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RECOMMENDATIONS FOR GEORGIA LOW-THC PROGRAM | TEREL NEWTON MD | TRULIEVE FL MED DIR 

Ga Program - https://dph.georgia.gov/low-thc-oil-registry 

1)  Removal of “end stage” language 

Georgia’s Low THC Oil Registry requires several (8 of 17 = about ½) conditions to be “severe or end stage” before patients qualify: cancer, ALS, multiple sclerosis, Parkinson’s, sickle cell, Alzheimer’s, AIDS, and peripheral neuropathy. Other conditions (e.g., intractable pain, PTSD, seizures) have no such qualifier.

Problem

This restriction denies earlier access even when evidence supports benefit in non–end stage disease:

• Multiple sclerosis: Nabiximols and oral THC/CBD reduce spasticity and pain and improved sleep; many of these patients had  moderate MS, not only end-stage [1].

• Parkinson’s disease: Cannabis reduced tremor and dyskinesia in outpatient studies of moderate-stage patients [2].

• Alzheimer’s disease: Low-dose THC reduced agitation and improved appetite in patients at mild-to-moderate stages [3].

• HIV/AIDS: Cannabis reduced neuropathic pain in ambulatory patients, not just at terminal stages [4]. 

Policy recommendation 

• Eliminate “end stage” as a requirement.

• Allow physicians to certify when the disease causes clinically significant symptoms or when standard therapies have failed.

• This mirrors how “intractable pain” is already handled in Georgia law, and it aligns with states like New York, where physician discretion governs eligibility.

References for Section 1
[1] Chan, A., & Silván, C. V. (2022). Evidence-based Management of Multiple Sclerosis Spasticity With Nabiximols Oromucosal Spray in Clinical Practice: A 10-year Recap. Neurodegenerative Disease Management, 12(3), 141–154. https://doi.org/10.2217/nmt-2022-0002

 [2] Lotan I et al. Cannabis (medical marijuana) treatment for motor and non-motor symptoms of Parkinson disease. Clin Neuropharmacol (2014). https://pubmed.ncbi.nlm.nih.gov/24614667/
[3] Shelef A et al. Safety and efficacy of medical cannabis oil for behavioral and psychological symptoms of dementia: an open label study. J Alzheimers Dis (2016). https://pubmed.ncbi.nlm.nih.g 

[4] Abrams DI et al. Neurology (2007). https://pubmed.ncbi.nlm.nih.gov/17296917/

2) Expansion of qualifying conditions

Georgia currently covers cancer, ALS, multiple sclerosis, Parkinson’s disease, Alzheimer’s disease, AIDS, peripheral neuropathy, epilepsy/seizures, Crohn’s disease, mitochondrial disease, autism spectrum disorder (with severity), Tourette’s syndrome (severe), PTSD (adults), intractable pain, and terminal illness.

Problem: This excludes conditions with strong or emerging evidence: fibromyalgia, ulcerative colitis, insomnia, opioid use disorder, and anxiety disorders.

Evidence:

• Fibromyalgia: THC/CBD lowered symptom burden by 44% [1].

• IBD: Cannabis reduced CDAI by >100 points; 45% remission [2].   [ 8 factors | 0-600 

• Insomnia: THC/CBD spray shortened sleep latency by 30–40 minutes, added ~1.2 hrs/night [3].

• Opioid use disorder: Cannabis laws linked to 17–31% lower opioid prescribing [4].

• Anxiety: Observational studies show significant acute reduction in GAD-7 scores post-cannabis use [5].

Recommendation: Add these conditions, or adopt a physician-discretion model (as in FL/VT/MN) to allow certification for any conditions similar to the qualified conditions and any debilitating illness.

References for Section 2
[1] Habib G, Artul S. Clin Exp Rheumatol (2018). https://pubmed.ncbi.nlm.nih.gov/29511842/
[2] Naftali T et al. Clin Gastroenterol Hepatol (2013). https://pubmed.ncbi.nlm.nih.gov/23648372/
[3] Suraev A et al. Sleep (2021). https://pubmed.ncbi.nlm.nih.gov/34009777/
[4] Bradford AC, Bradford WD. JAMA Intern Med (2018). https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2676999
[5] Cuttler C et al. J Affect Disord (2018). https://pubmed.ncbi.nlm.nih.gov/30197194/

Notes: CDAI scores range from 0 to 600. A score of less than 150 corresponds to relative disease quiescence (remission); 150 to 219, mildly active disease; 220 to 450, moderately active disease; and greater than 450, severe disease. 

