I apologize that this blog ended up being much longer than I had intended, but things evolved

My blog is now in its TENTH YEAR… I have seen advocates come and advocates go… I have seen untold number of people putting up petitions to help the community… untold number that have called, emailed, faxed, sent letters to their Fed and state representatives.  Some advocate groups believe that state laws that would protect prescribers and pts is the way to go.  While I am not an attorney, I have asked – how can a STATE LAW prevent a FEDERAL AGENCY (DEA) from coming into a state to prevent them from enforcing a FED LAW ?  I have yet to have anyone even attempt to provide me a answer… even a educated guess as to why it could work.

I have only worked as an employee about 6-7 post college, the rest I was self employed and when you are self employed, especially when you businesses deal with Medicare, Medicaid & insurance and all the bureaucracies that businesses have to deal with.  So I have been watching/dealing with various bureaucracies for over 4 decades.  I have never seen when some rules/law/regulations is opened to be revised … things tend to get WORSE…

My opinion of the CDC opiate dosing guidelines 2022,  this will be no different.  Those entities that looked at the 40 odd pages of the 2016 guidelines and found their favorite sentence, paragraph or page and claimed that they were observing the guidelines while ignoring all the carve outs for how those chronic pain pts would be entitled to appropriate pain management.

everyone in the community needs to fully understand that they are not alone, but likewise… no one person alone nor can any “small group” alone can change the path that the community is on.

The community is up against a army of Goliaths – most with either a badge or a law degree – and we have seen that they interpreted the 2016 guidelines in a way that allowed them to falsely accuse all too many practitioners of violating the CSA and fabricate a case against them and send them to jail for 20 yrs and confiscate all their assets and leave his/her family penniless and throw hundreds of chronic pain pts into cold turkey withdrawal.

There are already some rumors floating around that some prescribers are already implementing a 50 MME/day limit and the revised guidelines are still just in the comment period and there are also some rumors about many of the same people/entities involved in the 2016 guidelines are once again on board to finalize the 2022 guidelines.

Given this recent article that validated what many of us already suspected … that the MME system has no clinical studies behind it…  If the MME system is included in this new guideline, should we question and legally challenge the “expertise” and competency of those who finalize the 2022 guideline ?

The community needs to decide if they are going to remain in their segregate little “tribes”  and struggle to be recognized more than any other tribe or they can come together and put their $$$ together and hire a law firm to challenge that the MME system has no valid medical use.  Then law firms will probably start lining up to take on healthcare corporation who are harming chronic pain pts by using the MME system to limit or restrict the amount of pain management – including opiates – that a pt is “entitled to” …

https://www.acsh.org/news/2022/03/01/true-story-morphine-milligram-equivalents-mme-16154

The above link by  Chuck Dinerstein, MD, MBA traced back the “origins” of the “MME SYSTEM” …  It would seems that according to Dr Dinerstein’s  “genealogy research on the MME system “…  it is basically a “bastard”… there is no clinical studies (parents) of this “child” what everyone is using today is just a mishmash of opinions/observations of a untold number of so called medical professionals.

Any comments made by patients to the CDC proposed guidelines will most likely be DISMISSED as biased or anecdotal observation(s)…  in the “scientific community” … otherwise – WORTHLESS.

We know that it has been reported that the 2016 guidelines used many studies that were rated “3” or “4” – with “4” being CRAP… so it would appear now that the CDC used one set of criteria that had NO VALID STUDIES BEHIND IT. Who believe that most/many/all of those on the first committee did not know or should have known that there no validity behind the  “MME SYSTEM” ?

