In both cases -- provisional access and temporary access for opioid applicants -- there's really nothing for IDPH to "deny." The only question under the new law is whether the prospective patient has submitted a complete, conforming application (an application that includes all the required items). Regardless of whether IDPH goes on to approve or deny that application following a full review, provisional access/temporary access should only require that the applicant has submitted a complete application (even if that application is fated to be denied down the road).
(Indeed, it's not even clear there is a "approve/deny" process in the case of the opioid program since the new law doesn't really mention an approval by IDPH or even an ability to override a doctor's recommendation. Unlike the original program -- which requires, at a minimum, that IDPH validate the existence of the patient's qualifying condition -- the opioid program appears to merely require any doctor to have complete the form saying that the patient is a potential opioid prescription candidate. Since opioid patients don't get a mmj card, there's nothing for IDPH to do with such applicants other than put them in the system once a completed application is received.)
I agree that much will be revealed when the rules are published (hopefully by the 12/1 deadline) and we're all doing a lot of guessing about the new system now. But it passes the time, which since I'm a 9/14 applicant expecting his card any day, is nice.