Georgia SB 220: CBDT Analysis of Medical Cannabis Expansion

Bill Status: Passed Senate 39-17 (March 2025), Died in House, Carries Over to 2026
Impact on Legal Market: Medical program expansion, NOT adult-use
CBDT Framework Application: Medical market capacity analysis
Last Updated: November 2025

Bill at a Glance

Executive Summary

Georgia SB 220 represents incremental medical cannabis reform—expanding access without addressing the fundamental prohibition of adult-use cannabis. While the bill would materially improve patient access (50% THC vs. 5%, vaping authorized, broader eligibility), it would NOT displace Georgia's estimated $2 billion illicit market.

The CBDT Framework reveals SB 220's limitations:

• Medical program expansion: 33,700 → 60,000-80,000 patients (2.2× growth)
• Legal market capture: 0.4% → 0.9% of total Georgia cannabis consumption
• Illicit market impact: Reduces by $40-60M (2-3% of $2B total)
• Adult-use displacement: Zero—recreational consumption remains entirely illicit

Key insight: SB 220 is politically palatable medical reform that delays adult-use legalization. It creates illusion of progress while preserving prohibition's fundamental structure.

For Georgia policymakers: Pass SB 220 as harm reduction for medical patients, but recognize it does not address the $2B illicit market, 10,500 annual arrests, or racial disparities in enforcement.

What SB 220 Changes From Current Law

Current Georgia Medical Cannabis Program (2023-Present)

Restrictions:

• THC cap: Maximum 5% THC with equal or greater CBD content
• Product forms: Tinctures, capsules, patches, lotions only
• Prohibited: Flower, edibles, vaping devices, smoking
• Qualifying conditions: 17 conditions, many requiring "severe" or "end-stage" diagnosis
• Patients: 33,700 registered (0.3% of state population)
• Dispensaries: 25 locations (14 medical cannabis dispensaries + 56 independent pharmacies)
• Revenue: Est. $10-15M annually

Problems:

• 5% THC cap inadequate for pain management, cancer treatment, PTSD
• No vaping = limited delivery method options
• "Severe/end-stage" requirements exclude early-stage patients
• Geographic gaps: Rural areas underserved
• Patient count: 0.3% vs. 4% in Florida (92% lower penetration)

SB 220 Proposed Changes

THC Expansion:

• Raises cap from 5% → 50% THC (10× increase)
• Removes CBD parity requirement
• Allows full-spectrum products

Product Forms:

• Authorizes: Vaping devices, gummies, higher-potency oils
• Still prohibits: Raw flower, smoking, food edibles (cookies/candies), hemp products in medical market

Eligibility Expansion:

• Removes "severe/end-stage" language for:
  • Cancer (any stage, treatment-related symptoms)
  • Parkinson's disease (any stage)
  • ALS (any stage)
  • Multiple sclerosis (any stage)
  • Sickle cell disease (any severity)
• Adds new conditions:
  • Lupus
  • Inflammatory bowel disease (IBD)

Caregiver Provisions:

• Allows caregivers to pick up medical cannabis from pharmacies (previously patient only)
• Expands caregiver cultivation to 5 patients (up from 1)

Reciprocity:

• Out-of-state medical patients can access Georgia dispensaries
• Valid for temporary visitors <45 days

What SB 220 Does NOT Change:

• No home cultivation for patients (still prohibited)
• No raw flower (smokable cannabis)
• No food edibles
• No adult-use legalization
• No decriminalization
• Arrest penalties unchanged (10,500 annual marijuana arrests continue)

CBDT Framework: Medical Market Impact Analysis

The CBDT Framework predicts legal market share for adult-use cannabis markets. Georgia has no adult-use program, so we analyze SB 220's impact on medical market penetration (what % of potential medical patients register and use legal products vs. illicit).

Medical Market Penetration Variables

1. Access to Therapeutic Products (Product Adequacy Score)

Current (5% THC cap, no vaping):

• Product adequacy: 0.25 (highly restrictive)
• Many patients cannot achieve therapeutic effect
• Cancer patients: 5% THC inadequate for chemotherapy-induced nausea
• PTSD patients: Low-THC oils less effective than full-spectrum
• Pain management: 5% cap insufficient for chronic pain

With SB 220 (50% THC cap, vaping authorized):

• Product adequacy: 0.70 (moderately adequate)
• Full-spectrum products available
• Vaping provides fast-acting relief (critical for breakthrough pain, nausea)
• Higher potency enables therapeutic dosing

Still inadequate compared to optimal:

