On Friday, December 14, 2015, the Centers for Disease Control and Prevention (CDC) opened up the public comment period on its controversial Proposed 2016 Guideline for Prescribing Opioids for Chronic Pain.
16 days into the comment period, there have been over 1200 comments. That sounds like a good number until you realize it’s only 0.00001% of the estimated number of American adults who suffer in chronic pain.
We don’t know what CDC will do with the comments or how it will digest and draw conclusions from them. Will the comments really make any difference? One can hope that the comments will get the CDC thinking that the use of opioids is not solely an addiction issue, it is also a chronic pain treatment issue.
What is the public saying so far?
We asked Terri Lewis, Ph.D., who is an expert on health policy particularly as it applies to chronic pain, if she sees any themes in the comments thus far. Here’s what she had to say after reviewing the comments thus far.
“Here and there are commenters who would prefer to tell the CDC how to address this process properly in order to derive a balanced approach.”
“I am struck that few commenters have addressed physician education, system issues, insurance roles, workman’s compensation screw ups, or factors associated with other intangibles like the influence of a sicker, aging population and polypharmacy.”
Dr. Lewis provided a cursory overview of the primary trends she observed in the comments. They are as follows, and do not reflect any percentage weight.
- No, hell no. Opioids are bad because…they killed my….
- I am a professional and I am sick of dealing with people abusing the system - go CDC!!
- I am a professional and I am glad to see the CDC putting in place guidance so I have a mechanism for refusing to dispense.
- I am a professional and I believe these guidelines go too far.
- I am a professional who didn’t understand the problem until I was injured and now I understand what it is like to be treated like an addict.
- I am a recovered addict who got started down the road of heroin(e) [sic] when I …..
- I am a person with chronic pain who relies on these medications and I have been harmed enough already. Please don’t take away the little quality of life I have remaining.
- I am a person with chronic pain who is successfully working with my physician team around a sensible prescribing routine that is working for me - leave it alone.
What are some possible reasons why the number of comments are so low?
“Persons with chronic pain are doing the very best to get through the day,” she said. “It may take them more than the usual amount of time to formulate their thoughts about these issues. Many will not be able to respond without assistance.”
“I do see a few responses from care partners of persons who have chronic pain - but not nearly enough. They have an important story to tell and we need to encourage them to tell it.”
“What is clear, is that for many of these respondents, opioids are working well, but we don’t know enough about that - primarily due to lack of research methodology. For those who were harmed, the comments provide support that a host of factors were involved - from poor patient selection, wrong prescribing, over prescribing, the characteristics and beliefs of the user, lack of patient-physician engagement, and so forth. For both of these very reasons, I maintain that treatment must be based on the needs of the person and not the population. Treatment for chronic pain requires an alliance between deft physicians and educated responsible patients, no matter the methodology because not all paths lead to Rome. Each patient is unique, every injury is unique, and every dose-response to treatment is unique. Overgeneralization leads us to accidents and injuries due to faulty assumptions.”
“Reducing supply lines for prescription opioids or supply side economics will not address the problems associated with poor patient selection, wrong prescribing, over prescribing, the characteristics and beliefs of the user, lack of patient-physician engagement, and so forth. It will mean that persons who will benefit will have to endure far more of a burdensome misaligned set of processes.”
There are just over two weeks left before regulations.gov, will no longer accept comments (deadline January 13, 2016, at 11:59 PM ET).
If you are wondering the best way to respond, here’s an article that Dr. Lewis wrote for the National Pain Report with some smart advice about how to comment effectively.