FDA identifies harm reported from sudden discontinuation of opioid pain medicines and requires label changes to guide prescribers on gradual, individualized tapering
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Read this and weep – AGs and National Opioid Agreement – nicely put CPs OUT IN THE COLD It would appear that many different parts of our federal and state bureaucracy are focusing on cutting the availability of FDA-approved controlled opioids. I guess that the DOJ/DEA was not shutting down practitioners’ offices fast enough. More and more people were being poisoned/dying by illegal Fentanyl, but the media keeps referring to all the deaths are from JUST FENTANYL. Never mind that all the lethal illegal fentanyl was coming from CHINA & MEX CARTELS. So the NATIONAL OPIOID AGREEMENT was to get the wholesalers to RATION OPIOIDS to community pharmacies.
STILL NOT FAST ENOUGH. Now, someone has talked the FDA into attempting to remove all extended-release opioid medications from being available. Opioid medications have been commercially available in the United States for well over a century. If one reads the “fine print” on the website to place your comment. Comment Period Ends: May 4, 2025 at 11:59 PM EDT
We have an estimated 30% of the population dealing with chronic pain. Just imagine how many chronic painers can hold down a job because of long-acting opioids, and if they lose their long-acting opioids, many may end up on Medicare disability. We all know just how generous Medicare disability payments are! Just imagine how many chronic painers will not be able to get a good night’s restorative sleep.
Below is a federal law signed into law in 1935 – 35 years BEFORE the CONTROLLED SUBSTANCES ACT was signed into law. I am not an attorney, but 42 USC 1395 would seem to indicate that anyone in the federal government is prohibited from interfering with the practice of medicine. Regardless of this nearly century-old law, the DOJ/DEA is repeatedly doing just that – over and over and over again.
Is AG Pam Bondi going to arrest some of the people within her DOJ agency for violating many federal laws? She is shown in the above video, where she is talking about arresting judges who are under her DOJ agency and have broken a few federal laws.
Here is one of Pam Bondi’s re-election TV ads – running for FL AG – from about 10 yrs ago.
The June 2022 SCOTUS ruling that the DEA must NOT USE OBJECTIVE CRITERIA in judging prescribers in what they prescribe to pts dealing with SUBJECTIVE CRITERIA.
https://uscode.house.gov/view.xhtml?req=(title:42%20section:1395%20edition:prelim)
(Aug. 14, 1935, ch. 531, title XVIII, §1801, as added Pub. L. 89–97, title I, §102(a), July 30, 1965, 79 Stat. 291 .)
For short title of title I of Pub. L. 89–97, which enacted this subchapter as the “Health Insurance for the Aged Act”, see section 100 of Pub. L. 89–97, set out as a Short Title of 1965 Amendment note under section 1305 of this title.
Pub. L. 111–148, title III, §3601, Mar. 23, 2010, 124 Stat. 538 , provided that:
“(a) Protecting Guaranteed Medicare Benefits.-Nothing in the provisions of, or amendments made by, this Act [see Short Title note set out under section 18001 of this title] shall result in a reduction of guaranteed benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.].
“(b) Ensuring That Medicare Savings Benefit the Medicare Program and Medicare Beneficiaries.-Savings generated for the Medicare program under title XVIII of the Social Security Act under the provisions of, and amendments made by, this Act shall extend the solvency of the Medicare trust funds, reduce Medicare premiums and other cost-sharing for beneficiaries, and improve or expand guaranteed Medicare benefits and protect access to Medicare providers.”
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Apparently, the author of this article did not wish to call out what is still a hypertensive crisis level. Which it is a BP of > 180/120.
I can’t count the number of times that a pt has told me that after their pain meds have been reduced and their blood pressure would go up to > 200/100. Unfortunately, many pts often state that the pain doc will claim that they don’t treat blood pressure, and the pt’s PCP or Cardiologist claims that they don’t treat pain.
The graphic to the lower left indicates the potential medical consequences that a pt may experience if the pt’s blood pressure is not treated and reduced to a more acceptable/recommended level.