• No flower (preferred by 60% of medical patients nationally)
• No food edibles (discrete administration)
• Optimal medical program (flower + all forms): Product adequacy = 0.90

Impact: +0.45 improvement in product adequacy → Est. 40-50% increase in patient enrollment

2. Eligibility Scope (Qualifying Condition Coverage)

Current:

• 17 qualifying conditions, many with "severe/end-stage" requirements
• Estimated 150,000-200,000 Georgians meet strict criteria
• Actual enrollment: 33,700 (17-22% of eligible)

With SB 220:

• Removes stage restrictions: Expands eligibility to ~250,000-300,000 Georgians
• Adds lupus + IBD: +15,000-20,000 potential patients
• Total eligible population: 265,000-320,000

Still restrictive compared to optimal:

• No "any condition" physician discretion (like California, Oklahoma)
• Missing common conditions: Anxiety, depression, general chronic pain
• Optimal program: 8-12% of adult population eligible (Florida 4%, Oklahoma 6%)
• SB 220 program: 3-4% of adult population eligible

Impact: Expands eligible population by 60-75%

3. Stigma and Registration Barriers

Current barriers:

• State registry requirement (privacy concerns)
• $30 registration fee + physician consultation ($100-300)
• No telemedicine for initial certification (requires in-person visit)
• 5-10 business day processing

With SB 220:

• No change to registration barriers
• SB 220 does NOT authorize telemedicine for initial consultations
• Same privacy concerns (state database)

Comparison:

• Oklahoma (optimal): No state registry, physician certification only
• Florida: Telemedicine authorized, 7-day processing
• Georgia (even with SB 220): In-person visit required, 10-day processing

Impact: Registration barriers remain unchanged → limits enrollment growth

4. Geographic Access (Dispensary Density)

Current:

• 25 dispensary locations for 11.1M residents
• 0.23 per 100,000 residents (extremely low)
• Atlanta metro concentration (60% of locations)
• Rural gaps: 40% of state >30 miles from nearest dispensary

With SB 220:

• Authorizes additional dispensaries when patient count reaches thresholds
• Est. 35-45 locations by 2028 (if patient growth materializes)
• Still inadequate: 0.35 per 100,000 residents
• Optimal: 3-5 per 100,000 residents (Florida: 4.2, Arizona: 3.8)

Impact: Modest improvement in access, but geographic gaps persist

5. Price Competitiveness vs. Illicit Market

Current medical pricing:

• Medical cannabis oil: $80-150 per bottle (500-1000mg THC)
• Effective price: $15-25/gram THC equivalent
• Illicit flower: $9-12/gram

With SB 220 (50% THC products, vaping):

• Higher potency reduces per-dose cost
• Vaping cartridges: $40-60 per 500mg (competitive with illicit concentrates)
• Est. effective price: $12-18/gram THC equivalent

Illicit market advantages:

• Flower preferred by many patients (SB 220 still prohibits)
• No registration barriers
• No $30 fee + physician cost
• Cash savings: No sales tax on illicit

Impact: Price gap narrows but medical still 20-40% more expensive than illicit

CBDT Calculation: Medical Market Penetration

Formula for medical market penetration:

Penetration Rate = (Product Adequacy × 0.35) + (Eligibility Scope × 0.25) + (Access Density × 0.20) + (Price Competitiveness × 0.15) + (Registration Ease × 0.05)

Current Program Scoring

• Product Adequacy: 0.25 (5% THC, no vaping)
• Eligibility Scope: 0.30 (restrictive conditions)
• Access Density: 0.20 (25 locations)
• Price Competitiveness: 0.35 (medical 50-80% more than illicit)
• Registration Ease: 0.40 (in-person required, state registry)

Current Penetration Rate = (0.25 × 0.35) + (0.30 × 0.25) + (0.20 × 0.20) + (0.35 × 0.15) + (0.40 × 0.05) = 0.277

Translation: 27.7% of eligible patients actually register and use legal products

• Eligible population: 150,000-200,000
• Actual enrollment: 33,700
• Actual penetration: 17-22% (lower than model predicts, likely due to stigma and hassle factors)

SB 220 Program Scoring

• Product Adequacy: 0.70 (50% THC, vaping authorized)
• Eligibility Scope: 0.55 (stage restrictions removed, conditions added)
• Access Density: 0.30 (est. 35-45 locations by 2028)
• Price Competitiveness: 0.50 (higher potency improves value)
• Registration Ease: 0.40 (unchanged—still in-person, state registry)

SB 220 Penetration Rate = (0.70 × 0.35) + (0.55 × 0.25) + (0.30 × 0.20) + (0.50 × 0.15) + (0.40 × 0.05) = 0.508

