In the Wall Street Journal last week, I had a letter to the editor published regarding Bittner v. United States. As Travis Nix and Tyler Martinez explained in the article I had responded to:

Alexandru Bittner, a Romanian-American dual citizen, [mistakenly] failed to file five foreign bank account reports, or FBARs, with the IRS while living in Romania between 2007 and 2011. Taxpayers fill out annual FBAR forms if they have “foreign financial accounts exceeding $10,000.” When Mr. Bittner moved back to the U.S., he discovered this responsibility and had his certified public accountant file these forms to the IRS. The IRS responded by imposing a $2.72 million penalty even though there were no allegations of tax fraud or any additional taxes owed.

What the Supreme Court decides to do is yet to be seen, but Congress should also be taking notice. Americans across the country, and across the world, are recognizing now more than ever how the Bank Secrecy Act regime (the regime responsible for FBARs, suspicious activity reports (SARs), and currency transaction reports (CTRs)) treats citizens as suspicious until proven innocent. More so, Americans are recognizing just how dismal financial privacy is in the United States.

It’s time for a change.

For those interested in learning more, here are a few resources regarding the Bank Secrecy Act and how Americans have their financial activity surveilled:

• Revising the Bank Secrecy Act to Protect Privacy and Deter Criminals
• Treasury and DOJ Seek Greater Financial Surveillance around Cryptocurrency
• How Inflation Erodes Financial Privacy

Ever since the first nurse practitioner (NP) was created in 1965, a debate has raged between the medical profession and the advanced practice nursing profession (APRNs) over whether NPs can provide primary care services comparable in quality to physicians. Organizations representing APRNs argue that nurse practitioners receive training that fully qualifies them to provide primary care services. Organizations such as the American Medical Association maintain that “care from nonphysicians is dangerously being promoted as ‘just as good’ as that provided by doctors—despite the huge differences in education and training requirements.”

Both opponents and proponents of expanding nurse practitioners’ scope of practice can cite literature comparing care by NPs to care by physicians. Opponents point to the differences in education and training: physicians must complete 10,000 to 16,000 hours of clinical education and training, while NPs only have 500 to 720 hours. Proponents cite research that NPs provide safe, comparable care to their physician counterparts. Proponents and opponents make these arguments to state lawmakers considering legislation to expand NP scope of practice in their states.

Some physicians claim that NPs make up for their lack of knowledge and experience by ordering too many tests or consulting too many medical specialists, which adds to health care costs. If so, that also makes the argument that, rather than getting in over their heads and risking medical errors, NPs know their limitations and get help when they need it.

It is challenging to study and compare patient outcomes with NPs versus physicians as primary care providers. For example, there’s the matter of self-selection bias, where certain patients may prefer physicians. It is difficult to adjust the data based on the complexity of patients’ conditions. For example, patients who have comorbidities often see specialists. Studies should also consider cost—NPs cost less compared to managed care systems—and access to primary care (in many states, NPs and physician assistants tend to practice in rural and underserved areas).

A recent study by researchers at the University of Washington, the VA Puget Sound Health Care System, and the University of Michigan was designed to minimize confounding factors and offer the best comparison of NP to physician-provided care.

The study used a quasi-experimental approach to examine differences in clinical outcomes, service utilization, and health care costs between NP-assigned and physician-assigned patients. It used administrative data from the Veterans Health Administration (VHA), one of the largest integrated care systems in the U.S..

The VHA reassigned patients whose primary care physician had left the VHA to either another physician or an NP, independent of the patients’ health, introducing a pseudo-random feature to the study. The final sample included 806,434 patients in 530 VHA facilities across the U.S.. After comparing patient conditions pre- and post-reassignment and between primary care providers, the study found NP-assigned patients had similar total costs and clinical outcomes to physician-assigned patients and were less likely to require hospitalization.

The pseudo-random element of the study addresses the confounding variable of sampling bias. The integrated model of the VHA removed the exogenous variables of patient preference and complexity of health status at the time of reassignment. In addition, the study’s large sample size accomplishes a degree of generalizability that other studies have not. This minimizes the effect of independent variables seen in other studies, enabling researchers to better estimate the association between NP-assigned and physician-assigned patient outcomes.

In some states, NPs have full practice authority and independently evaluate, diagnose, and treat patients. Other states restrict their scope of practice, requiring them to work for physicians or have physicians oversee their practice. This new research strengthens the case for expanding NP’s scope of practice to allow them to provide primary care services fully and independently.

