1/We urge patients and families affected by pain to submit comments to the @CDCgov federal docket by midnight EDT. And I will summarize key points from my 10-page submission with @AJ_Gordon & @AjayManhapra federalregister.gov/documents/2020… 
2/We are aware @CDCgov is considering a Opioid Prescribing Guideline revision (we would like to help)- we didn’t see the 2016 document as terribly problematic on its merits. But in 4 years we do understand parts of what did go wrong in the care of patients with severe pain..
3/ A challenge for the 2016 guideline on “opioid prescribing for pain” was it shaped pain care without close linkage to the IASP scientific framework for understanding chronic pain & its impacts.Weak connection to pain science made simplified, harmful misapplication seem natural
4/3 new reviews of pain treatments by @AHRQNews raise the same concern. Modest mean benefits for any pain treatment don’t mean that “nothing is ever better than anything else, ever!” The framework for chronic pain assessment and care is not so simplistic
5/the focus on #opioid dose >90 MME as the key point of leverage for safety misfired, despite a fair original concern on dose escalation. But here’s the science: There is no sound literature to show that reduction in prescribed dose confers reduction in risk. 😐
6/We cite 10 studies for our view that, in patients on Rx opioids, overdose events emerge from a constellation of risks, including instability of the patient’s life, in the care relationships, and instability of the dose (& yeah, the dose). Forced dose reductions are risky
7/(And yes we do accept a priori that a systems-level measure showing LOTS OF patients at very high dose should lead to careful review as to whether pain services are optimally configured)
8/Finally the 3rd point to @CDCgov is that any future effort to alter or influence pain care MUST monitor & mitigate how it is implemented far more robustly (can they really do that?)
9/Tragically, the concept of enforceable opioid dose limits, without precautions, is now built into laws, into quality metrics, @CMSGov 5-Star ratings, and this: HHS Office of the Inspector General’s collaboration with law enforcement for purpose of targeting investigations
10/Because misapplication of Guidelines has been tragic, we”urge a more robust system to evaluate how it is applied &to remediate harmful misapplication. The inclusion of PATIENTS and FAMILIES as part of that system would greatly strengthen such efforts.”(& we’d like to help too)
11/A full copy of our response to the CDC docket is also posted online here (please let me know if there is any trouble accessing it) medium.com/@StefanKertesz…
