DEA PROPOSED cut in pharmas’ opiate production quotas

Apparently this was buried in a “whole mess” of fed publication on 10/18/2022 and last day to make comments in on Nov 17th and as I write this blog post only 56 comments have been made.  As I read this publication, the DEA statistical analysis of various PDMP shows that <1% of pharma opiates are being diverted… a <1% conclusion is within the margin of error.  It also suggests that the DEA has no interest in abandoning the 2016 CDC opiate dosing guidelines and it seems clearly that they have – internally – made the 90 MME their “line in the sand”… any prescriber providing >90 MME/day of opiates to a pain pt is OUTSIDE what they have determined as the standard of care and best practices and thus ILLEGALLY PROVIDING OPIATES TO A PT.

Below is the comments that I left on this fed publication and I have provided the hyperlink to the site to leave comments.

https://www.federalregister.gov/documents/2022/10/18/2022-22638/proposed-aggregate-production-quotas-for-schedule-i-and-ii-controlled-substances-and-assessment-of#open-comment

I find the proposed reduction of opiate production.. is much like trying to drive a car – only looking into the rear view mirror. A accident is almost assured and there will be people harmed and/or killed. First using the 6 yr old CDC opiate dosing guidelines which has been stated by many as being mis-used and causing many chronic pain pts to be under treated and the new 2022 guidelines that are suppose to give prescribers more latitude in providing appropriate dosing and better pain management to chronic pain pts.
The stated percent of current diversion should be consider statistically within the error of compiling such a statistical outcome. It also ignores that the growth in our population and a certain percent will end up being chronic pain pts.
There are TWO MILLION survivors of vehicular accidents every year, some of those are going to become chronic pain pts, maybe as many as 20%-30%.
Taking in consideration the current volume of illegal immigrants, out population in 2023 may expand 4-6 million. Historically, it is claimed that 20% of our population deal with chronic pain. So by the end of 2023, we could have 2-3 million more chronic pain pts than we have today.
At the very least, the DEA should take a break this year in reducing opiate production quota and see how appropriate prescribing – per the new 2022 CDC guidelines – shakes out.
According to this seizures of illegal fentanyl in fiscal year 2021 was up 134% and according to this in the first nine months of 2022 illegal fentanyl seizures were up 377%
it has been reported that 70K-75K OD/poisoned by illegal fentanyl last year. abt THREE TIMES the number that died from the use/abuse of some opioid. With those numbers, the DEA is concerned about <1% diversion of pharma opiates ?
If the DEA proceed to further cut pharmas’ quotas, it will just validate that the DEA still “living in the past”.. using mis-used CDC guidelines, trying to obtain a unrealistic goal of ZERO pharma opiates while doing little/nothing towards the dramatic escalation of OD/poisoning from illegal fentanyl… and busting prescribers for fabricated reasons… here is a recent outcome of a DEA action on a prescriber’s practice — DEA Suspension of Doctor’s License Leads to Double Suicide https://www.painnewsnetwork.org/stories/2022/11/9/dea-suspension-of-doctors-license-leads-to-suicides
but… all wars have COLLATERAL DAMAGE – RIGHT?

10 Responses

  1. Hello,, I’m one of the patients that are getting my pain meds reduced,, I’m sorry but I didn’t ask for a car hitting me from behind,, while I was stopped, turning left,, the pickup truck in which he was driving,, thinking he was texting and never even saw me,, let alone,, did he hit the brakes, well it wasn’t his vehicle,, it had no insurance,, he had NO LIcense, and a 5 year old in the car,, he was high as a kite and was drinking , he went to jail for 2 days, then he was bailed out, to this day, he’s still on the street,, in and out of the county jail,, may I say,, he still has his legs and can walk,, me I can walk with a cane,, maybe 35 steps,, then I’m in to much pain, and will fall to the ground,, I already had 2 spine surgery’s,, only made everything worse,, have had at least 15-18 spinal injections that did not work at all,, I’ve been to physical therapy a handful of times, I’ve had it all,, please my dr has been decreasing my medicine,, only to make me weaker,, and GET THIS,, He told me,, if I take LESS, the pain will go away,,and I’m like,,,, So all these years,, you have been telling me to take these pills as prescribed,,, that means he knowingly inflickedly all this pain on me,, to where I can NO LONGER WALK,,, on top of all this,,, my back Dr,, gave me a REFERRAL TO GIVE HIM,, and it tells him,, I’ve had everything done,, AND IT CLEARLY SAYS THE ONLY THING THAT WOULD HELP ME IS REGEAM OF MY PAIN MEDS TO BE INCREASED. This dr has more experience and is a very well known sports medicine dr,, my DIEBETIC dr days,, the the pain is causing my blood glucose is always spiked because of it,, my wound dr says it’s from the pain,, and my pain management dr says to decrease,, I’m in and out of the hospital every other month with blood clots with my arteries,,my DIEBETIC wound is 7 x 3,, I have 2 big bags of medical records,, MRI’S AND X-RAYS AND CAT SCANS,, and he wants to decrease me,, PLEASE CAN SOMEONE PLEASE HELP ME,, I’ve been throu more medical that 20 people put together,and also I live by myself,, so u know how hard it is to get in the shower, everyday when it’s to painful to stand on my legs, get in,, get out get dressed and get to appts everyday 40 miles a day,, I would hope someone would contact me from DEA OR CDC OR ANYONE TO HELP ME, I’m getting ready to call a pain med advocate,, then I’m getting a lawyer and seeing him I should not have to deal with all this,, stress is also making my wound worse,, WHAT IS WRONG WITH THE DR,, someone needs to pull his license for making people suffer the way he does, I have an appt on 12/6/22,, I’m hoping he will realize what he has done.. also he has 25 million dollars in Medicare fraud,,, wake up and realize,,MAKE THIS RIGHT, he knows how much I need if my other drs know, I’m tired of living in my small house,, at 59 years old,, I have kids and grandkids,, and I don’t leave my house,, it’s NO LIFE FOR ANYONE. And I’m tired of being in severe pain everyday every second of my life,, sooner or later,, he’s gonna cross the wrong person and he’s gonna find out what pain is,, and how bad people need pain meds,, I can’t cry anymore I have no tears left, can one of u big wigs call me please at 609-425-6883, this is only half of my existing problems, my dr was surprised to see that I can still walk,, ALLl of my discs in my back are collapsing ,, they said there is NOTHING THEY CAN DO,, I sit here and cry because I can’t even stand up long enough to cook dinner,, the other drs said there is something wrong,, for him to be pain management and tell people to take aspirin, I trued to talk to him but,, he really needs to give up his license, thanks,, I’m giving up ,, I can not take no more pain,, I’m done,, hope he feels like a man now,

