April 1, 2022
****YOUR COMMENT WILL MAKE A DIFFERENCE****
BACKGROUND OF THE CDC GUIDELINES:
On February 10, 2022 the CDC published a draft of their
updated/expanded Opioid Guidelines. Read our
July and
February newsletters for an in depth explanation of the 2016 Guidelines, and the all-day meeting CDC held in July to discuss their original draft for the updated/expanded guidelines.
WHERE TO COMMENT:
WHY COMMENT:
- We can't express strongly enough how important it is that you comment. Every single person who has been devastated by these Guidelines needs to post a comment.
- We also suggest that you send a copy of your comments to your local legislators. They need to hear from their constituents about how devastating the 2016 Guidelines have been and how your lives have been harmed.
- CDC will review ALL comments, and based on what they see will update the draft accordingly. The new draft will come out by the end of 2022 and will replace the 2016 Guidelines.
WHAT TO SAY IN YOUR COMMENT:
In case you would like some suggestions on what to say in your comments, here are some ideas:
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Remove ALL mention of MME (Milligrams of Morphine Equivalent) including in the supporting text.
- Not only is there not a standard way to count MME, the hard thresholds mentioned in the 2016 Guidelines of 50 and 90 MME have caused great harm both to doctors and patients. We wrote all the details about the issues with MME in our Debunking Lies section on our website. Although CDC did remove MME thresholds from the main Guidelines, they still are mentioned many times throughout the supporting text.
- Remove ALL mention of limit of days for prescription for acute pain including in the supporting text.
- Although they removed mention of 3, 5, or 7 day limits in the actual Guidelines, the supporting text still has "a few days" and "7 days" mentioned. This needs to be removed.
- Fund and execute a plan for how to de-implement the 2016 CDC Guidelines.
- Although CDC claims these were "just guidelines" arbitrary limits such as MME limits and 3,5, or 7 day limits are an issue because:
- Many state laws have been created based on them.
- They are worked into EHR (Electronic Health Records).
- Risk score algorithms such as NarxCare use them.
- CDC funded an extensive implementation plan for them.
- DEA also uses risk scores to flag doctors who "prescribe outside of the CDC Guidelines."
- The Guidelines need to be redacted and redone due to bias and conflicts of interest (COI's).
- Read about the lack of transparency and COI's.
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Dr. Roger Chou was involved in every aspect of the CDC Guidelines and has COI's.
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PROP members who were being paid by law firms involved in opioid litigation were involved with the Guidelines.
- Pain is not one condition and they need to mention there are MANY very painful conditions that might require opioids.
- Exclusions didn't work in 2016 and won't work now.
- They excluded "cancer pain" in 2016 Guidelines yet cancer patients have been affected.
- They added Sickle Cell Disease as an exclusion in these Guidelines (which is good since SCD patients have been horribly affected by the 2016 Guideline), but they also need to mention there are many painful diseases and conditions. Just saying "palliative care" patients are exempt won't help anyone. It didn't help in the 2016 Guidelines.
- There is no scientific basis for the distinction of cancer and non-cancer pain.
- Mentioning some conditions and not others leads to a lack of individualized care.
***ALL CPP'S CAN HELP BY:***
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Commenting: You have until April 11, 2022 to post your comment. Please do this and ask family and friends to do the same.
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Donating: Your donations allow us to pay for lobbyists and continue to dedicate our time to get this information out to you! Every dollar helps us to educate, legislate, and advocate.
