Wednesday, September 16, 2015

CDC Opioid Guidelines: Poor Process for Public Participation

The CDC held a public comment webinar on a set of 12 proposed opioid prescribing guidelines.  I bet you'd like to know what those 12 recommendations are, right?  I wish I could tell you.  Here's how the webinar went:

The recommendations were not (and will not be) published.  Therefore, they cannot be circulated to anyone not able to join the webinar.  I tried to take good notes, but I didn't catch the recommendations with precision (and it's clear CDC is aiming for precision in its language).  Because I can't share them exactly as written, I'm not going to paraphrase from my notes.

But the webinar was recorded, right?  Yes, it was.  But "for archive purposes only."  The webinar recording will not be made available to the public.

No one could ask questions.  We were reminded several times that the webinar presenters couldn't answer questions.  We could only make comments.  To which there were, of course, no responses.

About 30 minutes in, there were technical difficulties and we had to start over.


If this is how the Centers for Disease Control and Prevention is going to handle the process of addressing the largest man-made epidemic in history, we're in trouble.  No dialogue, no exchange of ideas, no questions.  This webinar was about "checking a box" so CDC could say they solicited public comment - this was NOT about actually getting valuable feedback. 

A few observations I did make on the recommendations:

  • It's not clear whether these recommendations are useful for those patients already on chronic opioid therapy.  
  • There's no explicit discussion about informed consent or pain management agreements.  
  • CDC is suggesting "additional precautions" should be taken above 50 mg MED and dosages above 90 mg MED should be avoided.  What are those "additional precautions"?  They don't say.  
  • CDC appears to be suggesting naloxone should be considered for any long term opioid patient. This is going to be expensive.  
  • There's no discussion of weaning or tapering opioid (or polypharmacy) regimens.  
  • These guidelines are pointed in the right direction, but CDC's attempt at specificity has actually led to ambiguity.  Nearly every recommendation leaves several, critical open questions.  
  • This process is moving fast: CDC plans to submit these recommendations to HHS in early November and will be published in January.  
Here's my one comment:

Dear CDC: 
Make these recommendations publicly available, in written form, so doctors, patients, and other stakeholders can study them and offer you informed comment.  

On Twitter @PRIUM1

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