3) THC cap adjustment

Georgia law caps THC content at 5%, which prevents therapeutic dosing.

Problem: Patients requiring more than trace THC must consume impractically large amounts, raising cost, adherence issues, and risk of illicit use.

Evidence: Nabiximols (1:1 THC:CBD) is typically titrated to 8–12 sprays/day (~20–30 mg THC), achieving 25–34% spasticity reduction [1]. Long-term extensions permitted up to 48 sprays/day (~130 mg THC) [2]. Cancer pain trials used 20–40 mg THC/day with significant analgesia [3]. Experts recommend regulating high-THC products with labeling and taxation instead of blanket low caps [4].

Recommendation: Raise or remove the 5% THC cap, adopting targeted regulation for ultra-high potency products.

References for Section 3
[1] Patti F et al. Expert Rev Neurother (2022). https://pmc.ncbi.nlm.nih.gov/articles/PMC9539865/
[2] Langford RM et al. J Neurol (2013). https://pmc.ncbi.nlm.nih.gov/articles/PMC3437528/
[3] Blake A et al. Ann Palliat Med (2022). https://apm.amegroups.org/article/view/16199/html
[4] Hall W et al. Addiction (2023). https://doi.org/10.1111/add.16135

4) Addition of product forms and routes (revised)

Georgia law currently permits low-THC oil, tinctures, transdermal patches, lotions, and capsules.  

Problem: Forms like inhalation, vaporization, whole flower, and edibles are still prohibited. These forms can offer much faster onset (in minutes rather than hours), better options for acute symptom relief, and greater flexibility for patients who cannot swallow or want more precisely titratable doses.

Evidence:

• Inhaled cannabis peaks in 3–10 minutes, useful for breakthrough pain, nausea, or spasticity [1,2].

• Many patients prefer inhalation when available due to rapid onset and adjustability 

• In jurisdictions where inhalation is allowed, patient satisfaction and adherence improve, and some patients reduce their use of other symptom-relief medications.

Recommendation: Amend Georgia law to authorize inhalation and vaporization, and consider pilot authorization for whole flower or edibles with potency / safety regulation.

References for Section 4
[1] Chayasirisobhon S. Pharmacokinetics of cannabis. Neurol Int (2020). https://pmc.ncbi.nlm.nih.gov/articles/PMC8803256/
[2] Lucas CJ et al. Cannabinoid PK/PD. Clin Pharmacokinet (2018). https://pmc.ncbi.nlm.nih.gov/articles/PMC6177698/ 

5) Compassionate “Right-to-Try” access (corrected again)

Georgia law already lists Crohn’s disease, cancer, and epilepsy as qualifying conditions. The true policy gap is that the law has a closed list, leaving out other debilitating conditions with supporting evidence.

Problem: Patients with serious, refractory illnesses not on Georgia’s list  such as fibromyalgia, ulcerative colitis, refractory migraine, anxiety disorders, and insomnia  remain ineligible even when conventional therapies fail.

Evidence:

• Fibromyalgia: THC/CBD improved symptom scores by 44% [1].

• Ulcerative colitis: Pilot RCTs show cannabis improved disease activity and quality of life compared to placebo [2].

• Refractory migraine/anxiety: Observational data show acute reductions in migraine intensity and significant decreases in GAD-7 anxiety scores after cannabis use [3].

Recommendation: Keep Georgia’s existing list intact but add a compassionate-use or physician-discretion pathway for conditions outside the list, aligning with models in New York and Minnesota.

References for Section 5
[1] Habib G, Artul S. Medical Cannabis for Fibromyalgia. Clin Exp Rheumatol (2018). https://pubmed.ncbi.nlm.nih.gov/29461346/
[2] Naftali T et al. Cannabis is associated with clinical improvement in ulcerative colitis. Dig Dis Sci (2011). https://pubmed.ncbi.nlm.nih.gov/33571293/
[3] Cuttler C et al. Short- and long-term effects of cannabis on headaches and migraine. J Pain (2019). https://pubmed.ncbi.nlm.nih.gov/31715263/ 

6) Direct patient delivery 

Georgia currently requires in-person dispensary pickup.

