April 1st, 2019
Alex Azar, JD Secretary, US Department of Health and Human Services 330 C Street SWWashington, DC 20416 Re: Pain Management Best Practices Inter-Agency Task Force Draft Report on Pain Management Best Practices: Updates, Gaps, Inconsistencies, and Recommendations (HHS-OS-2018-0027)Comments submitted electronically at www.regulations.govDear Secretary Azar,Thank you for the opportunity to submit comments on the draft report (file code HHS-OS-2018-0027), Pain Management Best Practices Inter-Agency Task Force Draft Report on Pain Management Best Practices: Updates, Gaps, Inconsistencies, and Recommendations. The Global Healthy Living Foundation (GHLF) is a 20-year-old 501(c)(3) patient organization reaching millions of chronically ill patients and their caregivers across the country through social media, community events and our online support and education. GHLF works to improve the quality of life for patients living with chronic disease by making sure their voices are heard and advocating for improved access to care at the community level. Our patients suffer from chronic conditions including arthritis, psoriasis, gastrointestinal disease, cardiovascular disease and migraine. As aresult, these patients incur significant financial burden due to the high cost of the treatments that are necessary to manage their disease. And, it is on behalf of the patients we represent that we provide this information for your consideration. We havealso submitted comments as a member of the Consumer Pain Advocacy Task Force (CPATF).We appreciate that the Secretaryquickly implemented the Pain Management Best Practices Inter-Agency Task Force (“Task Force”) authorized by the Comprehensive Addictionand Recovery Act of 2016, and appreciate the effort to complete such a comprehensive report. . Chronic pain is a real public health problem that is nothing short of debilitating for those going through it. Many individuals suffering in pain simply cannot function, cannot goto work, have difficulty raising their children, and simply interacting with society. More research is needed to developnon-opioid alternative therapies for these patientsso their pain is adequately addressed. The opioid crisis is equally real. We are at a point where nearly every Americans knowssomeone who has suffered as a result of addiction. In representing patients who suffer daily in physical pain,GHLFpromotesalternative pain management techniques vigorously: where viable, we encourage our patients totalk with their healthcare provider abouttryingoptions such as physical therapy, meditation, acupuncture, yoga/stretchingand non-opioid prescription and over-the-counter pain relief medications. We believe that opioids should never be used as a first line of treatment for chronic pain and should be used only under the strictest guidance from physiciansto reduce the likelihood of abuse.However, there remain chronically ill patients who cannot handle daily tasks without suppressing their pain in the way that opioids door for other reasons cannot tolerate alternatives.As you consider policy changesand work to finalize the report, we urge you to acknowledge the challenges thesepatientsface. First and foremost: take carenottostigmatize patients who rely on pain management to get through their daily routines. The damage being done by opioids needs to end, but these discussions often ignorethe very real physical pain that over 50 million Americans face every day.1Second, when addressing pain management, Americans need to have better access to alternative treatments as outlined above. These treatments need to be cost effective for patients and covered by insurance in order for them to be used.Thank you very much for the opportunity to comment on this draft report and again, for all of the agency’s efforts to reduce drug prices and help patients safely and effectively address their pain. We look forward to being a resource to the agency and partnering with policymakers to implement policies that result in patients having greater access to treatment while lowering costs to the healthcare system. Please do not hesitate to contact me at [email protected] we may be of further assistance with the Task Force’s workor if you have questions on our comments. Sincerely,Steven NewmarkDirector of Policy and General CounselGlobal Healthy Living Foundation1Prevalence of Chronic Pain and High-Impact Chronic Pain Among Adults —United States, 2016, September 14, 2018 / 67(36);1001–1006, https://www.cdc.gov/mmwr/volumes/67/wr/mm6736a2.htm.