What I Told the DEA

What I Told the DEA

(The Drug Enforcement Administration is taking comments on its Proposed Aggregate Production Quotas for Schedule I and II Controlled Substances. One of our contributors, Jeff Edney filed his comments on Saturday September 21st here.)

A DEA document states: “As a result of considering the extent of diversion, DEA notes that the quantity of FDA-approved drug products that correlate to diverted controlled substances in 2018 represents LESS THAN ONE PERCENT of the total quantity of controlled substances distributed to retail purchasers.”

The US population grew by 0.6% in the last year, so assuming your specified maximum 1% diversion – 0.6% growth = 0.4% max you should be reducing less than 0.5% or none at all, not 10%. Further, there are national shortages of analgesics and this will only make matters worse, discouraging people to undergo elective surgeries and wind up on social security disability instead. People are committing suicide every day.

What we need is an increase in analgesics to reduce suicides including many veterans who just cannot take the pain anymore, and stop driving law-abiding citizens to resort to illicit street drugs, further exacerbating the fatalities from overdoses. Prescriptions have declined 35% nationally since 2012. What is the correlated reduction in overdoses? Have they decline 35% with prescriptions? We don’t see that in the public domain data. Overdoses are up nationally. Isn’t that a hint that mandated quota reductions are fundamentally misguided? Production quotas force honest law-abiding citizens to seek pain relief from Mexican cartels than from qualified MDs or DOs who actually know how to prescribe FDA approved analgesics.

Jeff Edney

Please target the real problem – illicit fentanyl (carfentanyl and others), heroin, meth, and cocaine, and do not reduce the pain medications that our wounded veterans, hospice patients, cancer patients, people with severe health conditions, and surgical patients.

The reduction in opioid production also violates the CDC guidelines that started this process as noted in the Alford letter of 10 April 2019: “The guideline does not endorse mandated or abrupt dose reduction or discontinuation, as these actions can result in patient harm. The Guideline includes recommendations for clinicians to work with patients only when patient harm outweighs patient benefit from opioid therapy. The guideline on high dose prescribing focuses on initiation.”

No correlation exists between opioid prescribing and fatalities. Cutting back on prescriptions is counter-productive and sheriffs from multiple states report it is driving seniors and those with chronic health conditions to resort to street drugs, further compounding the problem, so the knee jerk reaction is to tighten limits even more, and further perpetuate the overdose problem. If the rationale is that kids get addicted from prescriptions after wisdom tooth surgery, then address that problem, but don’t take opioids away from hospice patients, cancer victims, and the disabled who suffer genetic disease such as autoimmune disorders.

Per this article, if accurate, we had 47,600 Opioid deaths in 2017 of which 28,400 were due to Fentanyl (mostly illicit by the description in this article and 15,482 deaths from heroin, so 47600-28400-15482 = 3,718 deaths from prescription opioids. Compare 3.718 deaths from prescription = 7.8% of all of the total opioid deaths, while mostly illicit fentanyl plus heroin account for 92.2%. In fact, I posit that if the 3,718 deaths from prescriptions which includes both intentional overdoses (suicide) and stolen drugs are magically reduced to 0, the net total deaths will be much higher than 47,600 due to forcing law-abiding patients with severe health conditions to resort to the much more dangerous street drugs. Assume this ration of 92.2/7.8 = 11.82 relative hazard ratio x 3718 = 43,949 + 28,400 + 15.482 = 87,831 deaths. So instead of a best-case scenario reduction of 7.8%, we wind up with a net increase of +85% increase in fatalities.

Production quotas limits will ultimately increase overdose fatalities, which is exactly what we are seeing both at national and state levels. While prescriptions have fallen 35% nationwide, overdose deaths have soared higher. This article below seems to suggest why this is true. Hopefully, the magnitude of the increase in overdose fatalities would be less than the hazard ratio indicates, but there is little doubt the sign would be different (a net increase no matter how large is a bad outcome borne of unintended consequences). For example, not everyone would resort to street drugs (ideally none but that isn’t realistic).