Spencer Pratt is a Research Associate in the Department of Health Policy Studies

Earlier this year, I had the pleasure of speaking with Deirdre Nansen McCloskey. Deirdre is a Distinguished Scholar and Isaiah Berlin Chair in Liberal Thought at the Cato Institute, as well as Distinguished Professor Emerita of Economics and of History, and Professor Emerita of English and of Communication, at the University of Illinois at Chicago. She is a highly regarded economic historian and, in her own words, a “literary, quantitative, postmodern, free-market, progressive-Episcopalian, ex-marxoid, Midwestern woman from Boston who was once a man.”

Deirdre is the author of many academic articles and books. The latter include her most recent work, Why Liberalism Works: How True Liberal Values Produce a Freer, More Equal, Prosperous World for All (2019), and the famed trilogy of books on the Bourgeois Era: The Bourgeois Virtues: Ethics for an Age of Commerce (2006), Bourgeois Dignity: Why Economics Can’t Explain the Modern World (2010), and Bourgeois Equality: How Ideas, Not Capital or Institutions, Enriched the World (2016).

Over the course of two hours, we discussed the spread of classical liberalism as a chief cause of the Great Enrichment, the renewed interest of the clerisy in the discredited idea of industrial policy, the workings of spontaneous order, bureaucratic meddling in the economy and public choice theory, F. A. Hayek’s distinction between the macro and micro worlds, the importance of innovation for economic growth, the difference between Smithian and Schumpeterian growth, hierarchy and equality, progress and utopia, the differences between conservatism, classical liberalism, and progressivism, revolution versus evolution, the importance of studying history, the rise of liberalism in the 18^th century, Francis Fukuyama, interjurisdictional competition, and ancient China.

We end our conversation on a personal note, with Deirdre reflecting on her life’s journey and her message to young people today.

The U.S. Department of Commerce (Commerce) recently announced a new set of sweeping export controls—focused on semiconductors and advanced computing—with the goal of stunting the growth of China’s technology industry and protecting U.S. national security and foreign policy interests. The announcement comes on the heels of a major speech made by National Security Advisor Jake Sullivan at the Special Competitive Studies Project Global Emerging Technologies Summit in mid-September, in which he laid out, in part, the Biden administration’s approach to U.S. export controls. Though couched in terms of national security, the Commerce announcement is the most significant economic policy development in the bilateral relationship between Washington and Beijing since the ill-advised trade war that roiled markets between 2018 and 2020.

A battle for technological supremacy in the 21^st century lies at the heart of the competition between Washington and Beijing. In theory, export controls can be powerful tools to protect U.S. national security and technological considerations. For example, it makes sense to prohibit the export of materials necessary to make nuclear weapons. Yet it is a much more challenging calculus where the product in question has both civilian and military applications, as is the case with semiconductors and their component parts. Commentators have provided excellent technical analysis about the new export controls, the economic and geopolitical effects of which are still unclear. Nevertheless, some initial words of caution—if not outright concern—are appropriate.

First, the export controls apply to both military as well as commercial technology and artificial intelligence and bleeding edge products. This is a significant departure from the status quo, in which the United States tried a bifurcated approach to leading technology exports to China: a ban on military sales but permitted commercial sales. As Gregory C. Allen of the Center for Strategic & International Studies noted, “High-end AI chips can no longer be sold to any entity operating in China, whether that is the Chinese military, a Chinese tech company, or even a U.S. company operating a data center in China.” Indeed, as Alan Beattie recently observed in his terrific Financial Times column on the export controls, “[T]he prohibitions on US citizens and green card holders working in China’s semiconductor industry meant hundreds of employees, including from the world-leading Dutch manufacturer ASML, stopped work within days.” Perhaps these changes are necessary given China’s military/​civilian fusion, but—based on public information, at least—the scope seems too broad at this point. A scalpel is almost always better than a hatchet.

Second, the new export controls were unilaterally imposed pursuant to the Export Control Reform Act of 2018 (ECRA) and its corresponding regulations. Yet when Congress passed ECRA, it wisely stated in Section 102 (4), “Export controls should be fully coordinated with the multilateral export control regimes. Export controls that are multilateral are most effective…” That is exactly right. As former China director on the National Security Council and current Brookings Senior Fellow Ryan Hass noted on Twitter, “Multilateral controls tend to be more effective than unilateral controls. The US seems to have decided that it needed to move first and accept costs for doing so to signal to others the seriousness of its concerns.” It remains to be seen whether other countries will join the U.S. or whether the move will antagonize the very allies the U.S. should be partnering with to pressure Beijing to raise its commercial standards.

