The CDC has officially released the draft CDC Clinical Practice Guideline for Prescribing Opioids—United States, 2022. The docket is now open for public comment, and it will remain open until April 11, 2022.
- Federal Register Notice
- Full Docket, including links to the proposed guideline, the overview of public engagement work that went into the development of the guideline, the GRADE tables of evidence, and the Opioid Working Group report.
Some Major Changes From the 2016 Guideline
First, we want to acknowledge the important and positive changes that we are seeing in this version. While we are still reviewing the full guideline, and all updates contained within, a few major changes from the 2016 guideline have become immediately apparent, which you can see below. We welcome feedback from you about these issues as well as any other celebrations or concerns you may have.
- Applies to additional clinicians: While the 2016 guideline was intended only for primary care physicians, the 2022 version is intended to provide recommendations for physicians, nurse practitioners, physician assistants, and oral health practitioners.
- Promotes integrated pain management: The draft states, “As clinicians may work within team-based care, the recommendations refer to and promote integrated pain management and collaborative working relationships with, for example, behavioral health specialists, such as social workers or psychologists, and pharmacists.” Further, the draft states that “medications should ideally be combined with nonpharmacologic therapy to provide greater benefits to patients in improving pain and function” and that multimodal therapies and multidisciplinary biopsychosocial rehabilitation-combining approaches can reduce long-term pain and disability.
- Calls for improved payment of multimodal treatments: The draft states that health systems and payers should work to ensure that multimodal pain treatments are available, accessible, and reimbursed. The CDC calls on public and private payers to support a broader array of nonpharmacologic interventions, stating that “reimbursement is often cited as a principal barrier to why these nonpharmacologic treatments are not more widely used.”
- Emphasis on joint decision making: Unlike the 2016 guideline, the 2022 draft emphasizes the importance of the clinician and patient jointly determining treatment goals and how opioid effectiveness will be evaluated.
- Removal of arbitrary dosage ceilings: In a drastic departure from the 2016 guideline, the 2022 draft has removed recommendations related to arbitrary dosage ceilings. Mentions of specific dosages are now presented in a much more narrative form, alongside specific evidence and considerations, but without explicit warnings not to exceed certain dosages. The guideline does, however, caution clinicians to be aware of rules related to MME thresholds established on a state-by-state basis.
Explicitly voluntary and not be used as mandatory limits: The draft says, “Of utmost importance, this clinical practice guideline provides voluntary clinical practice recommendations for clinicians that should not be used as inflexible standards of care. The clinical practice guideline recommendations are also not intended to be implemented as absolute limits of policy or practice across populations by organizations, healthcare systems, or government entities.”
AACIPM Takes Action
As always, AACIPM is actively working to connect the dots to expedite access to person-centered pain care, engaging stakeholders around this important opportunity for public comment (as we have done recently with efforts related to AHRQ and CMS).
AACIPM facilitated a call on Friday, February 18th, 1:00-2:00PM EST, with multi-stakeholder leaders, many involved in our ongoing efforts, to discuss this draft and the possibility of submitting a group response. On this call, each stakeholder group was be invited to share their reactions to the draft and any concerns they may have. AACIPM’s goal is to identify areas of consensus and opportunity across leaders representing people with pain, policymakers, healthcare providers, payors, purchasers, academia, patient/caregiver advocates and more.
If you are a leader of a an organization or policy group and would like to learn more about this, please contact Amy Goldstein, Director, AACIPM.