    • Also he told me he was having it put in my medical side notes that no dr hold ever up my pain meds, who does this 4 ft 8 dr think he is,, seriously pain management that prescribes nothing more than a little asperian,,How can anyone listen to this man, without knocking him out,, I wish him nothing more than I pain I live with everyday of my life. How could anyone that signs an oath, to keep his patients as comfortable as he can,, then turn around,, and pull this,, I’m sorry something is not right with him,, maybe make him have to take another test or something,, and cut his fingers off one by one,, and see how he likes pain,, then cut and arm up Dr then a leg while he’s doing n the office,, because this man does not know,,what pain is,, when I was admitted to shore hospital for a blood clot and DIEBETIC nerve pain ( it feels like you put your whole hand down on a burner of a gas grill on high and make him keep it there for 2 hours,let’s see if he likes it,, that’s what my pain was like,, the last time I was admitted,, I was screaming and crying so bad,,that’s pain,,they could not get me out of pain,, until they called my previous drs to see what mixture would put me under,, that’s pain baby,, anyway you want to challenge it,, I do not think anybody could deal with what I’ve been throu,, walk one day In my shoes,, then let’s see what he thinks about pain meds,, It’s time to wake up and smell the roses,, sorry it’s how I feel.

  2. Hi Steve. I read how the DEA comes up with their mysterious ways of determining how much opiates are allowed to be manufactured. I need a number, a % of the cut and WHY they are limiting the manufacturing. Were you, or anyone else able to decipher the proposed cut? As I tell people on my facebook posts to preface an article about pain/opioids/lack of proper pain treatment/etc, “YOU ARE ONE ACCIDENT AWAY FROM BEING A CHRONIC PAIN PATIENT”. No one reads the articles. Anyway, if the diversion rate is less than 1%, why cut production? We all know RX medications are NOT the problem. The DEA needs to be reined in. They are not medical doctors and they just love that 90MME written in stone from the 2016 Guidelines.

    • In reading the proposal… I keep “hearing” Pelosi and Obamacare – “.. you will have to let us pass it … so you can read it…”

    • As long as the rate of addiction continues to rise, the production will be cut. As I’ve warned, my prediction is that by 2030 there will be no opioids in America except illegal ones. And the addiction rate will continue to rise as long as people don’t understand the real cause.

      • I look for the cartel to hire someone to teach them how to make standardized fentanyl tabs… and they go into competition with the pharmas. Someone sent me today that the cartels has gotten into black market a “two drug” abortion kit.. sooner or later… the cartel will figure out that there is money to be made

  3. I’m no clairvoyent or crystal ball reader, but I’ve been warning people that by 2030 there will be no opioids. That’s because the real cause of addiction (that I know and teach BTW) is being ignored so opioids can be blamed. The rate of addiction is now doubling every 9 years, and over the next 5 years it will increase to every 4 years. As addiction increases, opioids will be blamed more, unitl there are none. People just won’t learn what will reverse this, though. I’ve had 25 people show up to learn over the last 3 sessions. That is pitiful. So, oh well, the suffering will get worse. Maybe someday, if I haven’t given up, people will learn.

    • you are probably correct… the gap between reality of pharma opiate use & abuse the the DEA’s agenda and perception… is probably wider and deeper than the Grand Canyon. In there most recent proposal to cut pharma opiate production quota… it appears that they are going to stick with the CDC 2016 guidelines and even though their own statistics of abuse of the pharma’s opiates are within the margin of error, but it seem – at least to me – that their goal is to get to ZERO abuse.. For 2022, the DEA did not even come close to the population’s need for ADD/ADHD meds… right now we have a major/dramatic shortage of those meds and I have read that some pts are going without their necessary medications for a couple of months at a time. We are dealing with the CSA that is under the control of the DOJ/DEA… who have “hot & cold running attorneys”.. The most recent ILLEGAL EO issued by Pres Biden – giving money to pay down college loans… what happened… not a bunch of emails, letters, phone calls to the WH… many state AG’s… file lawsuits having the EO declared as ILLEGAL. There has been many similar incidents since Biden came to office and each time the edicts and actions of many in this administration were taken to court and declared illegal/unconstitutional.

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