What Happens When the Dispensary Starts Looking More Like a Pharmacy?

For years, marijuana has occupied a strange space in American health care. In one corner, it sat beside heroin and lysergic acid diethylamide as a federal Schedule I controlled substance with “no accepted medical use.”¹ In the other corner, millions of Americans were legally purchasing cannabis products through state medical and recreational programs that operated in plain sight. That contradiction may finally be starting to crack.

The Trump administration’s recent decision to move certain medical marijuana products from Schedule I to Schedule III marks one of the most significant federal drug policy shifts in decades.² Although the move is limited in scope and does not legalize recreational marijuana, it raises a series of questions that pharmacists, regulators, wholesalers, insurers, and health systems can no longer avoid. Most notably, what happens when marijuana begins to look less like a fringe product and more like a traditionally regulated medication?

The rescheduling applies to FDA-approved marijuana products and products regulated through state medical marijuana programs. In practical terms, marijuana is now being grouped alongside Schedule III medications such as ketamine, anabolic steroids, testosterone products, and acetaminophen with codeine.²

That may sound like a technical legal change, but in the pharmacy world, scheduling classifications matter. They affect everything from prescribing authority and DEA registration requirements to inventory controls, recordkeeping obligations, reimbursement models, research access, and how health care professionals psychologically view a product.

Why Schedule III Matters

For decades, the Schedule I designation created enormous barriers to legitimate medical research. Researchers faced extensive DEA hurdles simply to obtain and study marijuana products. Universities and health systems often avoided the topic altogether because the compliance burdens were so substantial.³

Now, with marijuana shifting into Schedule III for certain categories, those barriers may begin to loosen. That could lead to more clinical trials, more standardized dosing data, better understanding of drug interactions, and potentially greater physician comfort with recommending cannabinoid-based therapies.

Will Cannabis Enter the Traditional Pharmacy System?

The bigger question for pharmacy may be whether this change slowly pulls cannabis into the traditional prescription drug distribution ecosystem. Today, most marijuana products exist in a parallel universe outside of mainstream pharmacy practice. They are generally dispensed through state-licensed dispensaries operating under unique regulatory frameworks that often have little resemblance to conventional pharmacy law. In many states, pharmacists are not even required to be physically present.⁴

Yet once a substance is federally recognized as having accepted medical use and placed into Schedule III, the conversation inevitably changes. Will pharmacies eventually stock medical marijuana products? Will wholesalers distribute them through traditional pharmaceutical supply chains? Will state boards of pharmacy begin asserting more direct oversight? Will pharmacy benefit managers and insurers eventually demand standardized utilization controls and formulary management?

Perhaps the most interesting question of all: If marijuana is now a Schedule III controlled substance, does that mean a prescription is ultimately required? At the moment, the answer to this question is not entirely clear.

The current framework still largely relies upon state medical marijuana programs, many of which use physician certifications or recommendations rather than traditional prescriptions. That distinction has historically been important because federal law prohibited prescribing Schedule I substances.^4,5

But Schedule III drugs traditionally require valid prescriptions issued by DEA-registered practitioners.⁶ If marijuana products continue migrating into the federally recognized controlled substance framework, pressure will likely grow for greater alignment with conventional controlled substance prescribing standards.

That could create operational and political tension. Many existing cannabis businesses were built around a retail dispensary model that intentionally operates outside traditional pharmacy systems. Bringing marijuana into a prescription-based pharmacy framework could fundamentally change who dispenses the product, who supervises dispensing, how records are maintained, and how patient counseling occurs.

Why Pharmacists Should Pay Attention

For years, the profession has argued that pharmacists are medication experts uniquely positioned to oversee drug therapy management, patient counseling, adverse event monitoring, and controlled substance stewardship. If marijuana increasingly becomes recognized as a legitimate therapeutic product, it would be difficult to argue that pharmacists should be excluded from the conversation.

At the same time, many pharmacists remain skeptical. Some continue to raise concerns regarding product standardization, potency variability, limited long-term efficacy data, psychiatric effects, diversion risks, and the commercialization of high-potency tetrahydrocannabinol products. Others worry that rapid normalization may outpace the science.⁷

Those concerns are not frivolous. Modern cannabis products are dramatically different from what existed decades ago. High-potency concentrates, infused beverages, gummies, vapes, and engineered delivery systems have transformed the market into something far more sophisticated—and far more commercially aggressive.⁸

This is where pharmacy leadership becomes important. The profession should avoid simplistic “pro-marijuana vs anti-marijuana” framing. The real issue is whether pharmacists will help shape the clinical and regulatory framework surrounding cannabinoid therapy or simply watch others do it for them.

History suggests that once a product enters mainstream therapeutic use, pharmacy infrastructure eventually follows. That infrastructure brings controls, documentation standards, counseling obligations, inventory safeguards, and clinical oversight. In many ways, marijuana now appears to be standing at the front door of that process.

The DEA’s upcoming hearings regarding broader marijuana rescheduling will likely intensify the debate. Litigation from antilegalization groups is also almost certain, and Congress may eventually become involved if federal and state systems continue colliding.

But regardless of where one stands politically, one thing is becoming increasingly difficult to deny: Marijuana is no longer sitting entirely outside the American health care system. The question now is whether pharmacy intends to help regulate that reality or simply react to it after the fact.

About the Author

Ned Milenkovich, PharmD, JD, is chair of the health care law practice at Much Shelist PC and is the former vice chairman of the Illinois State Board of Pharmacy.

REFERENCES

1. Drug scheduling. DEA. Accessed May 21, 2026. https://www.dea.gov/drug-information/drug-scheduling

2. Justice Department places FDA-approved marijuana products and products containing marijuana subject to a qualifying state-issued license in Schedule III, strengthening medical research while maintaining strict federal controls. News release. US Department of Justice Office of Public Affairs. April 23, 2026. Accessed May 21, 2026. https://www.justice.gov/opa/pr/justice-department-places-fda-approved-marijuana-products-and-products-containing-marijuana

3. Challenges and barriers in conducting cannabis research. In: National Academies of Sciences, Engineering, and Medicine; Health and Medicine Division; Board on Population Health and Public Health Practice; Committee on the Health Effects of Marijuana: An Evidence Review and Research Agenda. The Health Effects of Cannabis and Cannabinoids: The Current State of Evidence and Recommendations for Research. National Academies Press; 2017. Accessed May 26, 2027. https://www.ncbi.nlm.nih.gov/books/NBK425757/

4. Tanco K, Olson A, Fellman B, et al. Analysis of dispensing and utilization patterns of medical cannabis products in state licensed cannabis dispensaries. J Palliat Med. 2023;26(11):1482-1487. doi:10.1089/jpm.2023.0075

5. Merlin JS, Althouse A, Feldman R, et al. Analysis of state cannabis laws and dispensary staff recommendations to adults purchasing medical cannabis. JAMA Netw Open. 2021;4(9):e2124511. doi:10.1001/jamanetworkopen.2021.24511

6. Requirement of Prescription. 21 CFR §1306.21 (2010).

7. Merks P, Cameron J, Kazmierczak J, et al. Concerns, beliefs and attitudes of pharmacists about medical cannabis use in Poland. Healthcare (Basel). 2025;13(21):2657. doi:10.3390/healthcare13212657

8. Stuyt E. The problem with the current high potency THC marijuana from the perspective of an addiction psychiatrist. Mo Med. 2018;115(6):482-486.