Problem: This requirement disproportionately burdens patients in rural areas, low-income communities, and those with limited mobility or disability. Many patients travel long distances, incur travel costs, or are unable to get to a dispensary at all. This contributes to healthcare disparities, especially for minority populations and those with chronic illness who already face barriers in accessing care.

Evidence:

• In 2025  more than 25 U.S. states + Puerto Rico allow some form of medical cannabis delivery, enabling access especially for those living far from dispensaries or without reliable transportation. 

• In many of those states, delivery programs have been cited in patient surveys as reducing missed doses, reducing travel burden, and improving treatment adherence among rural or homebound populations. (While specific empirical data from Georgia isn’t yet published, national data shows patients in states with delivery laws report fewer disruptions in care. )   

Recommendation: Georgia should authorize licensed home delivery by certified dispensaries or registered couriers under a regulated model. Key features should include:

• Track-and-trace systems to ensure accountability.

• Statewide availability, not limited only to urban areas.

• Priority provisions for underserved communities (e.g., rural counties, low-income areas, elderly or disabled patients).

• Reasonable delivery fees / subsidies to offset cost burdens.

References for Section 6
[1] “Cannabis Delivery Service by State: March 2025 Update.” CannabusinessPlans. 2025. https://cannabusinessplans.com/cannabis-delivery-service-by-state/ Cannabusiness Plans
[2] Ebling T., et al. “US State Recreational and Medical Cannabis Delivery Laws, 2024.” American Journal of Public Health. 2025. https://doi.org/10.2105/AJPH.2024.307874 American Journal of Public Health
[3] “Here’s Every State Where Marijuana Delivery Is Allowed as of April 2025.” The Marijuana Herald. April 2025. https://themarijuanaherald.com/2025/04/heres-every-state-where-marijuana-delivery-is-allowed-as-of-april-2025/

RECOMMENDATIONS FOR GEORGIA LOW-THC PROGRAM | TEREL NEWTON MD | TRULIEVE FL MED DIR 

Ga Program - https://dph.georgia.gov/low-thc-oil-registry 

1)  Removal of “end stage” language 

Georgia’s Low THC Oil Registry requires several (8 of 17 = about ½) conditions to be “severe or end stage” before patients qualify: cancer, ALS, multiple sclerosis, Parkinson’s, sickle cell, Alzheimer’s, AIDS, and peripheral neuropathy. Other conditions (e.g., intractable pain, PTSD, seizures) have no such qualifier.

Problem

This restriction denies earlier access even when evidence supports benefit in non–end stage disease:

• Multiple sclerosis: Nabiximols and oral THC/CBD reduce spasticity and pain and improved sleep; many of these patients had  moderate MS, not only end-stage [1].

• Parkinson’s disease: Cannabis reduced tremor and dyskinesia in outpatient studies of moderate-stage patients [2].

• Alzheimer’s disease: Low-dose THC reduced agitation and improved appetite in patients at mild-to-moderate stages [3].

• HIV/AIDS: Cannabis reduced neuropathic pain in ambulatory patients, not just at terminal stages [4]. 

Policy recommendation 

• Eliminate “end stage” as a requirement.

• Allow physicians to certify when the disease causes clinically significant symptoms or when standard therapies have failed.

• This mirrors how “intractable pain” is already handled in Georgia law, and it aligns with states like New York, where physician discretion governs eligibility.

