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Generally sensible @JAMA_current piece, but several key elements not rooted in evidence, missed opps for @DrFrieden @andrewkolodny #thread
1/x Do need better surveillance on SUD. But "newly filled prescriptions for >30d" is not a marker for "addiction." Frankly puzzled by this 
2/x Using PDMPs as a surveillance tool for SUD is fraught bc 1. misses pp who access opioids on black mrkt, 2. raises major privacy concerns
3/x "Interdiction-->drug more expensive-->reduced use" logic model for heroin and fentanyl has been tested. It has failed. This is alt-facts
4/x Frankly deeply disappointed that @JAMA_current review process allowed this unsupported statement, Citations are simply not inapplicable
5/x SUD-affected pts should receive SUD care, as primary care. Idea that gov't officials should insert themselves through PDMPs is puzzling
6/x Was undecided about 42 CFR part 2 until recent OR & UT PDMP cases extinguished any meaningful protection of PDMP data from fed access
7/x This proposal would mean that DEA, other fed law enforcement could get data about ppl seeking drug treatment w NO judicial oversight.
8/x In fact, 42 CFR part 2, HIPAA, or other law should be EXPANDED to shield PDMP data from unfettered law enforcement access (state & fed)
9/ Removing barriers, improving incentives to scale up #bupe access in primary care settings is an unequivocal YES. Cannot come too soon
10/ Harm reduction through syringe and naloxone access is unequivocal YES. Wish much more was said on this (eg not clear why SCFs ignored)
11. How is proposal to take high dose Rx opioids off market "Treatment and Harm Reduction"? Very few pts take these Rx, mostly palliative
12/x Today's OD crisis driven by black market drugs. Yet 7/10 steps proposed focus on Rx drug supply. Missed, continue missing the boat /fin
