Pain Management Task Force Draft Report
2019-02-01 2019-01-24 2019-01-23 2019-01-23 2019-01-23 2019-03-04 2019-03-04 2019-03-04 2019-03-04 2019-03-04
HHS-OS-2018-0027-0415 HHS-OS-2018-0027-0357 HHS-OS-2018-0027-0312 HHS-OS-2018-0027-0313 HHS-OS-2018-0027-0321 HHS-OS-2018-0027-1725 HHS-OS-2018-0027-1738 HHS-OS-2018-0027-1751 HHS-OS-2018-0027-1693 HHS-OS-2018-0027-1699
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https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-0415 https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-0357 https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-0312 https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-0313 https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-0321 https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-1725 https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-1738 https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-1751 https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-1693 https://api.regulations.gov/v4/comments/HHS-OS-2018-0027-1699
Norri Timothy Stephanie Christine Ling Jennifer R Sue Anonymous Richard
Collier Fitzpatrick Lobignat M Zheng Andrews Haynes Nelson Anonymous Stewart
Chiropractic needs to be included rather than dismissed as a modality as this report indicates I have chronic pain due to nerves damaged in a surgery for 5 years now.  I tried every conceivable alternative treatment, yoga, meditation, acupuncture, CBD, and THC, and on and on.  They did not work    Then I tried Tylenol and after 3 days it  made me sick.  Then I tried Ibuprofen, which helped a bit but it injured my stomach and I had to stop taking it.  I tried some other NSAIDs, but they did not help much. Finally I was prescribed hydrocodone.  7.5 mgs twice a day and it works.  Nothing else does.  I have had 3 surgeries trying to fix the nerve, nothing is fixed yet and thank God for hydrocodone. I read where some study found tylenol and or advil was found to work as well as opioids for post operative pain.  I have never heard anything so ridiculous in my life.You should know, my brothers Doctor is scared to death to prescribe any type of opioid. He thinks the guidelines are the law. I am sure by now you have gotten enough data to see the guidelines have not reduced opioid deaths but just increased fentanyl deaths.This lady in our community due to the guidelines had her pain pills discontinued.  She killed herself...https://www.pressdemocrat.com/news/8639079-181/charge-dismissed-against-petaluma-man.I dont know how you can fix this mess you have made, but it has caused way too much suffering. I am a 64 year old female chronic pain patient suffering from Spondylolisthesis (having  had a failed back surgery), Fibromyalgia and Osteoarthritis. I was forced to leave my lucrative professional career and go on SS Disability about 10 years ago.My initial pain management physician,  treated me with many epidural steroid shots and pain medication until I was suddenly unable to reach him and his staff after countless calls for an appointment and to renew my medication. I was forced to go to the ER because of my intolerable pain, after which I went to his office in person. He burst out of his office and screamed out loud to a packed waiting room that I was a desperate drug addict seeking drugs. I was stunned and mortified.I found another pain management specialist under which I endured more epidural steroids. As a type 1 diabetic these raised my blood sugar levels to extremely high levels and had me in danger of hyperglycemic coma. They also caused severe epidural headaches.  He then had me try innumerable medications including Gabapentin, muscle relaxers, low dose Naltrexone, and others. These provided zero pain relief or gave me intolerable side effects to include severe dizziness. He then coerced me in to having a spinal cord stimulator implanted in my body. This failed to relieve my pain and it was removed.  I then had a stimulator from another manufacturer implanted. This did help with my pain but did not eliminate the need for further relief in order to function, so he continued to provide some pain medication.He then tapered my pain medication to half of what it had been. He told me it was because the government was cracking down on Doctors, and that several of his colleagues had lost their licenses. He was afraid to prescribe. His pain management group now became a spine care center. He suggested I get a second spinal cord stimulator implanted in another area of my back.He now tells me the practice no longer prescribes pain medication - even for cancer patients.I now receive a fraction of the pain medication which allowed me to live a tolerable life. I can no longer do any housework. The time I can spend on my feet or walking is very limited. I cannot have a normal social life or participate in many activities.My life has been forever altered by pain which could easily be controlled by a safe, inexpensive pain medication solution that I am now being denied. The opioid deaths in this country are happening to drug addicts deciding to take illegal, deadly street drugs - not patients like myself in a controlled physician environment. The millions like me in this country, have been thrust in to a life of severe suffering. Some so bad,  that suicides from intolerable pain are skyrocketing.We ask that legitimate pain patients not be punished for the actions of drug addicts, and that our Doctors be allowed, without fear, to treat us.Thank you for your attention to this urgent human crisis. Incurable Chronic Pain Condition. Treated over many years, started with medication therapies, invasive procedures, Brain Surgery, Gamma- knife Radiation and eventual disability 10 years before retirement age.I worked through all the complications of every medicine, every procedure, surgery, but the Gamma-knife was my Achilles heel.I have tried everything recommended and suggested in the Trigeminal Neuralgia treatment handbooks for