References for Section 1
[1] Chan, A., & Silván, C. V. (2022). Evidence-based Management of Multiple Sclerosis Spasticity With Nabiximols Oromucosal Spray in Clinical Practice: A 10-year Recap. Neurodegenerative Disease Management, 12(3), 141–154. https://doi.org/10.2217/nmt-2022-0002

 [2] Lotan I et al. Cannabis (medical marijuana) treatment for motor and non-motor symptoms of Parkinson disease. Clin Neuropharmacol (2014). https://pubmed.ncbi.nlm.nih.gov/24614667/
[3] Shelef A et al. Safety and efficacy of medical cannabis oil for behavioral and psychological symptoms of dementia: an open label study. J Alzheimers Dis (2016). https://pubmed.ncbi.nlm.nih.g 

[4] Abrams DI et al. Neurology (2007). https://pubmed.ncbi.nlm.nih.gov/17296917/

2) Expansion of qualifying conditions

Georgia currently covers cancer, ALS, multiple sclerosis, Parkinson’s disease, Alzheimer’s disease, AIDS, peripheral neuropathy, epilepsy/seizures, Crohn’s disease, mitochondrial disease, autism spectrum disorder (with severity), Tourette’s syndrome (severe), PTSD (adults), intractable pain, and terminal illness.

Problem: This excludes conditions with strong or emerging evidence: fibromyalgia, ulcerative colitis, insomnia, opioid use disorder, and anxiety disorders.

Evidence:

• Fibromyalgia: THC/CBD lowered symptom burden by 44% [1].

• IBD: Cannabis reduced CDAI by >100 points; 45% remission [2].   [ 8 factors | 0-600 

• Insomnia: THC/CBD spray shortened sleep latency by 30–40 minutes, added ~1.2 hrs/night [3].

• Opioid use disorder: Cannabis laws linked to 17–31% lower opioid prescribing [4].

• Anxiety: Observational studies show significant acute reduction in GAD-7 scores post-cannabis use [5].

Recommendation: Add these conditions, or adopt a physician-discretion model (as in FL/VT/MN) to allow certification for any conditions similar to the qualified conditions and any debilitating illness.

References for Section 2
[1] Habib G, Artul S. Clin Exp Rheumatol (2018). https://pubmed.ncbi.nlm.nih.gov/29511842/
[2] Naftali T et al. Clin Gastroenterol Hepatol (2013). https://pubmed.ncbi.nlm.nih.gov/23648372/
[3] Suraev A et al. Sleep (2021). https://pubmed.ncbi.nlm.nih.gov/34009777/
[4] Bradford AC, Bradford WD. JAMA Intern Med (2018). https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/2676999
[5] Cuttler C et al. J Affect Disord (2018). https://pubmed.ncbi.nlm.nih.gov/30197194/

Notes: CDAI scores range from 0 to 600. A score of less than 150 corresponds to relative disease quiescence (remission); 150 to 219, mildly active disease; 220 to 450, moderately active disease; and greater than 450, severe disease. 

3) THC cap adjustment

Georgia law caps THC content at 5%, which prevents therapeutic dosing.

Problem: Patients requiring more than trace THC must consume impractically large amounts, raising cost, adherence issues, and risk of illicit use.

Evidence: Nabiximols (1:1 THC:CBD) is typically titrated to 8–12 sprays/day (~20–30 mg THC), achieving 25–34% spasticity reduction [1]. Long-term extensions permitted up to 48 sprays/day (~130 mg THC) [2]. Cancer pain trials used 20–40 mg THC/day with significant analgesia [3]. Experts recommend regulating high-THC products with labeling and taxation instead of blanket low caps [4].

Recommendation: Raise or remove the 5% THC cap, adopting targeted regulation for ultra-high potency products.

References for Section 3
[1] Patti F et al. Expert Rev Neurother (2022). https://pmc.ncbi.nlm.nih.gov/articles/PMC9539865/
[2] Langford RM et al. J Neurol (2013). https://pmc.ncbi.nlm.nih.gov/articles/PMC3437528/
[3] Blake A et al. Ann Palliat Med (2022). https://apm.amegroups.org/article/view/16199/html
[4] Hall W et al. Addiction (2023). https://doi.org/10.1111/add.16135

4) Addition of product forms and routes (revised)

Georgia law currently permits low-THC oil, tinctures, transdermal patches, lotions, and capsules.  

Problem: Forms like inhalation, vaporization, whole flower, and edibles are still prohibited. These forms can offer much faster onset (in minutes rather than hours), better options for acute symptom relief, and greater flexibility for patients who cannot swallow or want more precisely titratable doses.

Evidence:

• Inhaled cannabis peaks in 3–10 minutes, useful for breakthrough pain, nausea, or spasticity [1,2].

