CANNABIS SATIVA L. A CONTROL PROBLEM
How should we schedule Cannabis Sativa L. (“Marijuana”)?
As federal patients receiving our healthcare through the department of veterans affairs, we feel Cannabis should remain on the Controlled Substances Act list within the United States of America. There are a number of reasons for this, which we will outline in greater detail below. To state it plainly, the VA is going to need to know how to categorize the various cannabis products that are available within their pharmacy system, as well as which various controls are required for specific preparations.
Additionally, any honest discussion regarding the medical use of Cannabis has to include warnings of potential negative side effects, ideally this discussion will be among the patient and their primary care physician. It is not appropriate to throw veterans seeking medical treatment into a recreational market for political expediency. We are medical patients. For all intents and purposes, keeping Cannabis within the CSA legitimizes the medicinal use of this traditional herb, and keeps the patients at the center of the conversation, where they belong.
Cannabis as it stands currently within the CSA
Schedule I
“Schedule I drugs have high potential for abuse. These drugs have no currently accepted medical use in treatment in the United States. There is a lack of accepted safety for use of the drug under medical supervision.
Tetrahydrocannabinol (THC, marijuana) is still considered a Schedule 1 drug by the DEA, even though some U.S. states, including California, have legalized marijuana for personal, recreational use, or for medical use.”
So, where would we place Cannabis within the CSA?
RSO/Hash(3) above 75% THC concentration) pharmaceutical preparation(synthetic)
Schedule III
“Schedule III drugs have potential for abuse less than Schedules I and II drugs. These drugs have a currently accepted medical use in treatment in the United States. Abuse of the drug may lead to moderate or low physical dependence or high psychological dependence.”
Concentrates(4): 35%-75% THC concentration)
Schedule IV
“Schedule IV drugs have low potential for abuse relative to Schedule III drugs. These drugs have a currently accepted medical use in treatment in the United States. Abuse of these drugs may lead to limited physical dependence or psychological dependence relative to Schedule III drugs.”
Botanical Cannabis (5): 0%-35%)
Schedule V
“Schedule V drugs have low potential for abuse relative to schedule IV drugs. These drugs have a currently accepted medical use in treatment in the United States. Abuse of these drugs may lead to limited physical dependence or psychological dependence relative to Schedule IV drugs.”
We have pinpointed what we feel are the most viable pathways for the policy recommendations provided. These include specific committees and departments within the government, as well as accompanying legislation which may be used as a vehicle to implement the remedies identified.
Which ones?
We’ve suggested using some of those funds to implement a harm reduction model centered on cannabis treatment, and other services/resources available through the VA’s “Whole Health” program.
“The Department of Veterans Affairs (VA) provides healthcare for 9,200,000 veteran enrollees, disability compensation benefits to nearly 6,000,000 veterans and survivors, pension benefits for over 357,000 veterans and survivors, life insurance for more than 5,500,000 veterans, servicemembers and their families, educational assistance for nearly 900,000 trainees, and interment of more than 130,000 veterans and eligible family members in national cemeteries. To adequately serve the Nation’s veterans, VA employs more than 425,000 people, making it one of the largest Federal agencies in terms of employment.” -Source
We’ve suggested expanding the VA’s “Choice Act” to include medical cannabis dispensaries and doctor recommendations in states where state regulated cannabis dispensaries have been established.
VA–DOD Joint Venture Facilities- Training and healthcare. Tying in that veterans are federal patients under federal responsibility.
Military Personnel/Veterans require similar language from the HOPE Act be applied to them, which requires the attention of DoD, and adjustment to the UCMJ code pertaining to cannabis use by military personnel. Once again, if the federal scheduling of cannabis under the CSA is addressed, and whole plant cannabis is properly placed/descheduled, this is more of an administrative procedure, as opposed to a political action.
We’ve suggested expanding the Compassionate Investigational New Drug program through the Health and Human Services and the Department of Veterans Affairs, so as to ensure veterans residing in states without medical cannabis dispensaries can still gain access to federally grown cannabis from the multiple sources available.
We are looking into the Office of Science and Technology Policy (OSTP), and the National Science and Technology Council (NSTC). The President of the United States chairs the OSTP. Vice President Harris is a member of the NSTC.
If it were up to us, we would introduce federal legislation which:
Releases to the public data collected per VA directive 1315 and its predecessors, since 2011;
Releases to the public all relevant data from the federal compassionate IND program pertaining to the safety, and efficacy of cannabis being used by the participating federal patients who have passed away, since 1976;
Provides for training and continuing education uniformly across the Veterans Integrated Service Network (VISN) level including, but not limited to the history of cannabis medicine; the function of the endocannabinoid system; new discoveries as research is conducted; and federal/state policy in order to best uniformly integrate treatment into federal patient care;
Uniformly expands the federal Compassionate Investigational New Drug Program (IND) through the VA;
Recognizes Veterans enrolled with, and receiving care from the VA as federal patients, requiring laws/policy being applied uniformly in all fifty states and territories of the U.S., reflecting the unique status of military (federal) personnel;
Provides an identifier on VA patient data cards identifying participating Veterans as federal cannabis patients; eliminating threat of prosecution/incarceration while traveling within the U.S. or on federal property with their medicine;
Provides for VA to grow cannabis for Veterans participating in the expanded IND program, and occupational therapy programs. Uniformly promoting home cultivation, and medicinal access to a broad variety of cannabis products, and;
Provides for a cannabis voucher system within the VA for Veterans to access cannabis under individual state medical cannabis programs/dispensaries.
Charters through Congress, new Veteran Service Organizations (VSOs) working in this field.
Why these things specifically?
State Program Template: These recommendations are intended to provide guidance related to veterans and medical cannabis in states across the country.
The American Legion, and Veterans of Foreign Wars are hemorrhaging membership, and posts across the country are falling into disrepair and foreclosure. These need to be transitioned into members-only compassion centers for our women and men who have served their country.
Based on our experience in the trenches, we have made the following observations of what baseline policy Veterans need states to implement:
Recognize cannabis as a viable treatment option for Veterans within their borders.
Provide incentives within the cannabis space as are already offered for Veterans in other state programs, such as fee waivers, job placement, and special licensing considerations.
Provide for cannabis dispensary licenses to be used by new or existing Veteran Service Organizations (VSOs)/Compassion Centers who choose to move away from alcohol sales.
Protect the ability of these VSOs/Compassion Centers to host cannabis farmer’s markets.
Protect the ability of these VSOs/Compassion Centers to give/receive cannabis donations to/for Veterans in need.
A new VSO is needed so Veterans can engage with each other and their community in a healthy, productive manner. This new VSO model does not involve alcohol. It implements a more conducive, harm reduction approach geared toward:
Reducing the suicide rate within the Veteran community;
Reducing the dependence on pharmaceuticals within the Veteran community;
Providing a safe environment for Veterans, their families, and friends;
Increasing the quality of life for Veterans, and their families;
Establishing new networking opportunities within the Veteran community;
Identifying and perpetuating positive trends within the Veteran community;
Designing metrics to monitor the utilization/effectiveness of proposed programs.
-Rico & Kowalski
