I have been a student of our bureaucracy/bureaucrats for nearly 40 yrs and how they act can be highly predictable.
The CDC’s first published opiate dosing guidelines were at first attempted to be done with a great deal of it done in secret. The meeting of the group was not published and they tried to keep the identity of all those participating in the meeting anonymous.
There was no period for the public to make comment on what was proposed… because there was NO PROPOSAL… the guidelines were created and published.
Immediately after they were published, the then head of the CDC Tom Frieden published a public statement to CLEARLY STATE that the guidelines DID NOT BEAR THE WEIGHT OF LAW… they were just GUIDELINES.
Many of us believe that the CDC did not have the statutory authority to generate these guidelines, thus besides not have the weigh of law they were basically UNCONSTITUTIONAL.
Our system is so designed that bills/laws/interpretation of laws do not have to meet any constitutional verification before they are put on the books and they can be applied/enforced as long as they remain on the books or until they are challenged in our courts and declared unconstitutional.
Some believe that figuratively the DEA and the VA were waiting outside of the meeting room door to get a copy of these new opiate dosing guidelines… they may have even been getting copies of the draft guidelines on a daily basis, because it would seem that those two agencies were ready to hit the ground running once the guidelines were officially published.
Again our medical system, once >50% of medical practitioners follow a particular process or policy and procedures it becomes a de-facto the standard of care and best practices. There seemed to be a coordinated push by the VA, DEA, insurance/PBM industry to influence these guidelines with practitioners go get them to adhere to these guidelines. So once that >50% goal was reached either locally/regionally/nationally … the DEA could come in and accuse prescribers of not meeting the current standard of care and best practices and thus the DEA could draw the conclusion that the prescriber was prescribing controlled meds that were not medically necessary to many/most/all of their pts.
After a couple of years, there was a growing number of statements that the CDC opiate dosing guidelines were being misapplied… and eventually the CDC agreed to reopen the guidelines for public comment to “revise” the guidelines.
This time the CDC followed the proper federal laws… they made a public announcement that they were revising the guidelines and had a public comment period.. Why shouldn’t they… they created the first set of opiate dosing guidelines without following any of the federal laws and they suffered no consequences and no one bothered to challenge the constitutionality of the original set of guidelines.
Historically, when laws/regulations are open for revision, they usually end up rougher/harder/stricter on those who they are to applied to.
It is no secret that PROP and FEDUP where making comments during the open comment period and those and other similar groups are in lock step with the DEA’s/VA’s agenda on treating pain with opiates and prescribing other controlled substances to people who have a medical need for treating their subjective diseases.
The community had better be prepared for new and tighter guidelines… maybe 50 MME/day limits – for all pts … acute, chronic , terminal. Maybe limiting PCP’s to maybe 20 -30 MME/day for 7 days for acute pain – no additional pain meds. Expand the guidelines to make it illegal for a pt to be prescribed a opiate, benzo and muscle relaxant together – BY ANY PRESCRIBER(S).
If my suspicions are anywhere near close to where the revised guidelines will end up… the community had better stop all its in-fighting and start raising money to challenge these guidelines in our court system as to their constitutionality. If I am near correct, prescribers will start discharging chronic pain pts – IN MASS – with a 30 days of meds to wean down off their controls. There is not enough pain clinics to accept or take appropriate care of all the chronic painers.
Suicides will increase dramatically, and street dealers will be more than happy to take care of all the chronic painers seeking relief from their relentless intractable chronic pain… and the street dealers won’t take insurance, won’t want you to pee in a bottle, no pain contracts nor care if you what more meds “early”.
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