By UOAA Advocacy Manager Jeanine Gleba, MEd.

For several years UOAA has been advocating for those in the ostomy and digestive disease communities who use opioids for non-pain conditions. In UOAA’s May 2022 ENewsletter we reported that UOAA submitted federal comments with the National Center for Injury and Prevention and Control at the Centers for Disease Control and Prevention on its draft update of the 2016 CDC Guidelines for Prescribing Opioids for Chronic Pain. We recommended that the guidelines should not be intended for primary care physicians and other clinicians providing non-pain care for outpatients such as those with digestive diseases resulting in an ostomy or fecal continent diversion who may use opioids to manage high output stomas or patients with short bowel syndrome.  

On November 4th, the CDC released the updated Clinical Practice Guidelines for Prescribing Opioids for Pain – United States, 2022. They had over 5500 public comments submitted.

Our voices were heard! In the CDC Response to Public Comments on the Draft 2022 Clinical Practice Guideline for Prescribing Opioids for Pain they specifically mention our submission under the “summary of themes that emerged from the public comments submitted to CDC” bullet number six:  

• Some respondents representing non-pain related conditions that use opioids for treatment (e.g., ostomy-related conditions and restless leg syndrome [RLS]) proposed that the Guideline title should be adjusted to better reflect its content and intended use. 

Then on page 4 under the “summary of edits the CDC made to the draft 2022 Clinical Practice Guideline based on public comment” bullets 2 and 3 apply to our comments and concerns:

• CDC changed the name of the document from the CDC Clinical Practice Guideline for Prescribing Opioids to CDC Clinical Practice Guideline for Prescribing Opioids for Pain to further emphasize its focus on prescription opioids for the treatment of pain. 
• CDC added language throughout the document to emphasize that the 2022 Clinical Practice Guideline provides voluntary clinical practice recommendations that are not intended to be inflexible standards of care or implemented as absolute limits of policy or practice for patients by clinicians, healthcare systems, or government entities. 

They did not specifically add any statement that the guidelines are not intended for primary care physicians and other clinicians providing non-pain care for outpatients with chronic and acute digestive diseases; however, the important takeaways from the document for our patient population are the following:

1) The voluntary guideline is intended ONLY for primary care clinicians and other clinicians providing PAIN care (acute pain, subacute pain and chronic pain).

2) The guideline is not a replacement for clinical judgment or individualized person-centered care.

3) The guideline should not be applied as inflexible standards of care across patients or patient populations by healthcare professionals, health systems, pharmacies, third-party payors or state, local or federal organizations or entities.

4) The guideline is not a law, regulation or policy that dictates clinical practice.

5) As stated on page 5 – “To avoid unintended consequences for patients, this clinical practice guideline should NOT be misapplied, or policies derived from it, beyond its intended use. Examples of misapplication or inappropriate policies include being inflexible on opioid dosage and duration, discontinuing or dismissing patients from a practice…and applying recommendations to populations that are not a focus of the clinical practice guideline.” 

In conclusion, it is clear that these new guidelines should not be applied to our patient populations utilizing opioids for non-pain treatments in accordance with the recommendations of their physician, which was the goal of our advocacy effort. 

With the updated CDC guidelines there should no longer be any misinterpretation of their voluntary recommendations. Our patient community will be protected and should not be restricted access to their lifesaving treatment. 

 

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