Please have a heart for the most unfortunate members of our society and revisit this recommendation. Hospice patients, cancer patients, post-op surgical patients, wounded veterans, nursing home residents, and disabled people protected by ADA and those with serious health conditions need these medicines you want to take 10% away from.

Jeff Edney is a member of the Alliance for the Treatment of Intractable Pain. Jeff is a former Director of Engineering (disabled), chronic pain victim & advocate and is married with pre-med son.

(If you want to comment to the DEA, you can go here.https://www.regulations.gov/comment?D=DEA-2019-0008-0001&p=1)

Let us know if you plan to comment and what you think of Jeff’s approach.

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Authored by: Jeff Edney

Jeff Edney is a member of the Alliance for the Treatment of Intractable Pain. Jeff is a former Director of Engineering (disabled), chronic pain victim & advocate and is married with pre-med son.

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Anastasia

I just want my medication returned to me. (The pre forced taper dosages, to be specific.) I was functioning. Food shopping, cooking for my family, feeling as if I was a ‘normal’ person. Now, with 80% of my medication removed, I am a nothing. A burden to my family. I wish for my pain to end in a permanent manner, but must remain for family members. I need my medication back – this is inhumane.

Barbara W

Thank you Jeff your calculations & letter is so perfect! If they are not motivated by money or corruption this could actually work. I’m sure all have heard of the corrupted ASSET FORFEITURE they perform .LAW ENFORCMENT AGAINST PROHIBITION (LEAP) HAVE WARNED US 200K MEMBERS whistleblowers from Narcotic agents DEA CIA FBI judges prosecutors ! they. go all over the world to get everyone to legalize & save lives tell the DEA to stay out of the Doctors offices. they r comprized of retired & active members of all branches of the criminal justice system against what they r doing.
Current DEA Kick backs & selling confiscated Opiods on the black market. If we could think of a way they would profit more by doing the right thing that would be good. The US can definitely tax the drugs like in other countries that have legalized. I am definitely making a statement to them as well of how harmful more cuts to our Medicine is!! They need to stop harassing our physicians constantly & trying to pin a 10 yr old death by some dirty abuser on them . Arrest all the for profit Rehabs getting dirty grant money like PROP did expose Koldny. No one would need to buy from mail order anymore. I’m telling them how all the Alchhol 88000 deaths yesrly but legal & they have broken at least 10 national & international laws of human rights. So just don’t listen to the rouge DOJ anymore & be the good guys that joined so they could protect us instead. I’m sure everyone of them has someone who is in pain too!!

Chrystal Augustuniak

No way in hell will they admit ill doings. I also believe this is being done on purpose, government has been after social security money but can’t really take it as long as people need it and use it, so what is the answer?…attack them.. that’s what this is an attack on innocent people. My question though is where in the bloody hell are the families of pain patients?, why do they only speak out when a pain patient dies and even then when they speak out ….it’s negative…don’t mention they are a pain patient struggling in life no they call them addicts. Families have a huge part to play in pain patients lives and not being here for them is helping that person commit suicide. Why aren’t more families fighting for pain patients? The more they stay silent the worse this is gonna get. By no means am I letting our government off the hook, by lying and feeding false numbers to pain patients families only feeds the doubt of family members. I will keep saying this subject does not anger anyone and that’s why we are being attacked. The blood of fallen pain patients is on everyone’s hands not willing to help them pain patients. I’m actually tired of fighting for proper pain management when I want to be cured, but I will keep fighting regardless for both ….

Judy

Thank you Jeff for advocating for all of us. I left my opinion on the DEA page. I just hope and pray that they’ll eventually wake up and realize the harm they are causing.

Valerie Monda

As a chronic pain patient who just endured a third spinal fusion, I applaud your well written article. This third fusion was extremely difficult as my pain was not well managed in the hospital. I was very honest with all medical staff pertaining to this surgery, and explained that I was a chronic pain patient and was taking medication to control my pain. I believe I was treated as a drug addict, and was not given adequate medication after the surgery. I have taken pain medication responsibly for the last eight years and have never had any problems. I hope article’s such as yours will open the eye’s of the DEA and all involved, and will put an end to the needless suffering that has become the norm in our society.

