Written Testimony From Our Chief Medical Officer Dr. Karen Keough in Support of Texas House Bill 3703

April 10, 2019
Representative Stephanie Klick
State Representative—Texas House District 091
1100 Congress Avenue
Austin, TX 78701
[email protected]

Re: HB 3703

Dear Representative Klick:

I am writing to state my support for HB 3703, and the expansion of the Texas Compassionate Use Program.

I am a practicing child neurologist and epileptologist while also serving as the Chief Medical Officer of Compassionate Cultivation, one of three licensees in the TCUP.

I am a first-hand believer in the power of CBD as a medicine. But I didn’t always see it this way. When my patients first came to me years ago with the idea that CBD could be a game-changer, my initial reaction was to tell them, “Don’t believe everything you’re seeing in the news.”

In the interests of my patients and my practice, I decided to learn for myself. I thoroughly researched prior work, both anecdotal and clinical. I joined the management team at Compassionate Cultivation, where I have been able to define the rigorous dosing guidelines and shape product strategy.

Most important, since the availability of medical-grade CBD in Texas through the TCUP, I have prescribed CBD to over 100 of my patients suffering from intractable epilepsy and the results have far exceeded my expectations:

  • 12% of our patients have shown a 90% or greater reduction in seizures
  • Another 17% are experiencing a reduction in seizures of anywhere from 50-90%;
  • And an additional 27% show a demonstrable improvement in seizures since joining the program.
  • Beyond these impressive results in seizure reduction, patients & parents report many additional benefits including reduced spasticity, improved sleep, improved mood & decreased irritability.
  • Several of my epilepsy patients with severe aggression became much more manageable according to caregivers
  • CBD therapy is very safe. Most of my patients report no side effects. Occasional sleepiness occurs at higher doses

Seizure control is the most important part of an epilepsy medical regime. It can make the difference between living a normal life instead of one consumed by the condition. Epilepsy is life-threatening, and every seizure prevented decreases the risk of premature death. Many medications used for refractory epilepsy carry substantial adverse side effects that limit their use, or detract from the benefits of seizure mitigation. Having an effective treatment that brings positive benefits without detrimental side effects is life-changing, because seizure control is not the only factor that determines quality of life. This week I have seen 2-3 patients every day to gush about the improvements they have seen since starting CBD therapy. I sincerely believe that this is the most impactful new therapy to come into my practice in the last decade, and I am grateful to be able to offer it to my patients.

I also believe that the Texas Compassionate Use Program made a very wise choice to require physician guidance in CBD therapy. Many of my best success stories are patients who had tried CBD from other sources before the TCUP, and only marginal benefit until we were able to find the right balance of accurate dosing and appropriate combination with other medications. CBD therapy requires close follow-up and frequent readjustment with careful attention to each patient’s needs.

One of the biggest challenges medical practitioners and patients face in the field of CBD treatment is separation of hype from hope. CBD has real promise in a large range of neurological disorders including spasticity, chronic pain, insomnia, autism, anxiety, PTSD, to name a few. But it won’t cure everything, and it won’t work for everyone. We need to learn more about how and when to use CBD, and the growing body of medical research will bring us forward quickly in the next few years. Doctors in Texas have an opportunity to contribute to that body of knowledge since the Texas CUP provides a much more regulated and consistent treatment environment.

I urge you to expand the TCUP program to allow more doctors to utilize CBD to improve the quality of life in many deserving patients throughout the state of Texas. Some conditions that are well-supported as responsive to CBD therapy include spasticity (from many causes, including multiple sclerosis), PTSD, and severe developmental behavioral disorders including autism. Physicians need to educate themselves about the benefits and subtleties of this uniquely promising treatment,and start to incorporate CBD into their pharmacopeia.

I am also acutely aware of the need for regulation to ensure that CBD (and low concentration THC) is used appropriately and responsibly. I submit that the best custodians of these responsible decisions are physicians. Certainly, we wish to work within state regulations, but we also want to have the purview to make individual patient treatment plans on a case by case basis to maximize every patient’s potential.

CBD is medicine. And, in Texas, doctors should be involved.

Thank you for this opportunity,

Dr. Karen Keough, MD
Child Neurologist and Epileptologist
Chief Medical Officer, Compassionate Cultivation