For friends and colleagues
Comments to the 2022 Draft Revised CDC Guidelines on Prescription of Opioids
Richard A Lawhern Ph.D.
February 25, 2022
To the writers and peer reviewers of the 2022 draft revised CDC guidelines on prescription of opioids:
My name may be familiar to some addressees. I speak and write widely as a non-physician subject matter expert on public policy for the regulation of opioid pain relievers and of physicians who employ them in treating their patients. I have over 25 years’ experience in this field, with tens of thousands of person to person communications in social media, and over 150 published papers, articles, and interviews in medically oriented journals and mass media. I have spoken and written for several public meetings of the Board of Scientific Councilors of the CDC National Center for Injury Prevention and Control.
The February 2022 draft revised and expanded CDC practice guidelines for prescription of opioids are fatally flawed and deliberately misleading. Like their 2016 predecessor, these guidelines misrepresent science that is known widely among practicing clinicians. When taken as directed, prescription opioids are both effective and safe for the great majority of patients with moderate to severe acute or chronic pain. The draft guidelines explicitly acknowledge damage done to millions of patients and clinicians by the 2016 document. They deceptively proclaim that physicians should be free to exercise their own professional judgment in the treatment of their patients. But the writers continue to reinforce their original anti-opioid agenda in a document intended to intimidate physicians and support draconian legal prosecution against any who continue to treat pain by means of opioid analgesics.
It is time for the US CDC to be removed from any role in developing practice guidelines for all medical specialties including pain management. Such guidelines are the proper purview of professional medical specialty academies and associations whose members are clinicians with practical experience in community or hospital practice. The CDC lacks both the legislative charter and the internal expertise to perform such oversight for other than communicable disease.
As written, the 2022 draft follows an old bureaucratic tradition: if you can’t convince your audience with evidence and rational argument, then baffle them with a large volume of BS nonsense.
Seven attachments are provided.
1. Detailed comments to the 2022 draft revised/expanded CDC practice guidelines, comprising 27 pages, 9400 words and ~40 references.
2. “The Opioid Crisis in Three Charts” – a short paper demonstrating that the so-called “opioid crisis” was not created by clinicians prescribing opioids to patients in pain.
3. Comments on AHRQ Technical Brief on “Prevention, Diagnosis, and Management of Opioids, Opioid Misuse and Opioid Use Disorder in Older Adults” June 2020
4. Comments on “Treatments for Acute Pain – A Systematic Review (AHRQ)” September 2020
5. Methodological Errors in “Treatments for Acute Pain – A Systematic Review”January 2021
6. “ Supplemental Evidence for an AHRQ Research Protocol on Integrated Pain Management Programs” December 2020
7. “Comments on Integrated Pain Management Programs – Systematic Review” June 2021
I will next week begin a campaign in social media to encourage patients, caregivers, and their clinicians to submit their own comments in their own words to the Federal Register site:
Do not clip and drop from what follows:
If you or someone in your family have been harmed by the 2016 CDC opioid guidelines, then tell the CDC peer reviewers how. Emphasize that the 2022 guidelines are not an improvement over the original.
If you have medical credentials, state them
If you wish to endorse my remarks by name, then do so:
“I wish to endorse the comments of Richard A Lawhern, PhD, as circulated in social media and filed with the Federal Register. His comments reflect my own experience and concerns.”
Likewise, I encourage all who read this note to call their Federal and State legislators’ offices. Do NOT send emails as those are regularly ignored. Many Congress creatures won’t even let you file comments to their web pages unless you give them an address in their State or Congressional district.
– Use the website of Common Cause to find contact data
– Call the listed phone numbers.
– Identify yourself politely
– Ask to have your comment logged in their daily call summary for the legislator to read.
– Provide your call-back number [optional]
– Speak the following messages:
“I am a chronic pain patient (or a caregiver for a chronic pain patient). I vote in your district”
“I have been personally damaged by the 2016 CDC opioid guidelines, and the 2022 version is no better.”
“I want your boss to co-sponsor legislation to ban CDC from issuing practice guidelines for any medical specialty other than contagious disease. We also need legislation to force the DEA to stop persecuting doctors out of practice when they treat pain.”
– Provide your call-back number [optional]
Richard A “Red” Lawhern PhD