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| CMS to make CDC "Opioid Guidelines" policy |
Friday
MARCH 3, 2017
As
stated in my article Count
Down 2016 – CDC Opioid Prescribing Guidelines and Chronic Pain, there are
drastic differences between a policy and a guideline. Is the CDC acting in good
faith? Why are the Centers for Medicare and Medicaid Services (CMS) morphing a
guideline into a policy, potentially putting millions of taxpayers in harm’s
way? They have not been properly represented. Is CMS aware that the CDC
did NOT consult with all stakeholders or do an in-depth literature review or
follow any of the other policy procedures set by our government? My biggest
fear is that the CMS is basing their decisions as though the CDC guidelines are already a policy. They are assuming the statistics they received are unbiased. See Why
should we hold the CDC accountable?
The
following is an excerpt
of an article written by Rick Martin, Guest Columnist for Pain
News Network. You can find his letter here. Please comment to the Center for Medicare and Medicare Services.
Change takes work if
the pain community is going to stop the Centers for Medicare and Medicaid
Services (CMS) from making the CDC’s opioid prescribing guidelines mandatory
for millions of Medicare patients, including a ban on daily doses higher than
90 mg morphine equivalent (see “Medicare Planning to Adopt CDC Opioid Guidelines”).
We don’t
need CMS and the insurance industry dictating what medication a physician can
prescribe for pain or the appropriate amount of medication needed (see"Insurers Behind Medicare's 'Big Brother' Opioid
Policy").
Rick
asks that we share with at least 10 people and ask them to share with ten more.
I decided to share my letter with everyone in my social networks via this blog.
Surely, ten of my many friends will keep the ball rolling. Rick gives his
permission to use
his letter, and you are certainly welcome to use mine.
---Begin---
CMS
at this email address: AdvanceNotice2018@cms.hhs.gov
Subject
line: CMS Disregard for Governmental Standards in Policy and Procedure-Putting
Patients in Harm's Way
To
Whom It May Concern:
Let
the record show that I, Celeste Cooper, oppose the Centers for Medicare and
Medicaid Services’ plan to align its policies with the CDC Guideline for
Prescribing Opioids for Chronic Pain. The “Guidelines” did not go through the
required process for policy development, and many feel they are biased. We as citizens,
taxpayers, and people living with chronic pain were not represented fairly, nor
was ALL the literature reviewed or processes followed that were put in place to
protect consumers from the consequences of prejudice.
“Guidelines”
give physicians and other licensed prescribers the discretion in determining
what is right for their patients. However, your policy as presently drafted
will make the guidelines mandatory for doctors, patients, and pharmacists. And,
what are the provisions for end-of-life and cancer pain?
On
June 1, 2016, Dr. Debra Houry, Director of the CDC’s National Center for Injury
Prevention and Control, wrote the following:
“The
Guideline is a set of voluntary recommendations intended to guide primary care
providers as they work in consultation with their patients to address chronic
pain. Specifically, the Guideline includes a recommendation to taper or reduce
dosage only when patient harm outweighs patient benefit of opioid therapy. The
Guideline is not a rule, regulation, or law. It is not intended to deny access
to opioid pain medication as an option for pain management. It is not intended
to take away physician discretion and decision-making.”
Why
would the Centers for Medicare and Medicaid Services (CMS) try to adopt a
guideline as a policy? This has the potential to put millions of taxpayers in harm’s
way, because they have not been properly represented.
Advocates
have shared their concerns over favoritism in the drafting the CDC Opioid Prescribing Guidelines of
favoritism in
drafting the CDC Opioid Prescribing Guidelines. (See links to reports below.) My
biggest fear is that you, the CMS, are basing your decisions as though the CDC
guidelines are already a policy that has met the standards of law. You are assuming
the statistics reported in the CDC Opioid Prescribing Guidelines are unbiased.
Can
you in good conscience implement a guideline as policy when it has not met the
test set forth by our government, for and by the people?
Sincerely,
Celeste
Cooper, RN, advocate, Medicare person living with chronic pain
Reports:
American
Academy of Pain Management Statement to the CDC on the Opioid Prescribing
Guidelines
Richard
Martin, RPh, U.S. Department of Health and Human Services, June 1, 2016 pdf
https://static1.squarespace.com/static/54d50ceee4b05797b34869cf/t/578e661603596e40a74db59e/1468950040230/Houry+letter.pdf
(accessed thru Pain Network News, CDC:
Opioid Guidelines 'Not a Rule, Regulation or Law'
A
Former Federal Peer Reviewer’s Analysis of the Draft CDC Guidelines, National
Pain Report
Congress
Investigating CDC’s Opioid Guidelines by Pain Network News
Shared
at the Addiction Treatment Forum
Congress
Investigating CDC’s Opioid Guidelines
---End---
BCC:
U.S.
Pain Foundation: contact@uspainfoundation.org
National
Fibromyalgia and Chronic Pain Association info@fmcpaware.org
American
Chronic Pain Association: acpa@theacpa.org
Alliance
for Balanced Pain Management: info@alliancebpm.org
I
also sent a copy to my senators and legislator., which had to be done on their
contact form.
Find
your senator https://www.senate.gov/
Find
your legislator http://www.house.gov/representatives/find/
More
links can be found on my website via http://www.celestecooper.com/advocate.html
In healing,,Celeste
"Adversity is
only an obstacle if we fail to see opportunity."
~ • ~ • ~ • ~ • ~ • ~
Celeste Cooper, RN
Learn
more about Celeste’s books at her website or find
links here on Celeste's
blog.
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