• Many patients prefer inhalation when available due to rapid onset and adjustability 

• In jurisdictions where inhalation is allowed, patient satisfaction and adherence improve, and some patients reduce their use of other symptom-relief medications.

Recommendation: Amend Georgia law to authorize inhalation and vaporization, and consider pilot authorization for whole flower or edibles with potency / safety regulation.

References for Section 4
[1] Chayasirisobhon S. Pharmacokinetics of cannabis. Neurol Int (2020). https://pmc.ncbi.nlm.nih.gov/articles/PMC8803256/
[2] Lucas CJ et al. Cannabinoid PK/PD. Clin Pharmacokinet (2018). https://pmc.ncbi.nlm.nih.gov/articles/PMC6177698/ 

5) Compassionate “Right-to-Try” access (corrected again)

Georgia law already lists Crohn’s disease, cancer, and epilepsy as qualifying conditions. The true policy gap is that the law has a closed list, leaving out other debilitating conditions with supporting evidence.

Problem: Patients with serious, refractory illnesses not on Georgia’s list  such as fibromyalgia, ulcerative colitis, refractory migraine, anxiety disorders, and insomnia  remain ineligible even when conventional therapies fail.

Evidence:

• Fibromyalgia: THC/CBD improved symptom scores by 44% [1].

• Ulcerative colitis: Pilot RCTs show cannabis improved disease activity and quality of life compared to placebo [2].

• Refractory migraine/anxiety: Observational data show acute reductions in migraine intensity and significant decreases in GAD-7 anxiety scores after cannabis use [3].

Recommendation: Keep Georgia’s existing list intact but add a compassionate-use or physician-discretion pathway for conditions outside the list, aligning with models in New York and Minnesota.

References for Section 5
[1] Habib G, Artul S. Medical Cannabis for Fibromyalgia. Clin Exp Rheumatol (2018). https://pubmed.ncbi.nlm.nih.gov/29461346/
[2] Naftali T et al. Cannabis is associated with clinical improvement in ulcerative colitis. Dig Dis Sci (2011). https://pubmed.ncbi.nlm.nih.gov/33571293/
[3] Cuttler C et al. Short- and long-term effects of cannabis on headaches and migraine. J Pain (2019). https://pubmed.ncbi.nlm.nih.gov/31715263/ 

6) Direct patient delivery 

Georgia currently requires in-person dispensary pickup.

Problem: This requirement disproportionately burdens patients in rural areas, low-income communities, and those with limited mobility or disability. Many patients travel long distances, incur travel costs, or are unable to get to a dispensary at all. This contributes to healthcare disparities, especially for minority populations and those with chronic illness who already face barriers in accessing care.

Evidence:

• In 2025  more than 25 U.S. states + Puerto Rico allow some form of medical cannabis delivery, enabling access especially for those living far from dispensaries or without reliable transportation. 

• In many of those states, delivery programs have been cited in patient surveys as reducing missed doses, reducing travel burden, and improving treatment adherence among rural or homebound populations. (While specific empirical data from Georgia isn’t yet published, national data shows patients in states with delivery laws report fewer disruptions in care. )   

Recommendation: Georgia should authorize licensed home delivery by certified dispensaries or registered couriers under a regulated model. Key features should include:

• Track-and-trace systems to ensure accountability.

• Statewide availability, not limited only to urban areas.

• Priority provisions for underserved communities (e.g., rural counties, low-income areas, elderly or disabled patients).

• Reasonable delivery fees / subsidies to offset cost burdens.

References for Section 6
[1] “Cannabis Delivery Service by State: March 2025 Update.” CannabusinessPlans. 2025. https://cannabusinessplans.com/cannabis-delivery-service-by-state/ Cannabusiness Plans
[2] Ebling T., et al. “US State Recreational and Medical Cannabis Delivery Laws, 2024.” American Journal of Public Health. 2025. https://doi.org/10.2105/AJPH.2024.307874 American Journal of Public Health
[3] “Here’s Every State Where Marijuana Delivery Is Allowed as of April 2025.” The Marijuana Herald. April 2025. https://themarijuanaherald.com/2025/04/heres-every-state-where-marijuana-delivery-is-allowed-as-of-april-2025/