Niese Cramphorn

Jeff, with your permission I am sending this to my elected officials and the morons that run the state of Oregon medical authority. They choose NOT to follow the CDC’s amendments but only the original document of 2016. For the last 3years they have been trying to come up with their own rules and in the meantime require Oregon pain specialists to reduce all medications to some abstract number that has something to do with of all things my ZIP CODE! I wish this upon them. This pain was not of my own doing. It was because the state and the FDA were not doing their jobs. They allowed a product that was known to be a bad to be implanted into my body at state of the art!! Dupont would not make the implant themselves as they knew it was bad but they sure as hell sold the Teflon that is now in my body creating havoc.

Somehow this mess needs to be straightened out nationally and keep the states from punishing patients randomly. I have been on Fentanyl for over 35 years and have yet to overdose. It is the crooks, junkies, addicts that need to be sought out not those like me.

Does anyone actually believe that out of ALL the politicians, DEA, etc. that these people do not have a family member or themselves are not a chronic pain patient? REALLY.
Do you think they are suffering? I believe it is far more realistic that they are in bed with the drug dealers making LOTS of $$$… they wont admit their numbers were lies so if they cant beat them….they joined them!

Bruce

Yeah, but what was the response? It’s a cult of death. It’s all on purpose. The mere fact that you attempt to use logic on them shows that you’re not getting it. This is what they want, depopulation. Apparently this movement is in full force because now they can replace HEALTHY people with robotics. We are useless eaters to them. Maybe respond with lawsuits? It has to be something tangible that transfers PAIN to them. It’s the new world order, globalist nihilism that wants us GONE. Get rid of the super rich who are running the show and then you’ll solve the problem. But it’s a good article from an academic perspective. But that’s it. Cheers

Louis Ogden

Thank you for the info, Jeff.

Mist

I made sure to share my story and 2 Vets who have taken their lives and vet that I know untreated bone cancer at end of life family threatened the doctor and the unnecessary suicides

Cynthia

Wonderful article, Jeff! Thank you for speaking truth to power. Can you send this to President Trump and AG Wm. Barr?

Chris jolley

Absolutely I will comment. I hope to motivate others and will post in the groups I’m in. Thank you for posting this. Thank you for writing this, the information and stats are spot on.

Connie

Now if they’d actually listen and act accordingly!! I don’t understand their game plan but it’s obviously not to reduce opioid addiction and overdose!!

Janna Crickmore

Left a comment. Told them to quit demonizing those of us under a doctors care and quit targeting responsible physicians and go after the illicit and illegal street drugs which everyone knows is the real problem

Bravo! Excellent and very well said Jeff! Thank you!

Janice

I left my own comments on the site. I like Jeff’s approach as using more statistics and advocating for everyone. Mine is of my experience only. I don’t know the stats or details like Jeff does and I don’t have the energy to research it. So I thank you Jeff, for your time and research on the subject. Made sense to me.

Katie

Thank you for writing this. I’ve seen so many people in my pain support group turn to illegal drugs after doctors decided to stop their prescription due to the CDC’s change in guidelines. I personally lost my job and had no choice but to go on SSDI after I could no longer find a doctor to prescribe pain medication for my arthritis and neuropathy. Living in constant uncontrollable pain is not a life I want to keep living and will keep fighting until something changes.

Thomas Kidd

Thank you very much for your well worded letter to the DEA. I appreciate it.

Janice

Very succinct and well said. But when has being “rational” got us anywhere? I applaud your efforts and hope the DEA will finally get the message that more people are being harmed than the government is protecting by these draconian measures.

Sandy

These kinds of articles make really great bed time reading. You go right to sleep having nightmares.

Michael Swift

WONDERFULLY composed Jeff, a special thanks to you, your efforts and determination to put out the REAL facts and shove it right back in the faces of an agency hell-bent on flexing their “Napoleonic” muscles.

Cindy

ps –
Jeff, thanks for letting us know about this DEA proposal.
I just submitted my comments, via the link you provided.

