The two-hat model’s feasibility depends heavily on the state where the provider practices. Federal VA Community Care credentialing operates the same way nationwide, but state cannabis programs vary enormously — in what they authorize, who can participate, what evaluations look like, and what restrictions apply. A model that works seamlessly in one state may be impractical or unavailable in the next.
The three rough categories of states
- Category 1
States with established medical cannabis programs that have been operating for several years, with broad qualifying condition lists, accessible provider registration processes, and operational dispensary networks. As of mid-2026, this group includes most of the states that adopted medical cannabis programs prior to 2018, including California, Colorado, Florida, Illinois, Maryland, Massachusetts, Michigan, New York, Oregon, and Washington, among others. In these states, the two-hat model is operationally workable, the regulatory framework is mature, and providers can build practice volume reasonably quickly.
- Category 2
States with medical cannabis programs that operate, but with significant restrictions — narrow qualifying condition lists, limited provider participation, restrictive evaluation requirements, or operationally constrained dispensary networks. These states are workable for the two-hat model but require providers to learn the specific state rules carefully before structuring their practice. Examples vary as state programs evolve; the right way to assess any specific state is current consultation with that state’s cannabis program office and a healthcare attorney familiar with the state’s framework.
- Category 3
A small but shrinking number of states still do not have functioning medical cannabis programs. In these states, the two-hat model cannot operate — there is no state authority under which the cannabis evaluation practice would exist. Providers in these states can run a federal VA Community Care practice but cannot add the state cannabis evaluation component. Some of these states have CBD-only programs that do not require physician evaluation in the same way; these programs do not support the two-hat model as the model is structured.
The variables that matter most
When evaluating a specific state’s feasibility, several variables matter more than others:
How does a physician register with the state cannabis program? What is the application process, the fee, the renewal cycle? Some states have simple, accessible registration processes; others require continuing education in cannabis-specific topics, specialty certifications, or other gating requirements. Knowing the registration process before deciding to enter the model is essential.
What conditions qualify a patient for the state cannabis program? Broad lists (chronic pain, PTSD, anxiety) support more accessible practice patterns. Narrow lists (specific cancer diagnoses, specific seizure disorders, limited terminal conditions) constrain practice patterns significantly. Veteran patient populations in particular benefit from states with PTSD as a qualifying condition, which is increasingly common but not universal.
What does the state require in each evaluation? Some states require comprehensive medical examinations; others accept focused evaluations. Some require in-person visits; others allow telehealth. Some require pre-existing physician-patient relationships before cannabis evaluation; others permit first-encounter evaluations. The structure of these requirements shapes what the practice looks like operationally.
How often must patients return for re-evaluation? Annual renewals create steady recurring practice volume; biennial renewals reduce administrative burden but require longer-term patient retention. The renewal pattern affects the practice’s long-term economics meaningfully.
Telehealth in cannabis evaluation
State rules on telehealth-based cannabis evaluation vary significantly and have been changing rapidly since 2020. Several states permit telehealth evaluations under defined conditions; others require initial in-person evaluation with telehealth permitted for renewals; others prohibit telehealth-based cannabis evaluation entirely. Providers considering a telehealth-based practice should confirm current rules in every state where patients might be located — a provider licensed in one state cannot conduct telehealth cannabis evaluations for patients located in another state unless licensed there as well.
Cannabis evaluation telehealth is constrained by the same cross-state licensure rules that constrain other medical telehealth. A provider physically located in California, licensed in California, with a California state cannabis registration, conducts cannabis evaluations only for patients physically located in California at the time of the encounter. Telehealth does not extend the provider’s state authority across state lines.
Multi-state providers
Some providers operate practices across multiple states — particularly providers in metropolitan areas that span state lines, or providers operating telehealth practices in multiple licensed states. For the cannabis evaluation side of the practice, multi-state operation requires separate state cannabis registrations in each state, separate compliance with each state’s program rules, and separate documentation reflecting which state authority applies to each evaluation.
The administrative complexity grows quickly. A two-state practice carries two registrations to maintain, two compliance frameworks to track, two sets of qualifying conditions to know, two evaluation requirement sets to follow. Most providers find that the operational complexity outweighs the patient volume benefits unless the cross-state demand is substantial.
Veteran patient distribution
For the two-hat model specifically, the veteran patient distribution matters as much as the cannabis program structure. States with large veteran populations (Texas, Florida, California, Virginia, North Carolina, Pennsylvania, among others) tend to have correspondingly large potential patient bases for a two-hat practice. States with smaller veteran populations may make the model less practical at scale even when the cannabis program is favorable.
VA Community Care referral patterns also vary by state. Some states have VA medical facilities with significant Community Care utilization (typically rural states with long travel distances to VA facilities); others have lower Community Care utilization because VA direct care is more accessible. The volume potential of the federal-practice side of the two-hat model varies accordingly.
How to evaluate a specific state
Providers considering the two-hat model in a specific state can work through a feasibility assessment by answering a set of concrete questions:
- Does the state have a functioning medical cannabis program with provider participation?
- Are PTSD and chronic pain (the two most common veteran qualifying conditions) on the state’s qualifying condition list?
- What is the physician registration process for the state cannabis program?
- What are the state’s evaluation requirements — comprehensive vs. focused, in-person vs. telehealth, established vs. new patient?
- What is the renewal frequency?
- What is the state’s veteran population?
- How active is VA Community Care utilization in the state?
- What does the state’s healthcare regulatory environment look like for the federal practice side — medical board climate, scope of practice rules, malpractice landscape?
The answers, taken together, give a clear feasibility picture. States that answer affirmatively across most questions support the two-hat model robustly. States that answer poorly on several questions may make the model impractical even if it is technically legal.
The right starting point
For most providers, the right starting point is the state where they already hold their federal medical license and VA Community Care credentialing. Adding a state cannabis registration to an existing federal practice is operationally simpler than relocating or extending licensure across states. The two-hat model is more accessible in some states than others, and providers in states where the model is harder may rationally choose to focus on the federal practice alone rather than force the two-hat structure where the state environment does not support it well.
Mendry’s state-specific resources track the program details for each state with an active medical cannabis program, including current registration processes, qualifying condition lists, evaluation requirements, and operational considerations specific to two-hat practice. Providers considering the model should consult both Mendry’s resources and direct outreach to the relevant state cannabis program office before making structural decisions.