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Introduction: The Tariff Test Case No One Is Talking About
For all the attention given to tariffs on steel, aluminum, and semiconductors, one of the most disruptive trade proposals on the horizon has remained oddly underdiscussed: Donald Trump’s plan to impose sweeping tariffs on foreign-made pharmaceuticals. Framed as a populist push to bring drug manufacturing back to U.S. soil, the policy is gaining traction on the campaign trail—and raising alarms among economists, health policy experts, and pharmaceutical executives alike.
While the former president has not yet detailed a full plan, multiple sources close to his economic advisory circle confirm that the groundwork is being laid for a 10–20% blanket tariff on all pharmaceuticals imported from key trading partners, including China and India. These two countries, it should be noted, account for over 70% of the active pharmaceutical ingredients (APIs) used in U.S.-consumed drugs.
The rationale is politically intuitive: punish foreign competitors, reward domestic production, and make America less reliant on hostile supply chains. But beneath the surface, the implications are far murkier—and potentially more dangerous.
This is not just a trade issue. It is a test case in how globalized health economics, domestic populism, and national security concerns collide—with patients, as always, caught in the crossfire.
The Supply Chain We Forgot We Had
To understand how Trump’s pharma tariffs might land, we need to revisit how the modern pharmaceutical supply chain operates.
Unlike consumer electronics or automobiles, where parts may be assembled in one location and finished elsewhere, pharmaceutical manufacturing is largely decentralized and opaque. APIs—the raw chemical compounds that make drugs effective—are often produced in China and India due to lower environmental regulations and cheaper labor costs. From there, they are shipped to contract manufacturers, often in Europe or Puerto Rico, who formulate the final product. Only a fraction of these processes occur on U.S. soil.
This design wasn’t an accident. It was driven by decades of globalization, in which efficiency and cost-saving trumped domestic capacity. But the COVID-19 pandemic exposed just how brittle this system had become.
During the early days of the pandemic, U.S. hospitals saw shortages of common medications—anesthetics, antibiotics, even basic painkillers—not because the drugs were too expensive, but because they were stranded on ships or behind closed ports. Trump’s tariffs are, in part, a reaction to that vulnerability.
But they also risk weaponizing a problem that requires surgical precision—not political bluster.
The Economics of a Blunt Instrument
A 15% tariff on foreign pharmaceuticals may sound like a modest policy shift. But even small changes in upstream drug pricing can ripple across the healthcare system in disproportionate ways.
For starters, U.S. pharmaceutical companies often rely on foreign-produced APIs even when the final drug is branded “Made in America.” A blanket tariff would raise costs for manufacturers across the board—regardless of where the final pill is pressed.
Then there’s the issue of generics. Around 90% of prescriptions filled in the United States are generics, many of which are produced entirely overseas or with imported components. The generics market operates on razor-thin margins, and a tariff could either force suppliers to withdraw from the market or pass the costs onto consumers.
“You’re essentially taxing the cheapest drugs we have,” said Dr. Matthew Lang, a health economist at George Washington University. “And those are the drugs most Americans depend on daily.”
Insurers, pharmacy benefit managers, and Medicare administrators would face tough choices: absorb the increased cost, restrict formularies, or shift the burden to patients through higher copays.
Whichever path is chosen, the result could be the same: higher out-of-pocket costs and less access—especially for low-income and elderly populations.
National Security or Economic Nationalism?
Proponents of the tariffs argue that national security justifies the cost. They point to a 2020 report from the U.S.-China Economic and Security Review Commission that warned of America’s overdependence on foreign drug manufacturing, particularly in geopolitical flashpoints like China.
There is truth to this concern. China dominates the global supply of antibiotics and other critical medications. India, for its part, relies heavily on Chinese APIs. A strategic disruption in this chain—whether due to conflict, pandemic, or economic coercion—could leave the U.S. vulnerable.
Yet critics argue that tariffs are a clumsy way to address this problem. “Tariffs don’t build factories,” said Janet Kuo, an analyst with the Brookings Institution. “They just make existing products more expensive. If the goal is to re-shore production, then we need targeted subsidies, public-private partnerships, and FDA support for domestic startups—not taxes on patients.”
Moreover, there is no guarantee that domestic producers could ramp up quickly or cheaply. Drug manufacturing requires not only infrastructure but regulatory clearance, quality assurance, and skilled labor—none of which can be imported on short notice.
