Part 01 · For Providers
Two-Hat Provider Guide · Part 01 of 10
Veterans use cannabis. State programs in 40 states authorize the medical practice of cannabis. The VA itself, under VHA Directive 1315, encourages veterans to disclose cannabis use and protects them from any benefits consequence for doing so. But the same VA directive prohibits VA providers from issuing cannabis certifications in their VA capacity. The result is a gap between what veterans need and what any single provider can offer under one credential. The two-hat model closes that gap by recognizing that the same clinician can hold both credentials — federal and state — and operate in each with the discipline the law itself requires.
The reassurance for cannabis-prescribing physicians
If you are a physician who already prescribes medical cannabis under a state medical cannabis practitioner credential, or you are considering it: you will not lose your medical license, your DEA registration, or your VA Community Care credentialing for writing medical cannabis treatments under your state authority. The federal protection has held for more than two decades under Conant v. Walters, and the VA itself, under VHA Directive 1315, explicitly does not punish providers for cannabis-related activity conducted outside their VA capacity. The two-hat model exists because this work is safe to do — not in spite of the legal framework, but because of how the framework is actually structured.
The numbers under the model
Survey data consistently shows that veterans use cannabis at meaningfully higher rates than the general adult population, with use rates particularly elevated among veterans with combat exposure, chronic pain, sleep disturbance, and PTSD. The reasons are not mysterious. Veterans return from service with conditions that respond poorly to the standard treatments the VA has on offer, and they look for alternatives. Many find them in state-licensed medical cannabis programs. The question for the healthcare system is whether those veterans have access to a treating clinician who understands both their federal VA care and their state cannabis care — or whether they are navigating two disconnected medical relationships on their own.
What the VA actually says
VHA Directive 1315 is the foundational document for VA cannabis policy. The directive does several things that providers entering the two-hat model should understand precisely:
- Veterans cannot be denied VA care or benefits for participating in a state-approved cannabis program. This protection is explicit.
- Veterans are encouraged to disclose cannabis use to their VA providers. The disclosure carries no benefits consequence and supports better coordinated care.
- VA providers may discuss and document cannabis use in the veteran’s VA medical record. This documentation supports drug interaction screening, treatment planning, and clinical decision-making.
- VA providers may not prescribe cannabis in their VA capacity, may not complete state certification forms, and may not register veterans for state cannabis programs while operating under VA authority. This is a federal authority constraint, not a state law constraint.
The directive does not prohibit a VA Community Care provider from also holding, separately, a state medical cannabis practitioner credential. It addresses what providers may do in their VA capacity. A clinician’s state-licensed activities, conducted under state authority outside their VA role, are governed by state law and state medical board oversight — not by VHA Directive 1315.
The current legislative trajectory
Congress has been moving on this. In June and July 2025, both chambers advanced appropriations measures that would, if enacted, allow VA clinicians to recommend cannabis directly in states where it is legal. These measures have not yet become permanent law, and VHA Directive 1315 remains the operative VA policy as of this writing. The trajectory matters because the gap the two-hat model fills today may narrow in coming years. Providers entering the model should track the legislative status and adjust their operational structure as policy evolves.
Why veterans benefit from the same clinician holding both credentials
The most common alternative to the two-hat model is the arrangement most veterans are using now: their VA Community Care provider for federal care, and a separate state cannabis practitioner (often someone they meet briefly and never see again) for the state cannabis certification. The arrangement has clinical problems. The cannabis practitioner does not know the veteran’s clinical history. The VA provider knows about the cannabis use but cannot, in their VA capacity, engage with the cannabis treatment itself. The veteran holds the integration in their own head, often imperfectly — managing drug interactions, dosing decisions, and treatment coordination across two providers who are not in contact with each other.
The two-hat model puts the clinical integration where it belongs: in a clinician who knows the veteran across both contexts. The same physician who manages a veteran’s chronic pain through VA Community Care is, in their separate state capacity, the physician who evaluates the appropriate role of cannabis in that picture and issues the state certification under state authority. The federal care and the state cannabis care remain operationally separate — different records, different billing, different schedules — but the clinical knowledge that informs each side is the same clinician’s.
Why veterans specifically
State medical cannabis programs serve many populations. Mendry’s focus is on veterans for three reasons that overlap.
First, the patient need is concentrated. Veterans use cannabis at higher rates than the general population, and they use it for conditions where clinical evaluation matters more — PTSD, chronic pain syndromes, sleep disturbance secondary to combat trauma. These are conditions where the medical question is genuinely clinical, not recreational.
Second, the federal care environment is unique. Veterans most often receive care through the VA system or through VA Community Care. That federal context creates the role-separation problem in its most acute form, because the federal payor is the one whose policy governs what the provider can do in their primary capacity.
Third, the integration matters more for veterans than for almost any other population. Veterans accumulate medical complexity at unusual rates. They take more medications. They have more concurrent conditions. They have more comorbid mental health concerns. Adding cannabis to their picture without clinical visibility creates real risk — risk that diminishes substantially when one clinician sees the whole picture across the two separated roles.
What this model is not
The two-hat model is not a way for VA Community Care providers to certify veterans for state cannabis programs under their VA credential. It does not authorize VA providers to issue state cannabis certifications in their VA capacity. It does not change VHA Directive 1315 or federal scheduling. The model works precisely because it honors the separation that current law requires, with the same clinician holding two credentials and operating distinctly under each.
The model is not a workaround for federal law. Cannabis remains a Schedule I controlled substance under federal law. The DEA’s rescheduling process to move cannabis to Schedule III is in progress but not finalized. State medical cannabis programs operate under state authority, with state-issued credentials, separate from federal credentialing. The two-hat provider works within this landscape, not against it.
The model is not a profit play. The economics, walked through in Part 5, are workable but not extraordinary. The reason to enter the two-hat model is the patient need it serves and the gap it closes — not the financial outcome it produces.
Why Mendry exists for this
A single provider trying to build the two-hat model alone faces real obstacles. The regulatory landscape varies state by state. The malpractice question takes work to navigate. The operational separation must be designed carefully. The patient communication patterns have to be developed. The peer network of other providers running this model does not exist without an organization that creates it. Mendry exists to be that organization. The role is educational and infrastructural — not clinical. Mendry does not provide treatment, prescribe or sell cannabis, complete state forms, or collect PHI. Mendry supports the provider community around the two-hat model with the resources, network, and credibility that make the work feasible for clinicians who would otherwise be doing it alone.
If the gap this guide opens with sounds real to you, the rest of the guide is worth reading. Parts 2 through 4 address the legal and regulatory questions. Parts 5 through 7 address the practical and financial questions. Parts 8 through 10 address the operational reality of running this model in your specific setting.