This was a comment today on my blog  today on one my recent blogs :  https://www.pharmaciststeve.com/statistically-chronic-pain-pts-dont-exist/

Ohhh i know the senators baldwin and johnson of wisconsin know we exist.About 3-4 years ago now,,i specifically ask senator baldwins to put a box on all death certificates ,”death due to forced physical pain from medical condition,”I was informed i was speaking to ,”Sarah,senator baldwins intern,but her communication from baldwin was,and i quote,,,”prove it,”Prove that person died from forced physical pain,,To her point,,I am sure they have and will continue to deny our right to have our deaths recorded honestly.They do not want it recorded how many they have willfully killed,from a treatable condtion.Now with our Vets hospital,ie,”Tomah V.A. being the poster boy for fake opiate addiction,,they will never let the truth be shown here or in America,,that they have killed,medically tortured,tortured to literal death 10,000s,,,,Soo we have to go outside of the U.S. to prove this and end this genocide,however,,w/Russia going nuts, i think our cause will be put on a back burner for now???

Is this an admission that they have the community running in circles like a dog chasing it’s tail ?    They have “their” FACTS, “their” TRUTHS,  “their” AGENDA and anything submitted that does not align with those … will be ignored, discounted or somehow buried.

We know that pts who have their meds cut/eliminated most/many/all will end up with hypertension, and even if doc gives the pt all four categories of anti hypertensive meds… little/nothing happens… because apparently the process that the pharma’s meds work on – is different that the processes under/untreated pain uses to raise BP.  The American Heart Assoc has for decades – maybe a century – has stated that uncontrolled BP is the “silent killer”…  it will also damage the eyes, the kidneys, if a stroke or heart attack doesn’t get the pt first… but those are all “natural causes” of death.   It is pretty much a sure bet, that anyone with under/untreated pain will end up with Addison’s disease… only the time  line from when their meds are cut and the time they are diagnosed.

I expect that the proposed 2022 guidelines will be accepted and published without a word changed, and with the figure of 50 MME’s in the text…the DEA, VA and all others in healthcare who will take liberties with the guidelines – as they did the last guidelines to find their favorite sentence, paragraph, page and instead of having 40 odds pages from the 2016 guidelines, they have 211 pages to wade thru.  If history repeats itself, all of the exceptions to allow pain pts to be properly treated in those guidelines will be ignored. After all, all those entities who ignored those treatment exceptions in the 2016 guidelines will have to do the same processes with the new guidelines – or admit that  they were wrong before and they will have to admit that they were previously wrong and put all their budgets and number of employees at risk of being reduced…  which in a bureaucracy is heresy.

If you are gathering info from pts to send to the AMA… the AMA is basically a “toothless paper tiger”, maybe a small double digits percentage of MD’s belong to the AMA…  The only reason that the AMA is financially viable is because they own the writes to the ICD medical billing system and everyone who does medical billing has to pay them a annual royalty to use them.  The state Medical licensing boards having licensed MD on the board, who have a DEA license are fully aware that the DEA can fabricate a case against just about any doctor and bankrupt them and throw them in jail for 20 yrs… they are not going to disagree with a medical license they want to yank.

IMO, it is time for the community to quit the infighting and put their dollars together and challenged the validity of the MME SYSTEM…  just think how many rules/laws/regulations/ policies & procedures that reference that as their basis. All the docs sitting in jail because the DEA claimed that they prescribed opiates without valid medical necessity – that could be appealed…

If the 2022 guidelines are used to create new daily MME limits… like was done with the 2016 guidelines…  In the first page of the proposed guidelines.. they stated something to the fact that they were using the same “high standards” they used in creating the 2016…  We know that is a lie…  and that reminds me of  Einstein’s definition of “insanity”…  If history repeats itself – the community within 2 yrs of the guidelines being accepted/published…. the community could end up meeting its WATERLOO !!!

Here is probably something most people making comments on the CDC proposed 2022 guidelines, didn’t see – because it was a “link” on the page where one has to put comments

According to the last line, on the first page where people are to submit comments,   the CDC could care less about how their new guidelines are going – or have – to impact individuals without “WELL SUPPORTED COMMENTS”   – to me that suggests CLINICAL STUDIES

Summary

• Read and understand the regulatory document you are commenting on
• Feel free to reach out to the agency with questions
• Be concise but support your claims
• Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted
• Address trade-offs and opposing views in your comment
• There is no minimum or maximum length for an effective comment
• The comment process is not a vote – one well supported comment is often more influential than a thousand form letters

Filed under: General Problems