Political Chess Meets Policy Roulette
If the tariffs do move forward, expect the political battle to be fierce. Democrats will likely attack the policy as reckless and anti-consumer, while some Republicans—particularly those aligned with libertarian or pro-business wings—may resist on grounds of economic orthodoxy.
The pharmaceutical lobby, already bruised from years of price-control debates, is expected to mount a robust defense. But they may face an uphill battle in an election year where “bringing jobs home” remains a potent talking point.
As with many Trump-era economic policies, the goal may not be policy coherence but political messaging. “Tariffs are a way of drawing lines,” said political scientist Nora Greenberg. “You’re either with American workers or against them. That binary appeals to voters—even if the actual impact is far more complex.”
Preparing for the Impact
While the tariffs are not yet law, stakeholders across the healthcare spectrum should begin contingency planning now.
There is still time to shape the outcome. Congressional hearings are likely. International partners may seek exemptions or retaliate with their own tariffs. And perhaps most significantly, Trump’s return to power—if it happens at all—remains an open question.
But the broader lesson is already clear: Globalized healthcare comes with globalized risks. And when political solutions are crafted without systemic understanding, the costs are rarely paid by policymakers. They are paid by patients.
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I had an interesting conversation today. Our PCP called in Barb’s opioid Rx in Monday or Tuesday. The independent pharmacy that we patronize called us and said that their drug wholesaler – one of the BIG THREE MAJORS – did not have her particular med in stock & it was in back order.
I know who the drug wholesaler that they use. So I called their corporate HQ. I got to someone in their customer service area. I told the gentleman that I was trying to confirm that they had no inventory of a particular C-2. He first told me that I was not a customer of the wholesaler, and he could not tell me if they had inventory.
I asked if he could transfer the call to someone who is his supervisor and could share that information? Surprisingly, this young man suddenly had the authority to provide me if they had any inventory on hand.
He stated that they had no inventory on hand. I asked him how many pharmas that makes this particular product, did they normally have it in inventory ? I was told that they normally had the product from NINE DIFFERENT PHARMAS. I asked if they had an inventory on the next higher strength. I knew that even though this was a extended release – long acting – dose that they could be split in half without interfering with the long-acting property. I then called our pharmacy and they checked the wholesaler’s inventory for the higher strength – but they only had CAPSULES – which you can’t split.
This guy had no information on when any of the strength that Barb needs would become available.
I have no way to check, but the THREE MAJOR DRUG WHOLESALERS control some 80% of the entire Rx marketplace. So I would not be surprised if all three of these wholesalers are also without inventory.
Barb has a implanted pump, so she can “survive” without one of the two oral opioids that she takes. I feel sorry if all those chronic pain pts that can’t refill their Rxs more than two days early and will soon be thrown into cold turkey withdrawal.
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The FDA does not routinely use Morphine Milligram Equivalents (MME) in its professional literature for opioid
dosing for several key reasons:
– **Variability in Conversion Factors:** MME conversion tables are based on data from small clinical studies
in limited populations, and different resources (tables, calculators) may use different conversion factors for the
same opioid. This lack of standardization can lead to inconsistencies and potential dosing errors when applied
broadly[5].
– **Patient and Drug Differences:** The pharmacokinetics and pharmacodynamics of opioids can vary widely
among individuals due to factors like opioid tolerance, genetics, age, organ function, and concurrent
medications. Some opioids (e.g., partial agonists like buprenorphine or novel agents like tapentadol) do not fit
neatly into the MME system, making it unreliable for all clinical scenarios[5].
– **Intended Use of MME:** The original purpose of MME was to provide a rough guide for clinicians when
converting from one opioid to another, not as a precise tool for dosing or setting rigid prescribing thresholds[5].
Over time, MMEs have been increasingly used by policymakers and payers to set limits, but these uses may not
reflect the nuances required for individual patient care.
– **Risk of Misapplication:** The FDA and CDC have both cautioned that applying MME thresholds as rigid
standards can lead to unintended consequences, such as under-treatment of pain or abrupt discontinuation of
opioids in patients who may benefit from them. Clinical guidelines now emphasize individualized care and warn
against using MME cutoffs as inflexible rules[1][5].
