I don't think MadMike means to impose. This has been constructively talked about before and there is little changing it. For now it is what it is and the process we've almost down to a science, which is good as new patients and renewals know what to expect. No lapse's or waiting at the mailbox feeling forgotten about.
The DOH isn't following the law's set forward, no. But the DOH didn't write them, and also, there are other laws in the mmj regulations that aren't followed - let alone pages of common law which are ignored. It's easy to point a finger and spin in a circle.
Fact is, we live in the smallest state and we are strapped to the max. Plus, our mmj laws are almost brand new and they haven't changed much since they were introduced. I'm not sure if you've received your letter yet and physically obtained your "card", however back when I went - one person was working in a tiny little office. Only a couple people (when I was there, one) print all of the state issued cards for all of their various programs. Only a couple sorting all of those applications, fee's. If you haven't been - once you do and see the dead scene, you'll see why it may take longer than the law states. However I received mine in a timely manner, but was still advised by others to be prepared.
You seem to be forgetting the other protections as well. Not offically in the law, but the DOH is not the issuer of your reccomendation. They are simply an intermediary that records everything and makes you a state licensed patient. To be covered under the law, a doctor that you have a physical relationship with (general care, cariopractor, physical therapist) must certify that the benefits of mmj outweight the risks. You don't actually have to hold a card. The law doesn't say this because it promotes dishonesty, fraud, etc. however the certification and the DOH registration have nothing to do with eachother. The fact is evident with the law you mentioned (if you don't hear back from the DOH after 30 days, your certification is assumed valid). I guess they had to put this in the regulations for protection, as a "what if". What if the DOH lost your application. I'm pretty sure there has been a case in RI where someone was arrested for minor possession about 5 days after receiving their certification. Their case was immediately dissmissed.
Anyways. As an example, Maine, who has had mmj regulation longer than us. They have issued doctors a tamper proof paper now for people who don't want to register with the state. So if you would like to use your mmj status as legal justification, you need a card, which can be cross referenced with the state... or basically a laminated license issued from your doctor. I guess RI is going to have to do after I just opened my big fat mouth.