Subject: Management of Acute and Chronic Pain Guideline. Docket No. CDC–2020–0029
Dear Dr. Redfield:
The American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons
(CNS) welcome the opportunity to provide comments regarding the Centers for Disease Control and
Prevention (CDC) Guideline for Prescribing Opioids for Chronic Pain, introduced in 2016. At that time,
the CDC stated that “CDC will revisit this guideline as new evidence becomes available to determine
when evidence gaps have been sufficiently closed to warrant an update of the guideline.”1 We appreciate
the agency’s outreach for information on real-world experience as the process of updating the guideline
begins.
In the four years since the guideline was published, it has proven to be extremely influential, but not
always in ways that have benefitted patient care. Practices such as forced tapering of opioid
prescriptions increased substantially in the wake of the guideline’s publication. Moreover, patients
receiving palliative care or cancer care were inappropriately swept up in the CDC’s call to reduce opioid
prescriptions as the recommendations were improperly applied to these groups. Importantly, the
guideline did little to discuss the available nonpharmacologic alternatives to opioid therapy.
Below are specific comments for the CDC to consider in developing the next edition of the guideline.
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