– **Epidemiologic vs. Clinical Use:** While epidemiologic studies have shown that higher daily MME doses
are associated with increased overdose risk, there is no universally agreed-upon MME threshold that defines
“safe” versus “unsafe” prescribing. The FDA recognizes that MME is useful for population-level risk
assessment but not as a precise clinical dosing tool[5].
Citations:
[1] https://www.cdc.gov/mmwr/volumes/71/rr/rr7103a1.htm
[2] https://www.ncbi.nlm.nih.gov/books/NBK458653/
[3] https://www.fda.gov/media/147152/download
[4] https://www.cdc.gov/mmwr/volumes/65/rr/rr6501e1.htm
[5] https://www.fda.gov/media/150436/download
[6]
https://www.fda.gov/drugs/news-events-human-drugs/morphine-milligram-equivalents-current-applications-and
-knowledge-gaps-research-opportunities-and
[7]
https://www.fda.gov/drugs/drug-safety-and-availability/fda-updates-prescribing-information-all-opioid-pain-me
dicines-provide-additional-guidance-safe-use
[8] https://www.fda.gov/media/126835/download
[9]
https://www.fda.gov/drugs/fda-drug-safety-podcasts/fda-updates-prescribing-information-all-opioid-pain-medici
nes-provide-additional-guidance-safe-use
[10] https://www.healthvermont.gov/sites/default/files/document/reg-prescribing-opioids.pdf
[11] https://www.ncbi.nlm.nih.gov/books/NBK551720/
[12] https://www.ncbi.nlm.nih.gov/books/NBK572085/
[13] https://health.ri.gov/addiction-overdose/safe-opioid-prescribing
[14] https://www.accessdata.fda.gov/drugsatfda_docs/label/2008/019813s033lbl.pdf
[15] https://www.ncbi.nlm.nih.gov/books/NBK458654/
[16] https://mn.gov/dhs/opip/opioid-guidelines/pain-phase/acute-pain.jsp
[17] https://healthandwelfare.idaho.gov/providers/opioid-use-disorder/opioid-prescribing
[18] https://mn.gov/dhs/opip/opioid-guidelines/pain-phase/chronic-pain.jsp
[19]
https://www.fda.gov/drugs/food-and-drug-administration-overdose-prevention-framework/timeline-selected-fda
-activities-and-significant-events-addressing-substance-use-and-overdose
[20] https://www.hca.wa.gov/assets/billers-and-providers/opioid-policy.pdf
—
Answer from Perplexity: pplx.ai/share
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The hyperlink below is just a link to a 557-page report from the WHITE HOUSE on the COVID-19 Crisis. Of course, the highlight of the entire 4 yrs crisis and a copy of the pardon that President Biden gave Anthony Fauci for his contributions to the COVID-19 crisis.
https://www.whitehouse.gov/lab-leak-true-origins-of-covid-19/?utm_source=wh_social_share_button
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https://www.acsh.org/news/2025/04/14/morphine-milligram-equivalents-metric-obscures-mission-49415
Generated by AI
“You can’t manage what you can’t measure.”
While this statement by business sociologist Peter Drucker is certainly true, in some scientific or regulatory instances, it is impossible to measure what you seek to manage. Proxies are measurable and, when strongly correlated with our goal, useful. Proxies can simplify complex problems, allow for performance tracking, and deliver faster feedback. But poorly chosen proxies derail the very goals they’re meant to support.
A Poorly Chosen Proxy
In the opioid wars, Morphine Milligram Equivalents (MMEs) became the proxy of choice. Easily measured, easy to regulate, and track—MMEs appear whenever a prescription is filled. So, it made sense, on the surface, to use MMEs to simplify the goal of reducing opioid prescribing.
Unfortunately, the goal of reducing opioid prescribing is, in fact, a proxy for an even more difficult goal: the reduction of prescription-related substance use disorder.
MMEs, now a proxy for a proxy—lose their strength of correlation and usefulness, succumbing to the proxy’s pitfalls: misalignment, unintended consequences, and oversimplification. More specifically, the use of MMEs in the war on opioid addiction and overdoses has resulted in unintended harm to individuals afflicted with chronic pain, oversimplifying the clinical nuances of addiction allowing bureaucrats to count pills instead of understanding patients.
