Hospital Pharmacy - February 2020 - 9

873870
editorial2019

HPXXXX10.1177/0018578719873870Hospital PharmacyDill and Kurkowski

Editorial

CBD: Considerations for Use Within
the Health System
Jennifer L. Dill1

Hospital Pharmacy
2020, Vol. 55(1) 9-11
© The Author(s) 2019
Article reuse guidelines:
sagepub.com/journals-permissions
https://doi.org/10.1177/0018578719873870
DOI: 10.1177/0018578719873870
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and Austin Kurkowski2

The landscape for use of cannabidiol (CBD) is rapidly evolving across the United States. Laws regulating the sale, distribution, and possession of CBD are being enacted on a
state-by-state basis, creating ambiguity in navigating the medical, legal, and ethical issues surrounding the use of these
products. As public opinion propels toward the acceptable use
of CBD, patients are increasingly seeking advice and information regarding safe and effective use of these products.
Pharmacists are the likely go-to experts to assist the health
care team in addressing patient questions and concerns related
to CBD and it is imperative that they be well informed on
medical literature and legal considerations to effectively navigate these issues within the health system environment.
CBD is a pharmacologically relevant constituent of the
cannabis plant, or marijuana, which lacks the intoxicating
properties that are attributable to tetrahydrocannabinol
(THC), the primary psychoactive constituent of cannabis.
CBD products have been widely marketed as human drugs,
dietary supplements, additives to food products, e-liquids for
vaping, animal foods and drugs, cosmetics, and more. They
can be administered via inhalation, oral, buccal, or topical
routes. Although widely marketed for the treatment of a variety of conditions, conclusive evidence regarding safety and
efficacy of cannabis for therapeutic purposes is largely lacking. In a 2017 report, an expert committee of the National
Academies of Sciences, Engineering, and Medicine
(NASEM) conducted an in-depth, comprehensive review of
the medical literature and characterized the strength of evidence regarding whether cannabis or cannabinoids are effective or ineffective for certain therapeutic conditions. They
determined that there is "conclusive" or "substantial" evidence for efficacy for only 3 therapeutic uses: (1) antiemetic
effects in chemotherapy-induced nausea and vomiting, (2)
chronic pain in adults, and (3) multiple sclerosis-related
spasticity as reported by patients1 (the full report can be
accessed at: nationalacademies.org/CannabisHealthEffects).
Of foremost importance in navigating the use of CBD
products within the health system environment is understanding and complying with the current legal landscape. On the
federal level, cannabis or marijuana has been controlled since
1970 under the Controlled Substance Act (CSA) as Schedule I
due to high potential for abuse related to the THC component
and no medically accepted therapeutic use, making it illegal
for providers to prescribe or pharmacies to dispense.2 The
2018 Farm Bill removed hemp, including cannabinoid,

containing less than 0.3% THC on a dry weight basis from the
CSA; therefore, it is no longer considered a controlled substance under federal law. However, this does not mitigate the
authority of the Food and Drug Administration (FDA) to regulate cannabis products under the Food, Drug and Cosmetic
(FD&C) Act. Although currently marketed CBD products
span the range of categories that fall under the jurisdiction of
the FDA, the scope and approach that the FDA will adopt in
regulating these products are unclear. The FDA held a public
hearing on May 31, 2019 to provide an opportunity for stakeholders to share their experiences with cannabis-related products and solicit input as to the current regulatory strategy.3
Beyond consideration of federal regulations, state regulations must be considered and care taken to remain in compliance with the more restrictive law. For example, the State of
Kansas recently excepted CBD from the definition of marijuana, descheduling CBD products from the Kansas Uniform
Controlled Substances Act.4 Although this currently applies
only for products that contain zero THC, a bill is being considered that would allow CBD products to contain up to 5%
THC as verified by a third-party, independent laboratory for
patients with debilitating medical conditions.5 If passed, this
would exceed the allowable THC content (<0.3%) defined
in the federal CSA allowing for deregulation of CBD products. This leaves health system providers in the gray zone of
navigating provision of care to patients who readily have
access to CBD products in the community, but the use of
which may be restricted or denied within the health system
setting due to concerns regarding compliance with federal
law and maintaining their Drug Enforcement Administration
(DEA) license. This confusion is amplified for health systems that have locations in multiple states or boarder states
as regulations may differ and CBD products available to
patients may not meet the legal requirement of the location
where the patient is being admitted. This may require different policies or workflows for locations within the same
health system creating confusion and frustration for patients
and providers alike.
1

University of Kansas Medical Center, Kansas City, USA
The University of Kansas Health System, Kansas City, USA

2

Corresponding Author:
Jennifer L. Dill, University of Kansas Medical Center, 3901 Rainbow Blvd,
Mailstop 4047, Kansas City, KS 66160, USA.
Email: jdill@kumc.edu
https://us.sagepub.com/en-us/journals-permissions https://www.doi.org/10.1177/0018578719873870 http://journals.sagepub.com/home/hpx http://www.nationalacademies.org/CannabisHealthEffects
Hospital Pharmacy - February 2020

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