I absolutely love you did the math. Excellent excellent article! I pray to God that someone with common sense instead of moncho ism have a heart & read your article & act on it & stop all this cutting medication bc I for one do not have any, have been cut off due to the pharmacy mistakes that I got red flagged , even though it was their mistakes & I got it corrected I’m suffering from some dumb controlled substance database that the pharmacy can’t even do correctly. I don’t know how much longer I can take it. I’m supposed to have 2 other surgeries which I’m not going to have bc of suffering after surgery & was told to use CBD oil/ ice the area as I cannot take NSAIDs due to ulcers / gastritis. CBD although it’s not even regulated. I had a nerve injury caused from surgery & I cannot reach the area w/ice. I’m left crying half the year now waiting for it to heal ,if it even does. Along with the other intractable pain issues that I suffer from. DEA is killing me! I will contact DEA.

Stephen Abbey

Is it ever going to end?. Everyone knows the facts. Just give the people there deserved pain meds back to them. The records will show who is taken them responsibly. I was doing so good before the crisis. Now I feel like I’m useless compared to before. I have so much work to do around my house just so I can make my 89 yr old mother happy and so maybe she can sell and retire to a smaller place to live out her rmander years. I am so tired of reading about the same old reports over and over. The pain meds work just fine if the people can get what they need just as before. What are we waiting for ?.

HOWARD

PAIN MEDS, are being taken to just get HIGH !!!! IAM A DISABLED VETERAN, AND ALL THESE PEOPLE ABUSEING PAIN MEDS MAKE IT BAD ON ME. I HAVE HAD TWO FAILED BACK SURGERIES ONE A FUSION, BRAIN SURGERY, I DON’T APPRECIATE PEOPLE ABUSING PAIN MEDS I HAVE TO TAKE AND I DON’T APPRECIATE IT AT ALL.

Matthew Berkowitz

we need to start making The FDA in the CDC and any other government agency accountable for the collateral damage caused by this [edit] opiate epidemic. People in chronic pain are committing suicide I will not be murdered by my government I never put myself on pain meds why am I being punished

Debbie Nickels Heck, MD

I have asked the AAPS to make pain management a focus of theirs in the upcoming year. I hope to work with them on a way they can be part of the solution as a group as I’ve seen OTHER physician organizations abandoned pain patients and focus on addiction which has done nothing positive for those in pain. Yes, the 7% with a propensity for addiction deserve treatment but NOT at the expense of the 93% who at some point will have some type of pain needing opioids.

Exstepper

Very articulate response to DEA with facts and statistics (that I was completely unaware of). I’m grateful to people like you who rely on research and reaching out for people like me. Thank you so much for your contribution on our behalf.

Danny

What an outstanding comment. Thank you, Jeff Edny.

Rosalind Rivera

Excellent review and informational LY study of the actual causes of the soaring and needless deaths of people suffering debilitating pain, their terrible but very necessary reasons for seeking illicit drugs and the very sad outcomes. It is clearly descriptive of the fatal errors that the CDC and others are committing without thought of real numbers and very real patient suffering. As a chronic and intractable pain sufferers I too am suffering due to the victimizing and homicidal statues put in place by the powers that be. When will this situation finally change, if it ever does?

Cindy

Jeff – Why is cancer pain treated differently than other pain?

You wrote:

” If the rationale is that kids get addicted from prescriptions after wisdom tooth surgery, then address that problem, but don’t take opioids away from hospice patients, cancer victims, and the disabled who suffer genetic disease such as autoimmune disorders.”

I’ve had Pelvic Pain Syndrome for almost 11 years. No treatment has helped, leaving me with opioids which help to differing degrees on different days and parts of days. I spent yesterday in absolute agony, and so far, today is no different.

Why is my pain and the pain of others with horrible agony not caused by cancer, less important than a cancer patient’s? Not just to you, but to countless people who are leaders in the pain community.

Terry Ott

That is just a terrific statement, Jeff, summing up things perfectly. Thank you for sending it.

Vincent

Excellent!