As I’ve previously explained, unilateral export controls raise major concerns regarding both efficacy and effect. Evasion of unilateral sanctions is common. If China can eventually source these products either domestically or from third party countries (home to U.S. firms’ competitors), the United States has not enhanced its own national security while at the same time simply denied sales to domestic companies. Needlessly denying U.S. tech companies revenue is no way to ensure that those same companies remain atop the global tech food chain. Indeed, as Eric Hirschhorn, under secretary of commerce and industry during most of the Obama administration noted in the China Business Review, “when we unilaterally control any technology too tightly, there’s a good chance we will drive research and development, and ultimately production, offshore.” An increasingly stringent export control ecosystem might also dissuade new firms from setting up operations in the United States—or incentivize offshoring of existing firms.

Third, the timing of the export control announcement raises numerous questions. Did it need to occur close to the recently concluded 20^th National Congress of the Chinese Communist Party, potentially embarrassing (and thus antagonizing) Beijing? Did the painful controls need to be implemented right now, just as the global economy, and China’s economy in particular, is faltering? Coming right before the U.S. midterm elections, was this more about U.S. political urgency, rather than about sound policy? Or was it really intended to amplify U.S. industrial policy—namely, the just-passed Chips and Science Act of 2022—by further encouraging the “re-shoring” of semiconductor resources? (Cato scholars have expressed skepticism of new semiconductor subsidies). Maybe there are good, classified reasons for why the sanctions were urgently needed today, but so far we haven’t heard them.

Fourth, the objectives of the new export controls are risky. Overnight, the policy hobbled China’s semiconductor industry and significantly damaged its technology industry. Meanwhile, Taiwan is a leading producer of semiconductors. Now that China is being cut out of the semiconductor supply chain and its own production has been kneecapped, the new policy could arguably hasten Beijing’s attempts to take control of Taiwan in order to secure the technological prowess it wants and needs to fuel its rise. At the very least, the policy—which Biden administration officials have expressly acknowledged is intended to thwart China’s technological progress—will further convince leadership in the Chinese Communist Party of the necessity of its quest for technological self-reliance as stated in its Made in China 2025 industrial policy. This sort of foreign discrimination and isolationism is a major irritant to firms in the United States and other market-oriented democracies around the world, and it could foster even more isolation and belligerence among the Chinese people (as past U.S. protectionism has done).

Too often Washington has treated sanctions as costless to the United States, but that is clearly not always the case. Aside from prioritizing multilateral over unilateral controls, policymakers should consider some simple steps to ensure a proper calibration between national security and economic considerations. For example, a tighter definition of “national security” is needed. The Trump administration’s bogus invocation of national security to restrict imported steel and aluminum is a perfect example of disguised protectionism. Though semiconductors are clearly a component of a country’s national security given their importance to weapons systems, the government should still explain how the controlled products in question are undermining U.S. national security (within reason; obviously certain intelligence must remain classified).

Likewise, policymakers should ensure that export controls are not unduly burdensome over the long term. A simple sunset with judicial scrutiny would be appropriate for export controls, particularly for products in which the technology is rapidly evolving. A high-end semiconductor needed for surveillance or a weapons system today may not be fit for that purpose tomorrow, yet such product could still be useful in commercial and civilian contexts. The government should be required to periodically show that the control is still necessary to protect national security or other vital U.S. interests. Finally, Commerce should be required to consult closely with affected businesses to determine if there are ways to mitigate potential national security risks without damaging commercial considerations.

There’s little doubt that China represents a major economic and geopolitical challenge for the United States and the rest of the world’s market-oriented democracies. Beijing is increasingly illiberal and repressive at home and bellicose abroad. Its brand military-civilian fusion is a unique challenge, particularly with respect to technology. Perhaps the Biden administration’s export controls will prove wise, but more caution—and official justification—are needed.

About a year apart, in the wake of the global financial crisis, two documents that would dramatically change the future of finance were published: in 2008, the 9‑page white paper “Bitcoin: A Peer-to-Peer Electronic Cash System” and in 2009, a 1,279-page draft of what would become the Dodd-Frank Act.

