Reminder: Comments Due Monday for CDC’s Draft Updated Opioid Guideline: Information and How to Take Action

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On February 10, the Centers for Disease Control and Prevention (CDC) released its draft updated Clinical Practice Guideline for Prescribing Opioids. This update is much broader than the 2016 Guideline. It applies to all types of providers except inpatient (hospital) care and to all types of pain – acute, subacute, and chronic.

• Federal Register Announcement
• Docket
• Full proposed guideline

The draft updated Guideline is a significant improvement over the 2016 Guideline. It emphasizes individualized treatment and recognizes the importance of treating pain. It also makes clear that the Guideline is not intended to be applied as inflexible standards across patients or systems. And importantly, it acknowledges the harm that has resulted from the 2016 Guideline and makes specific changes to address it, abandoning strict day and dose limits and cautioning against rapid tapers and abrupt discontinuation of opioid medications.

There is a lot of good in this document, and that is a direct result of years of advocacy! Now we need to ensure these improvements make it into the final updated Guideline. We also need to bring our continued concerns to their attention and call for changes in the final document, and we need to ensure they take the necessary steps to undo the significant harm that resulted from the 2016 Guideline.

We urge you to submit comments by the CDC’s deadline of April 11, 2022. We also encourage you to speak with your Members of Congress about the damaging impact that the 2016 Guideline had on people with pain. This input is essential to make the CDC authors and policymakers understand how urgent this issue is to people with pain, and to communicate the specific changes we need them to make before the rule is finalized.

Take Action!

This new Guideline is a draft. The CDC is accepting comments through April 11, 2022. The CDC must review and consider all the comments they receive as they finalize the Guideline, so we encourage you to share your thoughts and experiences! Based on the comments they receive, the CDC will make edits to their current draft to develop the final Guideline. This final Guideline will replace the 2016 Guideline.

We dug into the 200+ page rule and created some guidance.

• Summary of changes and our areas of concern
• Direct comparison of the 12 recommendations in each version
• Background information about the 2016 Guideline and what led to this update

It is also helpful to bring your stories and concerns to the attention of your Senators and Representatives in Congress.

Instructions for Submitting Comments

Comments must be submitted by April 11, 2022 at 11:59 p.m. All submissions must include the agency name (Centers for Disease Control and Prevention) and Docket Number (Docket No. CDC-2022-0024). Note: All relevant comments will be posted, without change, to regulations.gov, including any personal information provided.

You may submit in any of the following ways:

• Regulations.gov: You may submit electronic comments or go to regulations.gov and search for the Docket ID number CDC-2022-0024. Click on “Comment Now” and you can type your comments into the comment box or upload a document.
• Federal Register: You may submit electronic comments or go to federalregister.gov and search for CDC-2022-0024. Click on “Submit a formal comment” and you can type comments in the comment box or upload a document.
• Mail: You can mail your comments to: National Center for Injury Prevention and Control, Centers for Disease Control and Prevention / 4770 Buford Highway NE / Mailstop S106-9 / Atlanta, GA 30341 / Attn: Docket No. CDC-2022-0024.

Comment Guidance

Comments should express your views on the updated guideline. You can also share your experience related to the 2016 CDC Guideline or accessing treatment for your pain in general. Below are some tips and sample talking points, but you are not limited to comments about these points. Remember: All relevant comments will be posted, without change, to regulations.gov, including any personal information provided.

Tips for submitting comments and sample talking points:

• Introduce yourself: who you are, where you live.
• Talk about the things you like in the updated Guideline, and why those changes are important.
• Talk about the changes you don’t like, and what you’d like to see instead.
• Talk about the harms that have occurred as a result of the 2016 Guideline, and whether you feel this update will address them.
• Talk about your personal experiences. (For example: Did your doctor taper you down or off your medications? Did your doctor abandon you? Did your insurance refuse to cover your opioid prescription, or did your pharmacy refuse to fill it?)
• Be brief but specific. If you feel comfortable, mention your diagnoses, how your medication helped you to engage in life activity, and what activities were prevented when you lost access, if you did. (For example: “I have MS. With medication, I was able to garden, cook for my family, and even travel. After my medication was denied, I am bedridden at home.”)
• Talk about things you like or dislike about the process the CDC used to update the Guideline. (For example: Did you unsuccessfully try to participate in their public meetings? Did you have a difficult time trying to find information about how to provide input?)
• Talk about the other things you do to manage your pain and the role opioids play in your pain management plan.

Further Information

The CDC has provided a contact person, Arlene I. Greenspan, for those needing further information. Ms. Greenspan can be reached at [email protected] or 770-488-4696.

Note: CDC does not accept formal comments about the Guideline by email. Comments must be submitted by one of the methods above.

Instructions for contacting your Members of Congress

• Call your Members of Congress. Call the Capitol Switchboard at (202) 224-3121 (voice) or (202) 224-3091 (TTY). Ask to be connected to your Senators or Representative.
• Write to your Members of Congress. You can find your Senators’ contact forms at senate.gov and your Representative’s contact form at house.gov/representatives.
• You can use Resistbot to turn texts into faxes, mail, or hand-delivered letters by texting “RESIST” to 50409 and following their instructions.