It is a painful demonstration of Goodhart’s Law,
“When a measure becomes a target, it ceases to be a good measure.”
A new study in JAMA Network Open drives home the disconnect between proxy metrics and meaningful outcomes.
The Law That Capped Judgment
In 2016, New York implemented a limit to the initial prescription of opioids for acute pain to 7 days, stripping any discretion, i.e., clinical judgment, by physicians. The New York law, known as Section 3331, joined 39 other states in state opioid cap laws (SOCLs) aimed at:
The research involving Medicare beneficiaries looked at prescribing behavior before and after implementing New York’s SOCL Section 3331 for individuals undergoing total joint replacement (TJR). As they write,
“Adequate post-TJR pain control is a key marker of successful surgery, and inadequate control is associated with impaired recovery, resulting in delayed or unmet physical therapy milestones, increased health services use, and reduced quality of life.”
California, which had the highest number of Medicare TJRs and no SOCL, served as a control. The primary endpoint was the total MMEs filled after discharge. They considered the first 7 days after surgery and 30- and 90-day intervals consistent with the law and “key clinical practice milestones.” [1]
The patient cohort included 85,000 Medicare beneficiaries undergoing 93,000 total joint replacements, roughly a third being treated before New York’s SOCL implementation. The mean age was 73; 60% were women, and 89% were White.
The Data Speaks
“Overall, our findings suggest that Section 3331 may have achieved its intended objective of reducing opioid prescribing for acute pain in the short-term 7-day post-TJR period.” [emphasis added]
However, that’s where the success story ends. The unstated but actual goal, reducing prolonged opioid exposure, addiction risk, and leftover meds for diversion—remained unmeasured and possibly unmet. Exposure was longer in New York when those later refills are counted. And we have no data on addiction, diversion, or patient satisfaction.
What’s Missing from the Metrics
Most critically, the focus on the proxy, MMEs prescribed, left “meaningful changes in the pain needs of patients, morbidity, or mortality for future research.” The increase in refills after the initial 7 days is ambiguous. Do they suggest the persistence of pain requiring longer treatment or reflect misuse or diversion? Refills tell us nothing about “risky” behavior.
We don’t know—because the measure we chose can’t tell us.
Goodhart’s Law In The Real World
Goodhart’s Law manifests itself in many ways, as this study demonstrates. MMEs are too simple a measure of the complexity of real-world prescribing that is a confluence of practitioner beliefs, institutional protocols, and policy environment. California’s trends in prescribing behavior were nearly identical to New York’s, without the benefit or limitations of SOCL. MMEs fail because they are correlates, not causes. MMEs are a rough measure of opioid exposure, at best, a risk factor among many for substance use disorder.
They are neither a measure of pain management nor relief. MMEs also allow for gaming the system. Prescribers might under-treat pain out of fear—or overprescribe to avoid complaints—neither of which addresses patient well-being. Proxies distort behavior and, as Goodhart suggests, undermine intended outcomes.
Recognizing these pitfalls, one might hope for mitigation strategies. That could include:
Unfortunately, legislation is drawn in blacks and whites, and rarely are clinicians invited to the table. Researchers are equally culpable for using available data rather than more costly, in time and money, bespoke data. These researchers write that “much work remains to restrict opioid prescribing in the later post-TJR period, suggesting there is an opportunity to refine Section 3331 to reduce perioperative prescribing.” This refines the proxy and does little for the clinical outcomes of safe pain management and lowered addiction risk.
Proxy metrics like MMEs were never designed to bear the weight of legislation, yet we keep piling on. In chasing numbers, we lose sight of patients—of pain that goes untreated, of addiction risks that go unmeasured, of policies that solve for optics instead of outcomes.
Real patients suffer when we treat metrics as medicine.
If we want better results, we need better questions, metrics, and a better understanding of what and who we’re actually trying to heal.
[1] Secondary endpoints included MMEs per prescription and day, number of refills and the likelihood of at least one opioid fill, the likelihood of an opioid prescription longer than 7 days, and total opioids prescribed.
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