patients which are acknowledged by the leading specialists in the field. Patient Advocacy included.Its been long, hard and painful.I just want to be able to have some kind of life which even with OPIOIDS is limited.My latest attempt is a small portable ultrasound device I had to petition my doctor for over two years to be able to try. Oh! Yes! And on my own dime as any alternative therapy I tried was out of pocket as well.This is the shame of it all. Pain medications work to alleviate pain. All the alternative treatments cost exorbitant amounts of money that have no coverage.Until the Insurance Industry opens its pockets and that includes Medicaid and Medicare Im afraid alternative medicine will remain out of reach for most Chronic Pain Patients.I even read in these comments a plug for massage therapy? Whos kidding who? Massage therapy may assist some pain patients but many of us cant get out of our house to get there....... Or have the assistance we need to participate in the recommended alternative therapies. What I see happening is now the one item OPIOIDS is now being trashed or being set up as a non-viable payment reimbursement classification.I myself just changed my insurance provider and it created nothing but problems for my doctor, pharmacy and especially me!I left one pharmacy I tried due to the insurance company I had, yes Atena and CVS.Aetna was sold and CVS bought. CVS pharmacy in Chicago made up their own rules as to how they would dole out prescription narcotics outside of the law. I called and emailed the CVS corporate in Rhode Island. I did receive a call back from a corporate pharmacist telling me the CVS pharmacy was not following the law. I couldnt run away fast enough!My doctor who I respect who I discuss my interactions with has shared that pharmacists are totally ignoring prescriptions.I myself had a pharmacist of course from the same CVS write a belligerent note on my prescription bottle highlighted with bright pink highlighter. I thought the note was from my doctor, after speaking with her and her office, found out it was placed on my script bottle from the pharmacist?Who does that? Get in the middle of a 20 year relationship with a patient and a doctor?Its important you know I want to be out of pain, Ive had enough, I didnt ask for it and Ive tried everything experts have recommended and had to save up money for the privilege of doing it.So after you tackle laws on OPIOIDS. You could tackle payment reimbursement parameters for payment related to alternative treatment.All I see happening is the government does not want to pay for legal prescription therapy that is reimbursed.How about the study committee for ethical insurance reimbursement for all the marvelous alternative treatments that we are supposed to take advantage of and have access to use?If they work as well why arent they paid at 80/20 long term with no time limits applied?All you are doing is setting up a stampede to the nations emergency rooms for people in pain.Or the black market for lethal doses of drugs to stop the pain.Do you not understand most of us live on the edge as it is! Acupuncture is an effective and safe on the pain management. Hopefully it will be covered by Medicare. Dear Dr. Singh,RE: Docket ID# HHS-OS-2018-0027As a Certified Registered Nurse Anesthetist (CRNA), Im writing today to express my concerns with the Department of Health and Human Services Pain Management Best Practices Inter-Agency Task force draft report titled Pain Management Best Practices: Updates, Gaps, Inconsistencies, and Recommendations. I am supportive of recommendation 1c under section 3.3.3 (Workforce), which recommends expanding the availability of non-physician pain specialists. However, this recommendation is contradicted by another recommendation in the report for credentialing and training requirements that limit the pathways available for non-physician practitioners, such as CRNAs, to be able to provide interventional pain procedures. CRNAs are qualified pain practitioners who have the training and experience to provide high-quality treatments to patients suffering from a wide range of acute and chronic pain conditions, in a variety of practice settings. CRNAs who provide pain management do so in accordance with our professional scope of practice, federal and state law, and facility policy.As part of our educational preparation, CRNAs are required to learn and demonstrate competence in the management of pain. And, the standards issued by the Council on Accreditation mandate that nurse anesthesia programs provide content in, but not limited to, anatomy, physiology, pathophysiology, pharmacology, and acute and chronic pain management. These standards also require that student nurse anesthetists obtain clinical experiences in regional anesthetic techniques (i.e., spinal, epidural, and peripheral nerve blocks). As such, CRNAs possess the necessary knowledge and skills to employ therapeutic, physiological, pharmacological, interventional, and psychological modalities in the management and treatment of acute and chronic pain. Additionally, the Centers for Medicare and Medicaid Services (CMS) recognizes the ability of CRNAs to perform and bill for acute and chronic pain management services. The U.S. House of Representatives also recognizes the ability of CRNAs to perform pain management services and urged the Department of Defense to make funds available for CRNAs to pursue existing pain management fellowships. CRNAs and other non-physician providers play an integral role in providing these services, which positively impact several areas, including patient safety, reducing prescription drug abuse, and cost savings; and should be recognized in the report.I strongly urge HHS and the Task Force not to adopt these recommendations as drafted and request that the credentialing and training requirements be amended to be inclusive of all types of practitioners and their educational pathways. Sincerely,Jennifer Andrews1240 