, the WSLCB asks for this’ is the right closer if the customer pushes back.
3. 3**Budtender photographs the verification.** Camera at the till. Pay stub photo or badge photo lands as a CDN-stored image referenced by the audit-log row. CannAgent stores the image with a 90-day retention; some shops keep longer. Image gets PII-redacted at render-time (last-4 of any visible employer ID, no SSN tail).
4. 4**Discount applied at the till.** POS stamps the activity row: customer_id, employer_name (typed by budtender), verification_type (‘paystub’ / ‘badge’), discount_pct, transaction_id, image_ref. Audit-trail complete in <30 seconds.
5. 5**Customer comes back next month.** Re-verify. Don’t shortcut. The audit log shows N verifications for N visits — that’s the pattern WSLCB expects.

• **Discount-application gate at the till.** Before applying any industry / heroes / medical discount, the budtender must complete a 4-field micro-form: employer name (free-text), verification type (radio: paystub / badge / medical-card), photo upload (required), discount % (locked to your shop’s ceiling). No bypass; no ‘skip for now.’
• **Manager-PIN override required for non-standard discount %.** Anything above your standard cap requires a manager PIN + a typed reason. Audit log captures both.
• **Image storage with retention policy.** 90 days minimum for industry / heroes; 1 year for medical (per medical-endorsement compliance). PII-redaction at render-time so the inspector sees what they need without exposing the customer’s full SSN-tail accidentally.
• **Audit-log query under 60 seconds.** ‘Show me every industry discount applied in Q1 2026, grouped by budtender’ — your POS should answer in under a minute. CannAgent surfaces this as a one-click report; whichever POS you run, find the equivalent.
• **Quarterly self-audit.** Doug runs a self-audit on the first of every quarter — random-sample 10 industry discounts, verify the photo matches the employer named, look for patterns (one budtender doing 80% of the discounts? Investigate). The self-audit log is itself a document the WSLCB likes to see at inspection.

• **Discount applied with no verification record.** ‘She’s industry, I know her’ doesn’t hold up. Cite-able.
• **Discount % above the 50% cap.** Even once. Even with proper verification.
• **Same person on the audit log every week with different employers named.** Hopping employers is suspicious; it triggers a deeper review.
• **Budtender applying industry to themselves.** Cleanest: budtender doesn’t ring their own transaction. Manager rings the budtender’s purchase + applies the discount. Double-control; clean audit trail.
• **No quarterly self-audit.** Failure to maintain audit discipline is itself a finding even when the underlying transactions are clean.
• **Heroes / medical applied without separate verification flow.** Each program has its own evidence requirement. Stamping ‘heroes’ on someone with a paystub from a cannabis shop is wrong twice — wrong program, wrong verification.

• Verbal-only verification (‘she said she works at…’) — undocumented, cite-able.
• Paper logbook of industry visits — gets lost, gets wet, gets thrown out by the cleaning crew. The inspector finds the gap; the gap is the citation.
• Spreadsheet tracking of who’s ‘industry-eligible’ — violates the per-visit-verification rule.
• ‘Just put it on her loyalty account as a manual discount’ — workaround that loses the verification + breaks loyalty-program math.