Angela K. Oliver, Executive Secretary
Centers for Disease Control and Prevention
National Center for Injury Prevention and Control
4770 Buford Highway NE
Atlanta, GA 30341
Attn: Docket No. CDC-2022-0024
Subject: Feedback on the CDC Clinical Practice Guideline for Prescribing Opioids
Dear Ms. Oliver,
The American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS) appreciate the opportunity to provide feedback on the Center for Disease Control and Prevention’s (CDC) Proposed 2022 CDC Clinical Practice Guideline for Prescribing Opioids. We congratulate the authors on creating an updated document that avoids many of the unintended consequences and misinterpretations of the 2016 version. However, we believe that this guideline remains incomplete due to several notable omissions.
We agree with the authors’ statements regarding the limited benefits of opioids while also acknowledging that some patients benefit significantly from these medications and that they can be used responsibly with appropriate plans in place by a treatment team. Moreover, we are pleased to see the multiple bolded admonitions against forced opioid tapering and that patients currently on chronic opioid therapy should not be abandoned by their prescribing practitioner. Some clinicians frequently used the 2016 guideline to either forcibly and rapidly taper opioid doses or to outright suddenly cease prescribing for patients, both of which can potentially cause significant harm.
We also agree that post-surgical pain may require the use of opioids in the postprocedural period and that surgical teams should pre-emptively develop an exit strategy in the event opioid therapy is inadequate postoperatively. We would also encourage surgical teams to conduct this discussion and share this plan with the patient during preoperative discussions.
Unfortunately, the AANS and the CNS continue to be disappointed that, like the 2016 version, the proposed 2022 version of the guideline is incomplete. While the document devotes significant discussion regarding nonpharmacologic treatments for pain as alternatives to opioid therapy, the guideline fails to adequately explore surgical treatment options to reduce or eliminate opioid use.
Click here to read the full AANS/CNS Comment on Updated CDC Opioid Guidelines.
