January 13, 2016
Arlene Greenspan, DrPH, MS, MPH
Associate Director of Science
National Center for Injury Prevention and Control
Attn: Docket CDC-2015-0112
Centers for Disease Control and Prevention
4770 Buford Highway NE.
Atlanta, GA 30341
VIA ELECTRONIC SUBMISSION:
Re: CDC Guidelines for Prescribing Opioids for Chronic Pain, United States, 2016
Dear Dr. Greenspan:
ASHP is pleased to submit comments on the first draft of the CDC Guidelines for Prescribing Opioids for Chronic Pain, United States, 2016 as announced in the December 14, 2015 Federal Register.1 ASHP represents pharmacists who serve as patient care providers in acute and ambulatory settings. The organization’s more than 43,000 members include pharmacists, student pharmacists and pharmacy technicians. For over 70 years, ASHP has been on the forefront of efforts to improve medication use and enhance patient safety. We applaud the CDC’s efforts in the timely release of critically necessary guidelines focused on this important public health issue.
We appreciate the guideline development methods which use a systematic evidence based approach to validate the points throughout the document. We do believe that there are specific points, however, than if addressed would improve the plan.
The document provides a comprehensive view of a prescriber’s perspective on opioid prescribing, but does not address these issues from the viewpoint of other members of the health care team including nursing and pharmacy, or from the viewpoint of the patients themselves.
ASHP agrees with the 12 recommendations provided (starting on page 17); however, we strongly believe that pharmacists as the medication experts can contribute valuable expertise in optimizing the use of these high-risk medications.
While pharmacists at the Agency for Healthcare Research and Quality, the Food and Drug Administration, and the Substance Abuse and Mental Health Services Administration reviewed the draft plan, ASHP recommends that future revision to the draft plan include a wider array of practicing pharmacists, and include pharmacists as authors. ASHP would be pleased to suggest names of pharmacists who could serve as reviewers and/or authors.
The involvement of pharmacists in patient-care as well as the development of prescribing guidelines can help to control drug abuse and opioid overuse through the unique practice experience and knowledge of the pharmacist.
We are in favor of development of a more robust Prescription Drug Monitoring Policy which includes a national network, allowing providers and pharmacists to track patient-specific opioid use and prevent abuse and over prescribing at the point of prescribing.
ASHP remains very concerned with placing a daily maximum dosage on opioid use, and urges the CDC to recognize the importance of these medications in alleviating pain by recommending that practitioners develop individualized therapy on a patient-specific basis.
ASHP appreciates this opportunity to provide comments to CDC on the importance of pharmacists in the treatment of chronic pain with opioids. Please contact me if you have any questions on ASHP’s comments on the draft plan. I can be reached by telephone at 301-664-8806, or by e-mail at firstname.lastname@example.org.
1Federal Register Vol. 80, No. 239 pages 77361 – 77352
Christopher J. Topoleski
Director, Federal Legislative Affairs