|CMS to make CDC "Opioid Guidelines" policy|
MARCH 3, 2017
As stated in my article Count Down 2016 – CDC Opioid Prescribing Guidelines and Chronic Pain, there are drastic differences between a policy and a guideline. Is the CDC acting in good faith? Why are the Centers for Medicare and Medicaid Services (CMS) morphing a guideline into a policy, potentially putting millions of taxpayers in harm’s way? They have not been properly represented. Is CMS aware that the CDC did NOT consult with all stakeholders or do an in-depth literature review or follow any of the other policy procedures set by our government? My biggest fear is that the CMS is basing their decisions as though the CDC guidelines are already a policy. They are assuming the statistics they received are unbiased. See Why should we hold the CDC accountable?
The following is an excerpt of an article written by Rick Martin, Guest Columnist for Pain News Network. You can find his letter here. Please comment to the Center for Medicare and Medicare Services.
Change takes work if the pain community is going to stop the Centers for Medicare and Medicaid Services (CMS) from making the CDC’s opioid prescribing guidelines mandatory for millions of Medicare patients, including a ban on daily doses higher than 90 mg morphine equivalent (see “Medicare Planning to Adopt CDC Opioid Guidelines”).
We don’t need CMS and the insurance industry dictating what medication a physician can prescribe for pain or the appropriate amount of medication needed (see"Insurers Behind Medicare's 'Big Brother' Opioid Policy").
Rick asks that we share with at least 10 people and ask them to share with ten more. I decided to share my letter with everyone in my social networks via this blog. Surely, ten of my many friends will keep the ball rolling. Rick gives his permission to use his letter, and you are certainly welcome to use mine.
CMS at this email address: AdvanceNotice2018@cms.hhs.gov
Subject line: CMS Disregard for Governmental Standards in Policy and Procedure-Putting Patients in Harm's Way
To Whom It May Concern:
Let the record show that I, Celeste Cooper, oppose the Centers for Medicare and Medicaid Services’ plan to align its policies with the CDC Guideline for Prescribing Opioids for Chronic Pain. The “Guidelines” did not go through the required process for policy development, and many feel they are biased. We as citizens, taxpayers, and people living with chronic pain were not represented fairly, nor was ALL the literature reviewed or processes followed that were put in place to protect consumers from the consequences of prejudice.
“Guidelines” give physicians and other licensed prescribers the discretion in determining what is right for their patients. However, your policy as presently drafted will make the guidelines mandatory for doctors, patients, and pharmacists. And, what are the provisions for end-of-life and cancer pain?
On June 1, 2016, Dr. Debra Houry, Director of the CDC’s National Center for Injury Prevention and Control, wrote the following:
“The Guideline is a set of voluntary recommendations intended to guide primary care providers as they work in consultation with their patients to address chronic pain. Specifically, the Guideline includes a recommendation to taper or reduce dosage only when patient harm outweighs patient benefit of opioid therapy. The Guideline is not a rule, regulation, or law. It is not intended to deny access to opioid pain medication as an option for pain management. It is not intended to take away physician discretion and decision-making.”
Why would the Centers for Medicare and Medicaid Services (CMS) try to adopt a guideline as a policy? This has the potential to put millions of taxpayers in harm’s way, because they have not been properly represented.
Advocates have shared their concerns over favoritism in the drafting the CDC Opioid Prescribing Guidelines of favoritism in drafting the CDC Opioid Prescribing Guidelines. (See links to reports below.) My biggest fear is that you, the CMS, are basing your decisions as though the CDC guidelines are already a policy that has met the standards of law. You are assuming the statistics reported in the CDC Opioid Prescribing Guidelines are unbiased.
Can you in good conscience implement a guideline as policy when it has not met the test set forth by our government, for and by the people?
Celeste Cooper, RN, advocate, Medicare person living with chronic pain
American Academy of Pain Management Statement to the CDC on the Opioid Prescribing Guidelines
Richard Martin, RPh, U.S. Department of Health and Human Services, June 1, 2016 pdf
https://static1.squarespace.com/static/54d50ceee4b05797b34869cf/t/578e661603596e40a74db59e/1468950040230/Houry+letter.pdf (accessed thru Pain Network News, CDC: Opioid Guidelines 'Not a Rule, Regulation or Law'
A Former Federal Peer Reviewer’s Analysis of the Draft CDC Guidelines, National Pain Report
Congress Investigating CDC’s Opioid Guidelines by Pain Network News
Shared at the Addiction Treatment Forum
Congress Investigating CDC’s Opioid Guidelines
U.S. Pain Foundation: email@example.com
National Fibromyalgia and Chronic Pain Association firstname.lastname@example.org
American Chronic Pain Association: email@example.com
Alliance for Balanced Pain Management: firstname.lastname@example.org
I also sent a copy to my senators and legislator., which had to be done on their contact form.
Find your senator https://www.senate.gov/
Find your legislator http://www.house.gov/representatives/find/
More links can be found on my website via http://www.celestecooper.com/advocate.html
"Adversity is only an obstacle if we fail to see opportunity."
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Celeste Cooper, RN
Celeste’s Website: http://CelesteCooper.com
Learn more about Celeste’s books at her website or find links here on Celeste's blog. Subscribe to posts by using the information in the upper right hand corner or use the share buttons to share with others.