The subsequent history of these two documents is one of private innovation delivering what regulation in the U.S., at least so far, has not: an open and decentralized financial ecosystem where consumers have default access to their own financial transaction data. This history provides important lessons for policymakers on how the desired outcomes of regulations can fail to materialize years after laws’ inception and the market itself can achieve policy goals more quickly than regulation and without top-down direction.

While many are familiar with Dodd-Frank’s dramatic expansion of federal financial regulatory authority, a lesser known “open banking” provision (Section 1033), which occupies less than one page of the act, requires financial institutions to give customers access to their own transaction data in a usable format upon request, subject to Consumer Financial Protection Bureau (CFPB) rules. (While some definitions of “open banking” would have relevant laws explicitly refer to data transfers in addition to data access, Dodd-Frank’s access provision is solidly within the open banking universe.)

Last week, CFPB Director Rohit Chopra announced that the agency is planning to propose such rules in 2023, with the hope of finalizing them by 2024. Fittingly, this week was the fourteenth anniversary of the Bitcoin white paper. Over a decade on, Dodd-Frank’s goals of open banking by proclamation have languished, while Bitcoin has ushered in an entire industry unto itself that’s helped to accomplish open-banking objectives without any regulator ordering it.

Director Chopra’s announcement of the CFPB’s rulemaking plans articulated well some of the high-level goals of open banking and customers’ ability to port their financial data to new services, applications, and tools. Chopra argued:

• “A decentralized, open ecosystem will yield the most benefits for creators and consumers alike.”
• Expanded financial data access, if successful, will “reduce the ability for incumbents to build moats and for middlemen to serve as gatekeepers.”
• “It’s critical that no one ‘owns’ critical infrastructure.”
• And “more seamless integration … will give us all more choice.”

In a different context, Chopra’s words could be read as a laundry list of the benefits of cryptocurrencies and decentralized finance (DeFi). Open banking became a policy goal in no small part because of the gatekeeping role of centralized intermediaries. Cryptocurrencies’ main innovation is to remove reliance on such intermediaries. Accordingly, the benefits and opportunities Chopra seeks can be found in key features of the crypto ecosystem:

• Major cryptocurrencies are natively decentralized. Transaction histories are maintained not by a trusted intermediary but by a global network of computers incentivized to validate a cryptographically secure distributed ledger (a blockchain).
• Crypto users need not seek the permission of gatekeepers to access their transaction data. Rather, users are free to self-custody their own crypto holdings by directly controlling distributed ledger accounts with their own private keys. Where users do, their complete, pseudonymized transaction histories are available to them by default on public ledgers.
• Where financial rails are based on open-source software run by computers voluntarily participating in a permissionless network, the underlying infrastructure is not “owned” in the classic sense of someone possessing and controlling it with the right to exclude others.
• The crypto ecosystem is built on open-source code allowing it to be highly “composable,” meaning protocols and applications are modular and interoperable. In other words, they can be unbundled and reassembled like Lego blocks.

There is not complete overlap between an orthodox definition of open banking and the capabilities of crypto. As Nic Carter argues, unlike open banking, crypto and DeFi do “not seek to link multiple financial databases through either private sector agreement or state mandate, but instead envision[] an entirely novel financial system where a global userbase is united on one database—the ledger maintained by the blockchain.” Nonetheless, as sketched above, they drive toward similar goals.

When it comes to realizing these goals, it is worth looking at why it is regulation that has lagged private innovation. In the U.S., at least, consumer access to financial data typically has had more to do with the latter than the former. For instance, in an example of market-driven standardization, in 1997, software rivals Microsoft, Intuit, and CheckFree created a file format (OFX) for streaming financial information from banks to consumer desktop tools “before ‘open banking’ was even a term.” Banks in the U.S. went along based on consumer demand but became wary as their position as data gatekeepers eroded. Nonetheless, technology continued to lead the way as fintechs leveraged screen scraping software to collect data from financial institutions when consumers shared their login credentials with the fintechs.

With Dodd-Frank Section 1033’s regulatory hook, however, a bootleggers and Baptists alliance of banks and consumer advocates has objected to such tactics on consumer privacy and cybersecurity grounds, with some advocates questioning whether fintechs’ disclosures have been sufficient for consumers to give informed consent to the transfer of their own financial data. While private coordination can help to resolve such frictions, a top-down approach to driving market outcomes can falter by leading to zero-sum stakeholder competition that creates inertia or leads to regulatory capture. Director Chopra himself stated the capture problem clearly: “Regulation of the financial services industry has a bad name, and rightfully so. Financial regulators have largely complied with what dominant incumbents desire by writing complicated rules to fit existing business models.”

