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@admindotlaw With respect to the potential future ALJ hearing, do the OLC opinions hold weight? Or can the ALJ judge say the two-part test is not sufficient to prove CAMU?

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@natsfert @BalanJason Thanks for the info and great reporting! I expected this was the case as i would've only expected it to be signed after the OMB review and that would've been awfully fast. Hopefully @KevinSabet misinterpreted information he received rather than intentionally lying...

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@DTRTcannabis Which in theory means its been returned by the OMB.

Second example:
https://t.co/7Y0O8HnyiI

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@DTRTcannabis As a bit of an update to that you can see the historical reviews of the OMB - seems the signature happens after its completed. This is only one case, would need to find more to confirm.

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@admindotlaw Do you happen to know the order of process when it comes to signing a proposed rule? Does a proposed rule get signed before giving it to the OMB or after its returned? Seems a bit weird to me if the process involves signing off on it before giving it to the OMB.

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@KevinSabet @DavisonHal @adamgoers Do you have confirmation this was done in protest or just that Anne Milgram wasn't the one to sign it?

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@JustinH1664

https://t.co/jujR6bbp7J

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@admindotlaw @cmnyyonli Is it guaranteed a significant regulatory action at this point? Its also the OMBs job to determine if it is a significant action right?

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@Bkov9 4:15*

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@Bkov9 2/9/24 at 1:15PM ET

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@admindotlaw @SpcificImpsible Thanks for letting me pick your brain! I don't think you've entirely convinced me that the odds they go through order are 0% (just like the odds of it being schedule II), but your info has been useful. Looking foward to your analysis when DEA puts stuff on the register

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@admindotlaw @SpcificImpsible Just realized that question was a bit unclear, technically if someone wanted to legally challenge epidiolex's rescheduling when it was scheduled, it wouldn't hold up.

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@admindotlaw @SpcificImpsible I think thats pretty reasonable, so you don't think epidiolex scheduling would really hold up in courts?

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@admindotlaw @SpcificImpsible That why i believe epidiolex went through order - out of curiosity (maybe you already have publicly commented on it in the past), back in 2018 if you didn't already now know epidiolex went through order, would you have predicted order or formal rulemaking for it?

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@admindotlaw @SpcificImpsible away with it

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@admindotlaw @SpcificImpsible Now, due to it being both a medical review which should follow 811(a)-(c) but also the DEA imposing restrictions for the purpose of maintaining treaty compliance, i'm not confident which the DEA will choose to follow. They do seem to prefer going by final order when they can get

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@admindotlaw @SpcificImpsible "Finally, by considering HHS's recommendation, DEA has already begun the 811(a)-(c) process" - they also considered epidiolex's but did not follow (a)-(c) though right?

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@admindotlaw @SpcificImpsible not having to bet one way or another, just knowing that they are possibilities.

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@admindotlaw @SpcificImpsible I think i would be more confident in that if it was a schedule II rescheduling, but a (hopefully) schedule III rescheduling would involve placing restrictions not default to the CSA, thus justifying 811(d)(1) so as not to break with the treaty. That being said, i'm content