Joan

Thank you, Mr. Jeff

Pamela Townsend

Thank you for courageous fight for us law abiding, citizens who actually do receive pain relief from opioids. You are appreciated beyond words.

Mark Ibsen MD

My comment: Reducing opiate production places pain management in the hands of criminals.

Mickie

I did comment.I liked his approach because he used the numbers to tell the truth.The DEA used numbers to manufacture a problem that doesn’t exist.There is an illict drug problem but not one with patients and doctors.I feel he clearly got that point across with real data

Gail Honadle

In light of a new batch off BP meds and generic Zantac being with drawn for a agent that comes from China, why is the FDA not checking ALL generics. Nancy Pelosi says she wants to lower the cost of health care, how can you do that if you place a 95% Tax on every prescription. We are Seniors thus take several medications each. Only 2 of mine are name brand. None of my husband’s are and 3 of them are heart related, 1 BP, 2 Cholesterol. The Medically Educated doctors including his Ophthalmologist failed to warn him he couldn’t take Prednisone, Cortisone, or Steroids, along with a host of medications used to treat Bronchitis or Pneumonia as he has Severe Glaucoma. The Glaucoma Specialist had to inform him of that. Me, medial failed to tell me not to consume Soy, English Walnuts, or any member of the Broccoli family as I’m hypothyroid. Just to stay away for Grapefruit. We patients seem to do better research than our doctors do.

You are a Doctor, you’ve told me NOT to take any OTC pain meds for various reasons, now you are telling me to take them, Not Logical. Tylenol is a 10 day med, excess destroys the liver. All the rest destroy GI Tracts, kidney’s and heart all of them are blood thinners, thus not usable post surgery. I’d like to keep what is left of my Kidney, Heart, and Gastro tract functions with out surgeries I’d not need. I did quite fine on 5 mg NORCO for 5 yrs, 3 times a day. Now I’m home bound and have difficulty getting up to go to the bathroom or fix a meal. Box meals are not healthy, you told me so. All you’ve done is contradict yourselves. Either stand up for us or get out of the Practice of Medicine. You are more worried about your Bank account than me as a patient.

Congress Needs an Opioid Intervention https://reason.com/2018/10/18/congress-needs-an-opioid-inter?fbclid=IwAR1LIoyLML_INN8787VKhaINzpPFf7NlJhz9t6O4yqGNVJxF-31sGOq-GSw

Michael Kastner

Jeff. Thanks for speaking up for us and the wonderful report you wrote here. Very factual and so correct in who’s dying from ODs and why. The numbers do not lie. We Chronically ill, we ADA folks, Veterans and so many others are indeed suffering needlessly and cruelly. Those in power have created, as the man in the White House calls it, Fake News, trying to make the public believe other than the truth. The drugs from China, illegal as they are, enter our country and are widespread and on every corner now. That’s what’s killing so many.
Proper administration of an Opiate regime is fair and proper when prescribed by a physician and used as prescribed. I understand the dependency issue, it’s inborn in the medication and therefore patients who are serious about trying to get as much pain free or less pain days must try other modalities along with the Opiates. But for some, including me, they are the only thing that even takes the edge off and allows a little bit hope. It allows us to crawl out of bed and have a little bit of life.
I wish pain on no one. But think if those in power had the sort of pain we often have, for just one day, this wouldn’t even be a discussion. “They” couldn’t take it. Period.
Again thank you Jeff.
Regards,
Michael Kastner

Heather

Thank you. Excellent comments!

More comments! Just what we need.

Monica

Thank you! I also commented on the link. I hope everyone in pain does so!

Lori T.

