CBD for Physicians: What Doctors Need to Know About the BEI Program

By the Edify Clinical Team

The CMS Substance Access Benefit Enhancement Initiative (BEI) creates a new pathway for Medicare patients to access hemp-derived CBD products through their ACO. As a physician, your role in this program isn't passive. CMS requires documented shared decision-making before any substance access benefit is used, and that documentation starts with you.

This page gives you a clear overview of what the BEI program requires from physicians, how to identify qualifying products, and how to set up access for your patients. You can also visit our Medicare CBD program overview for a full program summary.

What the BEI Program Requires of Physicians

CMS has built shared decision-making into the BEI framework. Before a patient can access the substance access benefit, the ordering physician must document a structured conversation covering several specific elements.

Benefits and Risks Discussion

You must document that you've discussed the potential benefits of CBD for the patient's condition alongside known risks. This includes drug interactions, particularly with medications metabolized by cytochrome P450 enzymes, and the current state of clinical evidence. Your documentation should reflect that this was a real conversation, not a checkbox.

Patient Goals

The shared decision-making note should capture what the patient is hoping to achieve. Is it pain reduction? Better sleep? Reduced reliance on other medications? The goal should be clinically relevant and tied to a condition you're managing.

Medication Review

Document that you've reviewed the patient's current medication list. CBD has known interactions with blood thinners, seizure medications, and certain antidepressants. A medication review isn't optional; it's part of appropriate prescribing practice and CMS documentation requirements.

Follow-Up Planning

Your note should include a follow-up plan. When will you reassess? What outcomes are you tracking? CMS expects ongoing oversight, not a one-time authorization. Building follow-up into your workflow from the start keeps your documentation clean and protects your patients.

Product Qualification Requirements

Not all CBD products qualify under the BEI program. CMS has set specific product standards that any substance access benefit product must meet. Here's what qualifies:

Oral delivery only - Gummies and tinctures qualify. Topicals, vapes, and inhalables do not.
Hemp-derived CBD - Products must be derived from hemp, not marijuana or synthetic sources.
Delta-9 THC at or below 0.3% - Per federal definition of hemp. Every batch must be tested.
Total THC per serving at or below 3mg - Verified by certificate of analysis.
Third-party laboratory testing - Public COAs from accredited labs. Not in-house testing.
No synthetic cannabinoids - Naturally derived only.

Edify products meet all of these requirements. Our full compliance documentation is available at our compliance documentation page, and batch-specific COAs are posted at our lab results page.

Edify BEI Compliance Summary

BEI Requirement	Edify Compliance
Oral only	Yes. Gummies and tinctures
Hemp-derived	Yes. Kentucky-grown, Seed-to-Self
≤0.3% delta-9 THC	Yes. Every batch tested
≤3mg total THC/serving	Yes. Confirmed by COA
Third-party tested	Yes. Public COAs
No inhalables	Correct
No synthetic cannabinoids	Correct

How to Find Out If Your ACO Participates

The BEI is an opt-in enhancement available to ACOs participating in the Medicare Shared Savings Program (MSSP) and certain other advanced payment models. Not every ACO has enrolled in the BEI.

To check whether your ACO has opted into the Substance Access BEI, visit the CMS Innovation Center at innovation.cms.gov. You can also contact your ACO administrator directly. If your ACO hasn't enrolled yet and you're interested in advocating for participation, the application process is handled through your ACO's CMS relationship manager.

If your ACO is enrolled and you're ready to start ordering for patients, we can have your account set up quickly. The process is straightforward and designed with busy clinical practices in mind.

Edify's Qualifying Products

Edify offers two product formats that qualify under BEI product standards:

CBD Gummies

USDA organic, nano-enhanced, and available in consistent serving sizes. Each gummy contains a documented CBD dose and total THC per serving confirmed at or below 3mg by COA. Well-suited for patients who prefer a simple, predictable format.

CBD Tinctures

Sublingual delivery with nano-emulsified CBD for faster onset and more consistent absorption. Particularly relevant for patients with swallowing difficulties or who need dose flexibility. All tinctures are hemp-derived, third-party tested, and batch-documented.

Product specifications, ingredient lists, and full COA documentation are available through our compliance documentation page. We can also provide these directly to your compliance team upon wholesale inquiry.

How to Order for Your Patients

Once your ACO confirms BEI participation and you've completed the shared decision-making documentation, ordering through Edify is straightforward:

Submit a wholesale inquiry through our wholesale quote page. Include your organization name and approximate patient panel size.
Receive your pricing package within one business day, along with our full compliance documentation set.
Set up your account with your dedicated Edify account rep, who can walk your procurement team through the ordering process.
Place your first order and receive product with full batch documentation included.
Distribute to patients per your ACO's dispensing protocol, with documentation ready for your compliance files.

We work with ACO administrators, practice managers, and individual physicians. However your organization is structured, we can adapt to your workflow.

Content prepared by the Edify Clinical Team for licensed healthcare providers.

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