UpDate-CDC Proposed Opiate Guidelines Public Comment Now

Even though the FDA 120 mg Morphine/120 mg Morphine Equivalent Guidelines aren't Law, most Pain Drs are going by it. The CDC Guidelines also it states it is for Primany Care Drs. But, as well all know Pain Management Drs are already going by the FDA Guidelines. The first comment period the public wasn't allowed to comment like this. We rarely get a second chance.

Proposed 2016 Guideline for Prescribing Opioids for Chronic Pain-
www.regulations.gov/#!docketDetail;D=CDC-2015-0112

January 14, 2016-
The workgroup will have a meeting on January 28, 2016, in which they will take public comments. You need to register by January 18, 2016. Info is at the link below

/www.federalregister.gov/articles/2016/01/11/2016-265/board-of-scientific-counselors-national-center-for-injury-prevention-and-control-bsc-ncipc

Post Edited (Mercy&Grace) : 1/14/2016 4:49:44 PM (GMT-7)

Lynnwood, Thanks. I apologize for not posting both.

I just submitted a long reply.
Thank you for providing the links to allow us to comment.

I live in Oregon. The state of Oregon has a state-wide system that tracks prescription narcotics/opiates. Each time I fill a prescription it is tracked and monitored.

I feel apprehensive each time I fill my narcotic/opiate prescription.

I take above the 120 mg morphine equivalent.

Every 6 months, my MD must submit a plan outlining my narcotic/opiate plan of care to my medical insurance provider for review. It is also reviewed by an independent medical review panel of the state of Oregon.

Avascular necrosis (ischemic vascular insufficiency of bone) of my hips and jaw alone qualifies for the increased morphine above the 120 mg guidelines.

But it is unnerving.

I do support the state of Oregon's monitoring system. But sometimes I feel as though I am on the FBI's most wanted list when I have a narcotic/opiate prescription filled.

All and all, I find it a very humbling experience to need a narcotic/opiate on a long-term basis.
- karen -

Submitted my comment. So glad to have had the chance.

I'm hoping that the fact that they opened it again, this time for a real chance for the public to make comments that they will listen. Those that make comments will know that voice is heard, to what extent remains to be seen.

Just wanted everyone to know that there is a universal statement being used by healthcare professionals who are against opiates & they're signing it in droves. We need more signatures! Maybe message it out on Facebook? I know I don't usually do anything like that just for the fact I don't like tipping everyone off that I take pain meds. It's just an idea though. Somehow we need this to stop. The CDC getting involved is ridiculous. Might as well tell my kids daycare or a heating and air conditioning company jumping in with their own thoughts & restrictions on it. Complete foolishness!

Thank you M&G for the extra effort on this one. Just wanted to say I really appreciate your contribution to this site. Your unique perspective and associated postings are very helpful.

If you haven't already, please take a few minutes to add your comment to the attached URL. We need all of you to help advocate for our cause by Jan. 13.

Mercy&Grace:
I, too, want to applaude your efforts in bringing awareness to the importance of making comment to the proposed guidelines.

This is our collective chance to give personal voice to the exacting toll that is a life lived in pain without reprieve. The opportunity to give input like this may not come again.

I posted comment to the site. I do not think any DEA or FDA reviewer could finish the reading of my comments without a profound feeling of humanity and the basic right/need for comfort that should be everyone's.

Chronic, refractory pain has no bias, it does not discriminate on the basis of age, sex, nationality, profession, or hair color. But for the grace of God, chronic pain can affect anyone.

There was a recent article in the New York Times discussing how one of the FDA's principle investigator's who oversees the approval process of drugs for cancer was affected by the death of his own wife by metastatic ovarian cancer. Where he was once hesitant to sign-off on compassion release of new drugs, he is now a strong proponent for fast-tracking clinical trials and release for compassionate treatment.

Maybe if a member of the FDA or DEA advisory committee on the newly issued guidelines for pain was himself/herself an individual affected by chronic pain, the passing of guidelines that address the need for person-specific dosing would be easier. The management of pain is not a one-size-fits all prescriptive. It requires an individual-targeted approach and collaborative physician-patient relationship.