Golf Crest CtSpringfield, IL 62707-7601   Dear Dr. Singh,RE: Docket ID# HHS-OS-2018-0027As a Certified Registered Nurse Anesthetist (CRNA), Im writing today to express my concerns with the Department of Health and Human Services Pain Management Best Practices Inter-Agency Task force draft report titled Pain Management Best Practices: Updates, Gaps, Inconsistencies, and Recommendations. I am supportive of recommendation 1c under section 3.3.3 (Workforce), which recommends expanding the availability of non-physician pain specialists. However, this recommendation is contradicted by another recommendation in the report for credentialing and training requirements that limit the pathways available for non-physician practitioners, such as CRNAs, to be able to provide interventional pain procedures. CRNAs are qualified pain practitioners who have the training and experience to provide high-quality treatments to patients suffering from a wide range of acute and chronic pain conditions, in a variety of practice settings. CRNAs who provide pain management do so in accordance with our professional scope of practice, federal and state law, and facility policy.As part of our educational preparation, CRNAs are required to learn and demonstrate competence in the management of pain. And, the standards issued by the Council on Accreditation mandate that nurse anesthesia programs provide content in, but not limited to, anatomy, physiology, pathophysiology, pharmacology, and acute and chronic pain management. These standards also require that student nurse anesthetists obtain clinical experiences in regional anesthetic techniques (i.e., spinal, epidural, and peripheral nerve blocks). As such, CRNAs possess the necessary knowledge and skills to employ therapeutic, physiological, pharmacological, interventional, and psychological modalities in the management and treatment of acute and chronic pain. Additionally, the Centers for Medicare and Medicaid Services (CMS) recognizes the ability of CRNAs to perform and bill for acute and chronic pain management services. The U.S. House of Representatives also recognizes the ability of CRNAs to perform pain management services and urged the Department of Defense to make funds available for CRNAs to pursue existing pain management fellowships. CRNAs and other non-physician providers play an integral role in providing these services, which positively impact several areas, including patient safety, reducing prescription drug abuse, and cost savings; and should be recognized in the report.I strongly urge HHS and the Task Force not to adopt these recommendations as drafted and request that the credentialing and training requirements be amended to be inclusive of all types of practitioners and their educational pathways. Sincerely,R Haynes1919 Dunraven RdBloomington, IL 61704-9705   Hi- I am a psychologist, and I have RLS, and I work in substance use treatment and fully understand the importance of addressing the opioid crisis. I nightly take Requip and Gabapentin which make me too drowsy to function, even at a low dose, during the day. I am embarrassed that I occasionally need to take Tramadol for long afternoon meetings. I probably take two pills a month, or less, yet it is important that I be able to continue to do. It is the only medication that does not make me drowsy and yet helps me to sit and function at work during meetings. It is important that legislation not be too strict that it overrides medically necessary treatment.thank you! I have had hip dysplasia, spinal deterioration, 3 left hip replacements,  two right knee revisions, RSD/CRPS, pineal brain  tumor and seizures from a year old until today (age 541/2.. ) Ive been forced to taper off benzodiazepines (after 23 years) which has caused deafening tinnitus. My pain medication was cut from oxycodone 15mg TID (7 years without incident or abuse)  to 10mg Hydrocodone. My pain management doctor refuses to increase medication to help with my excruciating pain. I have only left my bed, in 8 months, to go to multiple specialists that are a 3 hr rpund trip from my home. The doctors have taken away my quality of life. I have broken no laws EVER, dont use alcohol/marijuana or illegal drugs, jumped through every hoop but I am still treated like a drug addict!! I havent been able to be the wife, to my husband of 32 years, that he deserves and Ive missed almost a year of being able to visit my four children and 5 grandchildren ( and another grandbaby is due late May 2019). I have been treated horribly by pharmacists every time I have to pick up my low dose medications. Im afraid of being completely cut off of all opioids due to false narrative of opioid crisis, doctors fears and pharmacists/insurance company refusing to fill doctors orders! The guidelines were never meant to effect current pain patients but were the ones being effected the most while illicit drug use increases. My disability,  constitutional and human rights are being violated. Please stop this before more chronic pain patients commit suicide after being forced to stop all opioids! Lawmakers should never get between a patient and their doctor!  End the Drug War.In a decriminalized environment absolutely none of this draft report would be necessary. Government created a problem, now government is pretending to want a solution, but in fact until the Drug War is completely and permanently ended no solution will ever be anything other than substantially sub-optimal. In a decriminalized environment opioid addiction is 100% benign, except for those individuals who knowingly and intentionally pursue risky behavior. These people are already pursuing their risky behavior choices in the current Drug War environment, so there will be absolutely no negative impact of decriminalizing opioids, and the elimination of negative Drug War externalities will be overwhelmingly positive for society.Providers need to quit being paranoid about opiates.Government needs to grow up.