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”.
Filed under: General Problems
I dunno I’m on the fence. We must consider that PROP is not in their core expert group and Thomas Frieden is not the CDC Director this time around. Why even bother with a revision if there were not pressure to do so. I doubt the pressure is to lower the MME. PROP’s letter seems to want the CDC to leave things “as is”. CDC, was it Debbie Dowell that explicitly said their GL has been misapplied. They were t meant to be hard fast rules.Why would she state that if it were not true?
I just don’t want to believe that things can get any worse. If they do, we mine as well just throw the towel in and say we are all addicts to obtain unlimited Methadone and/or Suboxone. Certainly better than nothing.
We don’t know how many people die either from suboxone. Doctors know people have certain genes should never be given suboxone. They also know if you have had a severe back problem or head problems like migraines, hydrocephalus, Spina Bifida it shou never be given. The test only costs 100.00 and should be given to each patient being put on Suboxone. It killed my daughter, so far I haven’t found a attorney to help with a lawsuit. Watch if not in our lifetime but soon I believe there will be a major lawsuit. What can we do? CDC needs to be sued by doctors, families of loved ones that are now passed because of restrictions on opiates. Oh where do we start!!
Steve,
Your thoughts on the revised guidelines closely match mine. The only reason the CDC is asking for comments this time around is to do a CYA. They didn’t ask for comments with the initial guidelines and they got burned for it. So, with the proposed new revised guidelines, they are providing for an official comment period.
But, the CDC will probably not give any/much weight to those comments. Why? Because the CDC has been receiving a massive number of comments on its original guidelines since before their release, and those comments from patients and doctors were ignored. So, why would the CDC suddenly start paying attention to the comments received during the recent comment period? My belief is they won’t. The invitation to comment is nothing more than a “smoke screen”.
if it happens the way you suggested we will either have mass suicides or mass murders by the people in pain who feel they have nothing left to loose. They will be making the second biggest mistake of their lives,
The first being having listened to that Con Man, psychiatrist, who should
Not have anything to do with pain meds, Andrew Kolodny. Who should rot in hell for all the deaths and pain he is responsible for.
What an amazingly effective plot. There was even money at the end of it. The FDA, HHS and even Doctors became perfectly mute, if not complicit, and interference from millions of complaining pain patients had not one atom of impact what so ever.
Well Steve Your spot on again!! And as long as that creep KOLONDY keeps sneaking his way onto boards like the CDC he will get his way with banning pain medication in favor of his drug of choice SUBOXONE. And with that he will lead all the “addicts” into his rehab clinics,that if he still owns he gets a piece of that pie too. This guy is the definition of a FRAUD!! I dont no who he paid off to become an “expert” but I have as much experience as he does in pain expertise. He is the new BERNIE MADOFF ! Only in medicine. How long before the idiots in charge realize that?
And you are correct. Once I lose my pain medication I will look to the streets an take my chance with the poison. Thats what they want. I have no choice I cant an I will not live with the pain I get when not on pain medicine!