CDC Is Proposing to Rewrite and Expand the 2016 Opioid Prescribing Guidelines!

November 25, 2019

Richard Lawhern Chief Systems Engineer – FCS Tech IPT at SAIC

This is for pain patients, medical professionals, and journalists who are considering in-person or telephonic attendance at the December 4-5 meeting of the National Centers for Injury Prevention (NCIPC) Board of Scientific Counselors at Atlanta Georgia. 

This notice may be shared with your networks.

The NCIPC agenda includes discussion of a pending rewrite of the 2016 CDC Guidelines on prescription of opioids. The meeting is set up to include public comments — but with only two minutes for individual speakers. Members of the public who are seeking to speak will need to listen to two Monday afternoon sessions on “The Nation’s Opioid Crisis and Work: Implications…” and “Background for Updating the CDC Guideline for Prescribing Opioids….” as well as hearing the public comments of others. If you are permitted to speak, then you can continue the narratives of those who have spoken before you, perhaps including some of the points offered below.

The first public comment period is 3:35-4:05 PM Monday December 4, and the second period is 10:40-10:55 AM Tuesday December 5. You may register for the meeting at

The meeting Agenda may be found here:

Dr Stephen Nadeau and I are working on refinements to the following points, which we will circulate to a list of medical professionals for endorsement and then submit for joint publication as a public service in multiple online venues. Sometimes the wheels grind slowly. Medical professionals are busy people. So we’re anticipating publication after the Atlanta meeting, though hopefully before the first of the year. 

Meantime, here are points that patient advocates may use in their own two-minute presentations.

Point Paper for NCIPC Board of Scientific Counselors – December 4, 2019 Meeting

• We speak on behalf of millions of people in pain who have been harmed by the 2016 CDC Guidelines on prescription of opioids.

  o CDC guidelines were not only “mis-applied” but factually in error on multiple issues.

  o Sweeping conclusions were drawn from very weak data or unsupported opinion.

  o Rarity of long term trials was conflated with implications that opioids are ineffective in the long term.

  o Real risk of addiction or mortality was grossly over-magnified and hyped.

  o Addiction from medical exposure is in fact rare.

• Over prescribing of opioid pain relievers by physicians to their patients did not create America’s public health crisis — and data published by CDC prove it beyond contradiction

  o Seniors over age 62 are prescribed opioids for pain six times more often than youth under age 19.

  o Youth have overdose mortality six times higher than seniors.

  o Overdose mortality among seniors has been relatively stable for 20 years while skyrocketing in youth.

  o Prescribing cannot account for this demographic inversion.

• Morphine Milligram Equivalent Daily Dose is not a useful measure of merit in opioid prescribing — and has been repudiated by the AMA 

  o Many patients benefit from opioid therapy at dose levels exceeding thresholds proposed in 2016 guidelines — often for years.

  o Individual genetic variations in opioid metabolism render generalizations on dose levels meaningless

  o AMA House of Delegates Resolution 235 [November 2018] and Board of Governors Study 22 [June 2019] apply directly.

  o American Academy of Family Physicians and five other medical associations declared on behalf of front-line physicians [April 2019]: that law enforcement must be removed from doctors’ offices. 

• Proven-reliable and safe alternatives to opioid therapy for moderate to severe pain do not yet exist.

  o Very weak medical evidence for effectiveness, no direct comparisons with opioids, no Phase II or Phase III trials

  o Opioid analgesics must remain an indispensable therapy in pain management for the foreseeable future.

  o Incidence of protracted prescribing in opioid-naive post-surgical patients is less than 1%;  

  o Incidence of diagnoses for substance abuse is less than 0.6% — reflecting the hostile regulatory environment rather than patient drug seeking.

  o Mortality risk from managed exposure to medical opioids is on the order of 0.02% per year — too small to reliably measure or control.

• No published trials demonstrate benefit from involuntary tapering of legacy patients. Coerced tapering instead risks patient medical collapse. 

  o There are no proven profiling instruments with predictive accuracy to assess risks of opioid prescribing in individual patients.

  o “Tapering” as now practiced often amounts to unilateral patient discharge and desertion without support.

  o There is no medical, ethical, or moral justification for coerced tapering of chronic pain patients who are otherwise stable. 

  o Denial of effective pain relief to new patients when it is available and managed by medical professionals may be a fundamental violation of human rights.

• If CDC is to rewrite the 2016 CDC guidelines, then AMA Resolution 235 must become an explicit and central guiding principle in recommended practice. 

  o Writers group must include multiple patient advocates as voting members. 

  o Explicit attention must be given to removing 2016 and newer Guidelines from drug enforcement legislation.

  o Draft treatment standards must be publicly circulated with a 90-day comment period and commitment to full public transparency.


Medical professionals wishing to be invited to endorse the final paper may send email to or comment here. Please provide name, degrees or qualifications, and current position or professional association. 

Published By: Richard Lawhern Chief Systems Engineer – FCS Tech IPT at SAIC

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