When it comes to making progress toward the “decentralized, open ecosystem” of finance that Chopra describes, the Bitcoin whitepaper has outperformed Dodd-Frank Section 1033 in the past decade plus. As policymakers look to further regulate the crypto ecosystem itself, they should keep top of mind the capacity of private innovation to not only achieve broad policy goals but also to get there before regulations do.

“I accidentally started a school,” says Siri Fiske, founder of Mysa Microschool.

Siri has spent the majority of her adult life in education, primarily in urban schools in Los Angeles. She first got interested in education when her children attended a public school co-op in California. She began designing curriculum for a public school there, focusing on units of study and ways to make learning fun. She then worked for independent schools and spent seven years working at a school in Korea.

Siri eventually moved to Washington, D.C. where she started designing her ideal school based on her experience designing curriculum as well as working with her own five children, who each had different learning needs. She considered what research says about how kids learn and what is missing in the education landscape.

“My initial plan was for a middle school,” she says. “There are great elementary schools and high schools, but there aren’t a lot of great middle schools.” She created a middle school model that she intended to be a school within a school—an existing public school would be able to implement her model as a subset of the regular middle school. As she was working on her design, she set up a non-profit and learned grant writing.

Siri’s grant writing was more successful than she expected it to be, and she landed enough funding to start her own school: Mysa School, a modern version of the one-room school house. According to the Mysa website, “Our students learn in a cooperative, multi-age environment; this is a collaborative, interdisciplinary school community where students chart their learning pathways, in close consultation with faculty. Students are empowered to choose how knowledge is constructed and how to demonstrate understanding. This results in a truly student-centered learning experience, where students are gifted with open and flexible physical spaces, a number of technological tools, and individualized curricula.”

Mysa uses a hybrid model that combines hands-on, project-based learning with online lessons, programs, and resources from around the world. Each week, students receive a customized menu of work that has been crafted with their personal interests and learning needs in mind. Students manage their projects, assignments, and deliverables with guidance from teachers as they work to master the content.

According to Siri, “In this day and age, with what we know about how people learn, and the resources we have instantly available, schools need to more flexibly adapt the ways that they teach each child to that particular child’s learning style. I believe that the Mysa model of education, with its personalized learning plans, honors the uniqueness of each student and is a highly effective way of not only teaching, but of lighting a fire of curiosity within each student.”

Siri gets frequent requests to start other schools—including from parents whose children had a chance to spend a day at Mysa. In 2021, she worked with a group of parents to open a campus in Vermont. She says it’s been a good opportunity to see if what her program that has been successful for a diverse group of children in urban DC will also flourish in rural Vermont. So far, it seems to be working.

One area where Mysa differs from many other microschools is that part of its mission is to help improve public schools. Siri uses national standards as benchmarks but finds unique ways to help children reach those benchmarks. She’s even piloting a software program to help schools and parents track student mastery using various benchmarks separate from grade levels. If you’re interested in participating in the pilot program, you can connect with her through the Mysa website.

Siri says, “The Mysa model not only prepares students for college but it honors the needs of the student in the moment, as adolescents and young adults, acknowledging that they have the rest of their lives to be grown up, but only one childhood.”

Mysa Microschool is an exciting example of what education can look like when we think beyond the conventional understanding of “school.”

Responding to medical experts, including the American Medical Association, who have been complaining for years that the Center for Disease Control and Prevention’s 2016 Guideline for Prescribing Opioids for Chronic Pain lacked a strong basis in the evidence—and after it issued an Advisory in 2019 stating the Guideline was misinterpreted and “misapplied” by state lawmakers and health care practitioners—the CDC announced it was going to revise the Guideline before the end of 2022. Unfortunately, 38 states have already cast the flawed 2016 Guideline in stone by enshrining—and misapplying—all or part of it in statutes that dictate how health care practitioners may treat patients in pain.

In February of this year, the CDC released a draft of the revised Guideline and requested comments. I provided my comments here. In those comments, I stated. “Notwithstanding the well-intentioned exhortations and disclaimer in the draft 2022 opioid prescribing guideline, the recommendations change very little from those put forth in 2016.”

