The Drug Enforcement Agency has published its final rule on HCPs - hydrocodone containing products - which will be rescheduled (from schedule III to schedule II) beginning on October 6.
The two areas that appear to be of greatest concern in the market regarding this move are:
1) The impact on pharmacies which will now be required to handle, store, and dispense these drugs with greater restrictions going forward, undoubtedly increasing costs for pharmacy operations; and
2) The impact on patient access. Will patients in pain still be able to get these drugs?
On the first issue, we should all acknowledge the reality of retail pharmacy operations. This will cause changes and those changes will lead to increased costs. While I would argue the clinical and public health benefits of the rescheduling of HCPs outweigh those costs, I'm not running a retail pharmacy. My hope is that these costs trend down over time as pharmacy operators adapt to the new routines required.
To the second issue regarding patient access, let's keep in mind that a rescheduling of a drug may not necessarily impact prescribing patterns. Yes, schedule II drugs cannot be written for more than a 30 day supply and each prescription requires an office visit. This will inconvenience some patients in chronic pain. That said, there are "work arounds". At the Georgia Workers' Compensation Education Conference here in Atlanta yesterday, I moderated a panel regarding medication usage for the treatment of chronic pain. A suggestion was made that some doctors may just write two 30 days scripts with a "do not fill before" date on the second script. Voila! 60 day supply.
Most troubling, though, is the sentiment I've heard from several workers' compensation professionals that goes something like "if a patient really wants the drug - and they will still want HCPs - they'll jump through whatever hoops necessary to get it." On the one hand, I get it. It's not as if cynicism in our industry doesn't have obvious and ubiquitous roots. On the other hand, we cannot allow patient directed care to dictate appropriate treatment pathways for injured workers. The rescheduling of HCPs should signal to physicians that the drugs are potentially more dangerous than we originally thought. Doctors, not patients, should therefore be engaged in differential decision making. If patients are going to be involved in that decision at all (and they certainly should be), the discussion should surround the significant risks and limited long term benefits of opioid use - not figuring out what hoops they have to jump through to continue getting it.
Bottom line: The rescheduling of HCPs is more symbolic than anything else. After 15 years of debate and discussion, the DEA, FDA, and clinical community have finally decided that virtually all opioid analgesics should be scheduled the same way (on schedule II, indicating high potential for abuse).
But don't expect to see a huge drop in HCP scripts in work comp. Our expectations of what's possible are far too low for that to happen.
On Twitter @PRIUM1
Wednesday, August 27, 2014
Thursday, August 7, 2014
[Another guest post from Dr. Pamella Thomas, PRIUM's Medical Director. Recently, another physician challenged both the science behind ACOEM's 50 mg MED threshold as well as its applicability to chronic pain cases. This was the response from Dr. Thomas.]
Hope all is well.
I am a bit surprised that you would challenge the 50 mg morphine equivalent dose (MED) threshold supported in the updated ACOEM guidelines. We are in a CDC-declared opioid epidemic. People are dying needlessly. It is difficult to dissent against ACOEM’s 50 MED threshold when the reported death rate is 3 to 5 times greater in patients prescribed 50 mg MEDs and above than in patients prescribed 49 mg MEDs and below. For context the current CDC VitalSign report shows that, nationally, 46 opioid overdose deaths occur each day.
Furthermore the ACOEM guidelines are – contrary to your suggestion – both applicable to and directed toward chronic cases. As the most recently updated standards for the practice of occupational medicine, ACOEM further reveals our developing understanding of opioid best-practices. There is simply no credible evidence to support long term opioid use for chronic non-cancer pain. Conversely a Cochrane review demonstrated that back pain patients taking opioids for more than a week, when compared with a similar cohort taking opioids for a week or less, were twice as likely not to return to work within a year. A related review contradicted the practice of escalating doses. High doses of opioids were shown to be no more effective than lower doses of opioids, supporting the intuitive notion that once opioid receptors are saturated, increasing the dose does not yield additionally beneficial results. If you have not yet read the two studies used to confirm the new ACOEM morphine equivalent dose (MED) level, you should.
Another concerning issue that pain management physicians among others are not taking into account? Up to 30% of patients can’t properly metabolize approximately 25% of drugs currently used clinically due to inherent pharmacogenetic deficiencies (Wang et al., 2009). Drugs in this grouping include codeine, tramadol, oxycodone, hydrocodone and many synthetic and semisynthetic opioids which are not adequately metabolized by other CYP450 isoenzymes. As result many patients are building up levels of the parent drug causing cascading effects such as hyperalgesia, which in turn often causes the treating physician to further increase dosage. Dose escalation is often pursued instead of weaning without documenting either improved function or reduced pain.
Following a psychosocial evaluation, most patients feel better once weaning starts in conjunction with pain management and mind-body therapies (e.g. cognitive behavioral therapy, motivational interviewing, etc.). However, only about 4-7% of patients are ever evaluated for these potential treatment options despite prolonged treatment and a history of attenuated improvement. Similarly medically indicated evaluations for dependence and addiction or interventions for smoking cessation are often left unaddressed.
My feeling is that a number of clinicians still practice based on an outdated biomedical model instead of utilizing a growing body of evidence supporting a psychosocial model of pain and its correlation to impairment and disability. It is ignored that psychologically and/or socially distressed people seek medical treatment for psychosocial conditions. Due to this lack of recognition, many psychosocial conditions are being managed through inappropriate modalities and passed off as anatomically diagnosed biomedical pain. These inappropriate modalities (e.g. opioids, surgery, and interventional treatment) share complicit complications and side effects that further exacerbate long term disability and failed syndromes.
Consider that in October 2010, the CDC published a report indicating that over 60% of US children had suffered some form of traumatic abuse prior to the age of 18. These same children grow up and enter the work force. Some of them eventually file claims because of unresolved, unaddressed issues amplified by a work related injury, leaving the worker feeling victimized by a supervisor, a poor work environment, or low wages. Injecting opioid treatment into this psychosocial complexity without addressing the underlying issues leads to long term disability and frequent social isolation due to unsympathetic family, friends, and coworkers.
I hope that this will help clarify why the decision was made that, when people are dying daily, we cannot apologize for taking action to ensure patient safety. While we realize guidelines take time to be updated (MTUS is being rewritten currently), an epidemic exists at this moment which can be controlled by removing the cause.
We do not want to be downstream catching bodies but upstream saving lives.
Thank you for your understanding.
On Twitter @PRIUM1
On Twitter @PRIUM1