I am keeping my fingers crossed.
- Karen -

(Seashell), Thanks. You made a great point when you brought up about the FDA principal investigator went trhough with his wife and how it changed his prospective. The people that make these lawes and guidelines are not touched by untreated or under treated chronic severe pain. If they were, they would have different views. I have said for a while that I don't think that there are millions and millions of Americans that aren't having their chronic severe pain treated adequately. If there were that many people, other woujld be effected by it. If there were that many people, they would be vocal and visable. I know first hand how chronic severe pain that is untreated and/or untreated can affect a persons ability to go anywhere and do anything. But, if they are on the internet, they can submit a comment.

Alcie, there have been a lot of comments from people that are in favor of these guidelines because they or their family have been touched by addiction. There are also drs and other professionals that are in favor of the guidelines. I have seen a number of people post saying that their drs don't like not being able to treat them like they want to. Where are those drs comments ?

Here's an opinion from a board certified pain physician.

Comment
Sirs and Mesdames, I am a board certified pain physician who feels that opioids have been over prescribed ever since the pharmaceutical companies discovered they can make 10's of Billions of dollars on sale of opioid to chronic patients. OF SIGNIFICANCE is that there is not a shred of long term evidence supporting the use of long term opioid management. In fact, the only study I am aware of (the journal "Pain" (copy of article is attached for your perusal)) indicates patients with chronic pain who are on pain medication actually do significantly worse than those not on opioids.

There are no trials comparing treatment of long term pain with non-opioid management against opioid management. As far as I am aware, there are no trials evaluating the efficacy of long term opioid management for chronic pain longer than 12 weeks, and all of these are compared to placebo (!). So, for instance, we do not know if after 2 years of treatment are people better off if they've been on oxycontin or on acetaminophen. What about maybe just a little bit of amitriptyline?

Yet at the same time, opioid overdose deaths have increased dramatically, the problem of addiction is adding huge costs to society in so many ways - not only the treatment of addiction (Suboxone, methadone, etc) but the auto accidents, lost work, divorce, unemployment - all of which, to my knowledge have not been studied, but certainly should be.

Though it is known that chronic pain patients are more likely to develop opioid addiction than the general public, the true rate of addiction development in patients prescribed for chronic, non-terminal pain is not known and should have been thoroughly studied prior to widespread promulgation of opioid use for non-cancer pain, and it was not.

The only articles about opioid supposedly not being addicting were from Foley and Portnoy in the 1980's and Portnoy has now admitted that he overstated the case, that he was being paid by the drug companies and that his so-called research has led to countless people becoming addicted (Wall Street Journal, Dec 17th 2012).

While some things perhaps do not need to be studies (the efficacy of parachutes for instance) something with as much risk and history of damage to society most certainly should be studied prior to the release of these products to the general public (of course, still under a doctor's supervision, but with little or no training in the risks and benefits other than the literature produced by or at the direction of the pharmaceutical companies). There are now approximately 80 drug overdose deaths per day in the USA making the death toll greater that that from automobile accidents.

The CDC is supposed to be part of the public watch dog group that protects the public. The appropriate thing to do is to certainly recommend that opioids be under tight control IF they are used at all to treat chronic pain.

The resistance to recommendations of tight control are coming at the expense of the public health and at the behest of drug companies who don't wish their profits to decline by more appropriate prescription guidelines and from unfortunate patient groups who may already have addiction and don't want to see their supply decline.

It just seems that nobody knows anything, so now the finger pointing begins. If you walk up to a bunch of toddlers and ask who broke the vase, they will all start pointing to each other. Meanwhile, the vase is lying there broken, and nobody wants to be the one to fix it.

There're quite a few Drs making comments. I basically scrolled thru the TON of comments, and clicked on ones that I could tell were by a Dr.

Something needs to be decided NOW. This limbo stuff is what's driving both patients, and dedicated pain docs crazy. I wonder how many of these comments will be actually read-maybe this is more a PR stunt.

Sorry if I come across as bitter.

Maybe instead of fighting this battle, maybe the battle to fight is the one that will eliminate the problem in the first place-like buying a new vase.

M&G, I have the same thoughts you have on this. If someone does read this & I seriously doubt that will happen, it will be read by someone that has no clout whatsoever. In other words that person's opinion is not one that is important to anyone.

This is a good example of how they never get their numbers right on deaths as a result of prescription medications. If you read through those comments there is a ton of comments of how someone died from using heroin after being on a pain med. What we don't know is were they using heroin before the script, some even stated they got 1 script from ER or a dr & this is how it all started. Easier to blame the medical community than to admit their kid had a big drug problem. So, once again they are chasing the rabbit down that hole.