Reducing Research Harms: Analysis and Recommendations for Researching Schedule I Substances Under the HALT Fentanyl Act
Alaina M. Jaster, Joseph J. Hennessey, Tanner L. Anderson, Anna Tsyrulnikov, Amartya Pradhan, Gina Giorgio, Elijah Z. Ullman
Journal of Science Policy & Governance July 2, 2026 Peer reviewed DOI: 10.38126/jspg280109 via OpenAlex
Summary
Research on Schedule I substances in the United States is heavily restricted by the Controlled Substances Act, creating what is termed Research Harm—the restriction or deterrence of legitimate scientific inquiry due to governmental regulatory controls and criminal prohibitions. Barriers include lengthy DEA registration timelines, inconsistent guidance, and policy confusion, limiting access to substances with therapeutic potential like psilocybin, MDMA, cannabis, and DOI. The 2025 HALT Fentanyl Act introduces procedural improvements such as expedited registration and shared institutional access but leaves key regulatory issues unresolved. Recommended reforms include revising medical utility interpretations, conducting periodic evidence reviews, and establishing a scheduling framework for easier research access.
Study at a glance
| Design | policy brief |
|---|---|
| Key finding | The regulatory structure of the Controlled Substances Act creates significant Research Harm by restricting legitimate scientific inquiry into Schedule I substances, and while the 2025 HALT Fentanyl Act offers some procedural improvements, key barriers remain unresolved. |
Abstract
Research on Schedule I substances in the United States remains heavily restricted by the regulatory structure imposed by the Controlled Substances Act (CSA). This regulatory system creates significant Research Harm, which can be defined as the restriction or deterrence of legitimate scientific inquiry arising from governmental actions, such as regulatory controls or criminal prohibitions that limit researchers’ access to or use of substances for scientific investigation. The barriers identified in this policy brief, including lengthy Drug Enforcement Administration (DEA) registration timelines, inconsistent guidance, and confusion around policies, limit access to substances with emerging therapeutic potential such as psilocybin, MDMA, cannabis, and DOI. The 2025 HALT Fentanyl Act introduces important procedural improvements, such as expedited registration, shared institutional access, and limited allowances for synthesis, but leaves key issues in regulatory processes unresolved. To ensure scientific progress and protect public health, we recommend further reforms, including revising interpretations of medical utility,, conducting periodic evidence reviews, and establishing a specific scheduling framework that allows easy access to substances for research