The CDC goes to great lengths to stress throughout the draft 2022 Guideline that the document is meant to serve as a list of suggestions and recommendations and is by no means intended as a mandate, emphasizing that physicians should use their best clinical judgment to provide individualized treatment to their patients. However, I commented, “The CDC guideline will inevitably become interpreted and adopted as hard and fast rules by state and local governments, pharmacies, health plans, and third-party payers, despite guideline warnings against doing so.”

I also criticized the draft for suggesting dosages based on “morphine milligram equivalents” of opioids:

For example, the guidelines still rely on Morphine Milligram Equivalent (MME) dose recommendations, even though there is no pharmacologic or biochemical basis for relying on equianalgesic conversion factors.

The use of MME conversion tables is nothing more than junk science. As Dr. Nabarun Dasgupta of the University of North Carolina Injury Prevention Center has written:

Contrary to conventional wisdom, conversion values are not based on pharmacologic properties. Instead, they arose 60 years ago from small single-dose clinical studies in postoperative or cancer populations with pain score outcomes; toxicologic effects (e.g., respiratory depression) were not evaluated.

On November 3, the CDC published the final version of the 2022 Clinical Practice Guideline for Prescribing Opioids for Pain. The Guideline no longer recommends MME dosage thresholds, but it still urges practitioners to be cautious about prescribing more than 50 morphine milligram equivalents of opioids per day, stating :

Many patients do not experience benefit in pain or function from increasing opioid dosages to ≥50 MME/​day but are exposed to progressive increases in risk as dosage increases. Therefore, before increasing total opioid dosage to ≥50 MME/​day, clinicians should pause and carefully reassess evidence of individual benefits and risks. If a decision is made to increase dosage, clinicians should use caution and increase dosage by the smallest practical amount.

To prevent the recommendation from being “misapplied,” the Guideline adds the following disclaimer to the above paragraph:

The recommendations related to opioid dosages are not intended to be used as an inflexible, rigid standard of care; rather, they are intended to be guideposts to help inform clinician-patient decision-making.

Alas, the 2022 Guideline still includes the now-discredited MME conversion table that providers can refer to when prescribing opioids.

The Guideline recommendations are still primarily based on “Type 3” and “Type 4” evidence, evidence with important limitations.

If the past is prologue, expect the Guideline’s suggestion to use caution approaching a dose of 50 MME to morph into another de facto mandate as lawmakers, pharmacies, and insurance plans fixate on that number. As Josh Bloom and I have written before:

When a government agency “recommends” a policy, it’s akin to a recommendation from Tony Soprano; it is inevitably interpreted as a mandate, obeyed by state and federal agencies, health insurers, and even pharmacies.

Perhaps most egregiously, the rationale of the 2022 Guideline remains predicated on the flawed assumption that overprescribing opioids caused the overdose crisis. There is no correlation between prescription volume and the nonmedical use or addiction to prescription opioids. And the percentage of people aged 18 or older addicted to prescription pain pills has been unchanged at less than one percent this entire century. The CDC should follow the evidence and abandon this mistaken premise.

Finally, as I concluded in my comments on the draft proposal back in February 2022:

1‑The Centers for Disease Control and Prevention should not be issuing opioid prescribing guidelines. Professional specialty organizations, overseen by practicing clinicians and clinical educators, are the institutions that should be issuing standard of care and best practices guidelines.

2‑The CDC guideline will inevitably become interpreted and adopted as hard and fast rules by state and local governments, pharmacies, health plans, and third-party payers, despite guideline warnings against doing so.

3‑The 2022 guideline very closely resembles the 2016 guideline and is based on weak evidence; in the case of Morphine Milligram Equivalent recommendations, the guideline is pharmacologically unsound, and the conversion tables are based largely on decades-old subjective studies that didn’t even examine toxicologic effects such as respiratory depression rates.

4‑The overdose crisis is largely caused by a growing population of nonmedical drug users intersecting with increasingly dangerous drugs being developed for the black market fueled by drug prohibition. Efforts to address the problem through reductions in opioid prescribing have only exacerbated the situation by driving nonmedical users to more dangerous drugs while depriving pain patients of necessary relief.

5‑The Centers for Disease Control and Prevention should abandon its efforts to establish a prescribing guideline and defer to the professional institutions usually charged with establishing best practices.

Nothing in the just-published Guideline makes me want to reconsider that conclusion.