The AAMC and the Council on Governmental Relations (COGR) submitted a joint July 12 letter (PDF) to the Drug Enforcement Administration (DEA) in response to a notice of proposed rulemaking (NPRM) to transfer marijuana from schedule I of the Controlled Substances Act (CSA) to schedule III. As noted in the Department of Justice press release, “Marijuana has been classified as a schedule I drug since Congress enacted the CSA in 1970. On Oct. 6, 2022, President Biden asked the Attorney General and the Secretary of Health and Human Services (HHS) to launch a scientific review of how marijuana is scheduled under federal law.” The proposed rescheduling is consistent with the HHS’ medical and scientific determinations to transfer marijuana to schedule III.
In the letter, the associations emphasized the number of institutions currently conducting research related to marijuana’s safety, efficacy, and side effects. The recommendations focused on key aspects of the NPRM that impact institutions’ ability to conduct critical research. For example, the AAMC and COGR urged the DEA to reconsider its proposal to exclude synthetic THC from the scope of the rulemaking so that both naturally and synthetically derived delta-9 THC can be analyzed under the CSA’s eight-factor analysis.