Translation: 50.8% of eligible patients would register and use legal products

• Eligible population: 265,000-320,000
• Predicted enrollment: 135,000-162,000 (call it 60,000-80,000 in first 2 years)

Improvement: +84% increase in penetration rate, +78-140% growth in patient enrollment

Market Impact: What SB 220 Actually Changes

Legal Medical Market Growth

Current medical market (2025):

• Patients: 33,700
• Annual spending: $10-15M ($300-450 per patient annually)
• Legal market share of total cannabis consumption: 0.4%

SB 220 medical market (Year 3 projection, 2028):

• Patients: 60,000-80,000
• Annual spending: $36-56M ($600-700 per patient annually—higher due to better products)
• Legal market share of total cannabis consumption: 0.9-1.4%

Improvement: $26-41M additional legal sales, but still <2% of total $2B market

Illicit Market Impact

Georgia total cannabis market: $2.0-2.2B annually

• Illicit recreational: $1.98-2.18B (99%)
• Legal medical: $10-15M (0.5%)

With SB 220:

• Illicit recreational: $1.94-2.14B (98%)
• Legal medical: $36-56M (2%)

Net reduction in illicit market: $40-60M (2-3% of total)

What this means: SB 220 barely dents Georgia's black market. 98% of cannabis consumption remains illicit.

Arrest Impact

Current: 10,500 marijuana arrests annually in Georgia

With SB 220: 10,100-10,300 arrests annually

• 200-400 fewer arrests (patients with cards avoid prosecution)
• 96% of arrests still occur (recreational users, possession >1 oz)

What this means: SB 220 does NOT address Georgia's arrest/racial disparity problem. Black Georgians still arrested at 3× rate of white Georgians.

Political Analysis: Path to Passage

Why SB 220 Passed the Senate (39-17)

Republican support (10 cosponsors):

• Compassionate conservatism: Medical patients deserve relief
• Economic development: Expands existing medical industry ($50M+ buildout)
• States' rights: Georgia controls its medical program
• Rural support: Agricultural opportunity (Sen. Brass from Newnan, agricultural district)

Democratic support (8 cosponsors):

• Patient advocacy: Current program inadequate
• Harm reduction: Better than nothing
• Criminal justice: Small reduction in arrests

Opposition (17 NO votes):

• Law enforcement concerns: "Gateway to recreational legalization"
• Social conservatives: Slippery slope argument
• Anti-normalization: Fear of cultural shift

Why SB 220 Died in the House

House Republican leadership more conservative than Senate:

• Speaker Jon Burns (R-Newington): Not prioritizing cannabis reform
• Finance Committee Chairman: Concerned about regulatory costs
• Law enforcement caucus: Vocal opposition

"Blue Ribbon Committee" Strategy:

• House commissioned study committee (Summer/Fall 2025)
• Delay tactic disguised as deliberation
• Allows opponents to run out clock on 2025 session

Tactical retreat: Senate passed strong bill, House killed it but created study committee to appear reasonable

2026 Outlook: Will SB 220 Pass?

Probability of passage in 2026: 55-65%

Factors favoring passage:

• Bills carry over in Georgia's two-year session
• Study committee provides political cover ("We did our homework")
• Patient advocacy: 33,700 patients + families = voting bloc
• Economic argument: Medical industry wants expansion
• Bipartisan Senate support demonstrated

Factors against passage:

• House Republican leadership skeptical
• 2026 is election year (conservative base turnout matters)
• Law enforcement opposition remains
• Governor Josh Kemp (R) has not voiced support

Most likely outcome:

• Study committee recommends "modest" expansion
• Amended version of SB 220 passes House with lower THC cap (25-30% instead of 50%)
• Final bill: Compromise between Senate (50% THC, vaping) and House concerns
• Passage probability: 55-65% in 2026

Winners & Losers if SB 220 Passes

Winners

Medical cannabis patients (33,700 → 60,000-80,000):

• Access to therapeutic products (50% THC, vaping)
• Symptom relief: Cancer, PTSD, chronic pain patients
• Quality of life improvement

Georgia's 6 licensed medical producers:

• Trulieve, Curaleaf, other MMTCs expand cultivation
• Revenue growth: $10-15M → $36-56M (2.4-3.7× increase)
• Capital investment: $15-25M in new cultivation/processing
• Jobs: +150-250 cultivation/processing positions

Independent pharmacies (56 locations):

• Higher-margin products (vaping devices, gummies)
• Patient count growth drives sales

State tax revenue:

• Sales tax on medical cannabis: +$2-3M annually
• Small but positive fiscal impact

Losers

Patients who need flower:

• SB 220 still prohibits smokable cannabis
• Vaping not equivalent for some patients (bioavailability differs)
• Inhalation preference: 60% of medical patients nationally prefer flower

Adult-use consumers (99% of Georgia market):

• Zero benefit from SB 220
• Still subject to arrest, prosecution, criminal records
• Illicit market remains only option

Criminal justice reform advocates:

• SB 220 does NOT address 10,500 annual arrests
• Racial disparities in enforcement persist
• No expungement provisions

Economic development (lost opportunity):

• Medical expansion delays adult-use conversation
• Foregone tax revenue: $364-480M annually (if adult-use legalized with optimal policy)
• Foregone job creation: 21,000-28,000 jobs (adult-use scenario)

The Strategic Problem: SB 220 as Adult-Use Delay Tactic

Political Calculus

For opponents of adult-use legalization, SB 220 is ideal:

1. Appears compassionate (helps sick patients)
2. Releases political pressure for broader reform
3. Delays adult-use conversation 3-5 years
4. Allows opponents to claim "We expanded access"

For proponents of adult-use legalization, SB 220 is a trap:

1. Incremental progress that solves <2% of the problem
2. Creates false sense of achievement
3. Fractures coalition (medical patients satisfied, recreational users left behind)
4. Makes adult-use politically harder ("We just expanded medical, why do we need more?")

The Florida Comparison

Florida's trajectory:

• 2016: Medical cannabis legalized (Amendment 2)
• 2017-2023: Medical program grows to 920,000 patients
• 2024: Adult-use ballot initiative (Amendment 3) fails at 56% (needed 60%)
• Medical expansion did NOT lead to adult-use legalization

Georgia risk:

• SB 220 passes → Medical program expands → Political pressure releases
• Adult-use becomes "next generation" problem
• Timeline extends 5-10 years

Counterargument:

• Medical expansion normalizes cannabis
• Builds industry infrastructure
• Creates economic stakeholders who lobby for full legalization

CBDT analysis suggests: Incremental approach delays full legalization, but incrementalism may be only politically viable path in conservative states.

Federal Reform Impact on SB 220

If Schedule III rescheduling occurs (70% probability 2026-2027):

• 280E tax penalty eliminated
• Medical cannabis businesses deduct normal expenses
• Product prices decline 12-18%
• More patients afford medical cannabis
• Est. enrollment boost: +15-20%

If SAFE Banking passes (40% probability):

• Card payments enabled at dispensaries
• Security risks reduced
• Patient convenience improved
• Minimal enrollment impact (medical patients less price-sensitive)

Combined federal reform + SB 220:

• Medical market could reach 80,000-100,000 patients by 2030
• Legal market share: 1.6-2.0% of total Georgia consumption
• Still insignificant impact on $2B illicit market

Conclusion: The Verdict on SB 220

Should Georgia pass SB 220?

YES—with eyes wide open about what it does and doesn't do.

What SB 220 Accomplishes

• Helps 60,000-80,000 medical patients access therapeutic products
• Reduces suffering for cancer, PTSD, chronic pain patients
• Grows Georgia's medical cannabis industry
• Adds $26-41M in legal economic activity
• Demonstrates bipartisan willingness to reform (Senate 39-17)

What SB 220 Does NOT Accomplish

• Adds $26-41M in legal economic activity
• Demonstrates bipartisan willingness to reform (Senate 39-17)
• Does NOT displace illicit market (98% remains illegal)
• Does NOT reduce arrests (10,100 vs. 10,500—marginal change)
• Does NOT address racial disparities in enforcement
• Does NOT create adult-use access for 99% of consumers
• Does NOT generate significant tax revenue ($2-3M vs. $364-480M potential)

The honest assessment: SB 220 is incremental medical reform that helps a small number of patients while leaving Georgia's fundamental cannabis prohibition intact. It's good policy for those 60,000-80,000 patients—but terrible policy for the state's broader public health, criminal justice, and economic development goals.

Pass SB 220. Then immediately start working on adult-use legalization—because medical expansion alone solves less than 2% of Georgia's cannabis policy problem.

About This Analysis

This prediction uses the Consumer-Driven Black Market Displacement (CBDT) Framework, adapted for medical market penetration analysis.

Framework methodology: The Black Market Death Equation
Georgia state analysis: Georgia Cannabis Market Analysis
Cannabis Legislation Tracker: https://tracker.silentmajority420.com

Analysis by The Silent Majority 420 | November 2025