Here are my comments to the CDC on their new proposed opiate dosing guidelines

This is the most polite and documented way to tell CDC to just STICK IT WHERE THE SUN DOESN’T SHINE. They plainly state in their proposed GUIDELINES are VOLUNTARY, NOT MANDATORY – doesn’t that basically say that they really don’t have the statutory authority to create & publish such GUIDELINES and NO AUTHORITY TO ENFORCE THE GUIDELINES ?

They are just throwing them out there… to make the chronic pain community that they are making changes – anyone ever heard of “feel good ” laws/rules/regulations ?

This is just more CRAP from the CDC for other entities to misread, misinterpret and create more policies and procedures that can cause the community more harm.

If one looks at the five authors of this proposal – Dr Chou is back, and the other three work for the CDC mostly in addiction. I was always told … don’t ask a surgeon for their opinion about your particular health issues unless you want to be “cut open” for some INVASIVE PROCEDURE… so if you ask someone that deals mostly with addiction…  guess what you get ?

Yes, the limit of 90 MME’s is now gone, but they only put one MME figure in this proposal – FIFTY MME’S and all too many various entities will see that and target that as a arbitrary daily limit.

Did anyone read the following… to me it suggests that, my money is on the fact that the proposed guidelines will be accepted and published without ONE WORD changed.


  • Read and understand the regulatory document you are commenting on
  • Feel free to reach out to the agency with questions
  • Be concise but support your claims
  • Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted
  • Address trade-offs and opposing views in your comment
  • There is no minimum or maximum length for an effective comment
  • The comment process is not a vote – one well supported comment is often more influential than a thousand form letters

CDC Clinical Practice Guideline for Prescribing Opioids–United States, 2022

My comments and opinions, are based from my experiences of nearly 52 yrs as a licensed pharmacist, and married to a woman who has been a intractable chronic pain pts for some 30+ yrs and who personally is dealing with activity induced high intensity pain. I advocate for chronic pain pts and over the last decade I have communicated with tens of thousands of pts.

The CDC needs to plainly state that it is revoking/rescinding the 2016 opiate dosing guidelines and discard this proposed opiate dosing guidelines and put out a statement that any entity that created laws/rules/regulations/policies and procedures that used the CDC 2016 opiate dosing guidelines should be rescinded, revoked, repealed and/or reversed.

Because they were only guidelines, that were based on faulty studies and conclusions and anything created from those guidelines are – at best – of questionable quality.

The 2016 guidelines gave too many well meaning bureaucrats, politicians and executives in various large healthcare corporations, but with little/no medical background to become “middlemen” in the fabricated war on pharma opiates and create their own version(s) of trying to restrict/restrain pharma opiates from being prescribed to legit chronic pain pts.

The 2022 proposed guidelines mentions MME – TEN TIMES – MME’s are inaccurate and antiquated process that were used in the 80’s – or earlier – when opiate rotations were in vogue – when it was perceived that a pt had developed a tolerance to the medication.

These opiate equivalents were developed by using opiate naive pts with acute pain induced mechanically (heat or cold) and given a SINGLE DOSE of a opiate. Those resulting outcomes, have little/no relationship to treating chronic pain. Since this study was based on the OBJECTIVE FEELINGS of pts, with unknown different rates of opiate metabolism because CYP-450 opiate metabolism tests were yet to be discovered. They are CRUDE ESTIMATES AT BEST and the footnotes of most all MME conversion programs will plainly state that.

I did a word scan of the 211 pages and searched for CYP-450, PGx, Pharmacogenomics and did not find one mention of these very important DNA testing to determine the opiate metabolism of a individual pt. Without at least one of these DNA tests being done on a chronic pain pt – especially a pt that is labeled as a intractable chronic pain pt – any practitioner attempting to provide adequate pain management using opiates, is IMO, still practicing medicine like was done in the mid-20th century.

The CDC – and all these meddling middlemen – need to get out of the practice of medicine and leave the practice of medicine to the FDA and the various state Medical Licensing Boards.

Since the 2016 guidelines were released, I can’t count all the pts that have told me that they have had their pain meds reduced – or cut entirely – have become bed/chair/house confined. Living/existing in a torturous level of pain, their blood pressure is in stroke range and even taking up to 4 different BP meds .. Does not reduce their BP back to a normal range. Pt that have taken too many NSAID’s and/or Acetaminophen and end up having liver or kidney failure. (Graphic attached) Their unmanageable high blood pressure, has caused eye damage, kidney damage, a stroke, heart attack, committed suicide or died prematurely from the complications of their comorbidity issues from under/untreated pain… (chart attached) . And everyone involved, gets to “wash their hands clean” because their death certificate read “natural causes”

I have attached two different charts showing OD’s starting after the Decade of Pain Law was not renewed in 2010. One chart shows the OD’s from individual legal and illegal drugs and a second one shows the number of total OD’s from all opiates and I have marked on each chart when the 2016 CDC guidelines started and when the current administration opened our SW border. Both show a dramatic increase in OD’s from illegal substances and recently the CDC or DEA stated that 75% of OD’s involved a illegal Fentanyl analog. Regional variations have been stated to be between 73% to 87% illegal Fentanyl analog involvement.

It would appear that the CDC in stating that this proposal is VOLUNTARY, NOT MANDATORY, GUIDELINES appears to be admitting that they have NO ENFORCEMENT POWER over these guidelines and may not even have statutory authority to even create and publish them.

The CDC needs to WITHDRAW this proposal, withdraw, rescind, revoke the 2016 guidelines and get out of the business of the practice of medicine and quit putting out “cook book recipes” in how to treat subjective disease(s), that has no means of measuring the intensity of the disease on the pt’s QOL.

6 Responses

  1. Thank you Steve for your thoughtful commentary on this topic. I live with chronic pain and have recently been made to stop my medication as a result of my doctor closing his practice and not having any doctor willing to help me with medication.

  2. Spot on Steve, thank you.

  3. Excellent advice Steve. I do have a question, I thought there were five involved in writing this? Did one drop out? I am seeing too many pain patients who haven’t read the newest CDC Draft and for some the reasons are valid. I told one group if you haven’t read it then don’t comment on, just tell their individual story. If people don’t read it, yes it is long, then if the comment is based on someone else’s thoughts, they will come across as sounding, well, like a fool. Don’t write “I heard it’s bad” explain why it’s bad. I recommended reading maybe 15-20 pages a day if it’s overwhelming, then take notes, it will break the 211 page document into something anyone can read and understand. I fear it’s going to be interpreted by physicians and other prescribers just like the 2016 guidelines, incorrectly and the way this 2022 Draft is written you can bet it will be a repeat of 2016, only worse, at our expense, the pain community and those who care for those in pain. Once again we lose out. Bottom line, we are screwed.

  4. That’s utterly terrifying. It is refreshing to hear someone speak on it that actually KNOWS and has personal experience with the issue tospeak out for the chronic pain patients for a change. Thank you sir!

  5. Thanks Steve. Your very first remarks are spot on about the authority to even advice on this subject is spot on. How can this be changed? My biggest fear is drs won’t get the message. Since 2016 they have been so ingrained in this mess they will be too afraid to change. Too many jail sentences for unwarranted abuse etc. Sounds good but just more BS.

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