Great post Jeff! I could not have said it better. I just wish that the DEA and other powers that be, would get a brain. This whole reduction in manufacturing opioids is totally ludicrous. As Jeff has pointed out oh so clearly there have been reductions across the board in opioids prescribed to patients, manufacturing quotas, etc. but the deaths continue to skyrocket. I have seen senior citizens in my rural area purchasing drugs from the local street dealers or the online black market end up dead. They don’t have a clue of what they are buying or how to dose. Those that did ended up dead because the heroin was cut with fentanyl. This opioid issue is a mess. I personally think that the government wants those who are disabled, veterans and people trying to live another dang day with cancer…DEAD. It’s all about the money and it’s really heartbreaking. I am hoping for some commonsense corrections to this mess ASAP. What has our society come to? In my opinion, HEARTLESS. We as pain warriors must do any and everything in our power to speak out on this issue before one more person dies or takes their life because of these draconian laws are being put into place for good. Once this happens, these laws will be almost impossible to reverse. We need a leader to head the charge in this matter who is not currently suffering and the rest of us must fall into line in helping this leader with this most important task.
This is a life or death issue for the majority of us who are suffering chronic, unrelenting pain. Heck, we do better for our pets than humankind. Do we have a leader out there willing to take this on? So far I am hearing crickets…

Jody Hoffman

The DEA has been losing the war on drugs ever since it began they have never stopped or even slowed down the illegal drugs coming into the country or what is manufactured or grown here. Now marijuana is being legalized in many states & the DEA wants to keep their jobs and the billions of dollars they are given every year not to mention the millions of dollars in seizure and forfiets. They are trying to prove to the general public that they are doing something but they don’t know that the public is not as gullible as before

For what it’s worth; yes I agree to yet “another survey.” The only thing I don’t like that Mr. Edny states is that now we are going to simply obtain our medicine from the streets. Yes later he remarks this won’t be the case for all. This most certainly isn’t the case for me as of plenty of others on here in whom I’ve read their horror stories and their thoughts of suicide. To me this just ads more fuel to the fire. We’re talking about a group of chronic pain patients that weren’t too well-off to begin with three years ago. Fast forward to today I can just see us running out to purchase street drugs. More like rolling in our wheelchairs and with what do we have to buy them? We’re talking about people that can no longer work, go to church, take care of their homes, get to the grocery, alot of chronic pain patients have been rendered all alone and can’t even take care of themselves. Someone please tell me just how we’re going to take every bit of energy we have and every penny we can scrape together to obtain street drugs?! I’m sorry but I don’t think so! Once and for all, please leave us out of their so called crisis. We know we’re not to blame and I firmly believe they do as well.

Cindy R

Very well written, thank you! I forwarded it to my PainDoc, who was recently suspended for “overprescribing”. He said they indicated they want all patients at 90 MG or less.

Thank you for the statistics on overdoses, especially. I just wish we had verifiable numbers on suicides due to abrupt tapers or withdrawal of pain meds.

Rakel

Well said. Can you add the statistics for number of. MIs (Heart Attacks) and strokes from undertreated pain suffered by those who have been force tapered or just had their opioids stopped? This is a class action lawsuit if anyone is able to organise it. In the UK the addiction rate for Chronic Pain Patients taking prescribed opioids is 0.03%. There is no evidence that long term opioids don’t work as doing a study would be unethical (you would have to give high dose opioids to opioid naive persons) so it has never been done.

Hayden

Well said Jeff but, unfortunately DEA is now in the “pain management” business, NOT in the illicit drug enforcement business which IS what the agency is “supposed” to be doing. Pain and suffering to legit pain management patients means….nothing to them! In fact incentives, have been reported for the agency to take down the “low hanging fruit”. SHAMEFUL! I am up early today (as usual because of inability to sleep) and should be preparing to go to my house of worship but instead, I will stay in my home and watch “television” to get my weekly inspiration.

Pamela Osburn

I live with cronic pain.Sudo Gout in all joints Osteoarthritis in multable joints scoliosis. Fibromyalgia on top of all I go to a pain clinic who has cut me to nothing .mabey enough to get up shower.think about something to eat by then my wrists are throbbing and i no longer can cut food to eat .then for the remander if the day i lie in bed waiting for the next day.Im really at a point I think its best not to live anymore .they have taken my medacation away so much that i barly get through a morning . Its not me that caused this crisis. Its bad drugs comming into our contry.They never even considered cronic pain patients. The Drs are scared to help anyone anymore .life will end for me and many others perhaps the Goverment wants to cut down on population. Because the way i see it .suicide rate will be very high soon from cronic pain patients.