I would like to thank the CDC for providing me the opportunity to comment on the proposed revision to the 2016 Guideline for Prescribing Opioids. I appreciate this opportunity to provide my perspective, as a health care practitioner and policy analyst.
The CDC correctly issued an Advisory in 2019, urging health care practitioner to avoid misinterpreting and misapplying the 2016 guideline, correctly stating that the 2016 guideline never intended for practitioners to impose hard limits on the dose and number of opioids prescribed to pain patients and that it was never intended for practitioners to abruptly taper patients whose chronic pain had been well controlled with opioids. The Advisory was issued after 36 states codified hard limits on opioid prescribing inspired by the 2016 Guideline, and a plethora of patients subsequently being abruptly cut off from or denied pain medication, many of whom resumed a life of despair. It was also issued around the same time that the American Medical Association released a similar statement.
The draft revision of the CDC guideline opens by emphatically making the same point, stating “The voluntary clinical practice guideline provides recommendations only and is intended to be flexible to support, not supplant, clinical judgment and individualized, patient-centered decision-making.” The draft emphasizes, “This clinical practice guideline should not be applied as inflexible standards of care across patient populations by healthcare professionals, health systems, pharmacies, third-party payers or state, local, and federal organizations or entities.”