FDA's Proposed New Opioid REMS Revealed

By Karen Lee Richards, Health Guide Wednesday, July 07, 2010
In June 2009, I first told you about the FDA's plan to develop “Risk Evaluation and Mitigation Strategies” (or REMS) in an attempt to reduce prescription drug abuse by limiting access to opioid medications.  The ideas they were considering would have made it a great deal more difficu...
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7/ 7/10 2:38pm

Hi karen,

Thanks again for sharing another informative piece. I am concerned. i am one of those patients who does use a longer/slower acting opiods. I have been on this medication for over 10 yrs without ever having to increase my dose except post op from neck surgery. In fact I have taken myself down with the help of my wonderful pain specialists from 160 mg to only 5 mg when I get up. That's tends to be when I the pain is just not managable. I have Fibro, spinal stenosis of the cervical spine, arthritis. I also had jaw joint implants put in my jaaws in 1984 and remained sypmtomatic when in 1991 the FDA recalled the implants due to a high rate of failure. The implants were disintergrating in peoples bodies which set up  rejection process. It has been a rough 28 years. These implants were approved by the FDA which later our attorney's discovered much wrong doing and neglect on the part of the FDA, who is our governing agent set to protect our bodies fro such horrors. I have a hard time trusting the FDA.

I am praying that this all sahll not come to be as I a patient who has had the need for opiod medicaion jst to get by will be ina real fix should the FDA make it harder or impossible to receive my meds. I am not a drggie, never have been, and resent being compiled with a group of "could be's"

Thanks for letting me vent.

Toni Helser

tjhelser 

7/ 7/10 4:45pm

I hadn't been keeping up with this issue- although, ironically, it's never been more relevant...

 

I'm glad that you posted this article! Teri Robert's motto that "knowledge is power" is so applicable here! 

 

I'm especially grateful that you linked to it on facebook, as I rarely come to the chronic pain site here on healthcentral!

 

Thanks again,

 

Jamie 

 

 

7/ 8/10 5:10am

Thanks for making this info available to us. As a fairly new user of extended release opioids (though I have been on pain meds for 7 years now), this is an issue important to me. The extended release meds have been the first to give me a halfway decent quality to my life. I suffer with RSD in my leg which in turn has messed up my back because of uneven weight distribution and crutch use. Once I started the extended release meds I was able to keep the pain to a fairly manageable level most days so I could have a fair shot at enjoying life a little bit. Anuthing the FDA does to change that would be horrible as far as I am concerned. There are so many issues with insurance companies and RSD (in particular) that could have possibly put my RSD in "remission" and avoided all this pain, which is a whole different story. Now that I am stuck with it, I hope the FDA does jeopardize the little quality of life I have finaly found by changing things.

7/ 8/10 8:03am

The FDA and the rest of the Obama administration is woefully out of touch with the needs of the public regarding pain. Many key members of the Obama administration involved in health care never heard of the National Pain Care Policy Act-prior to my informing them about it. Few members of the public are on advisory committees in the NIH -we are not being heard as the Obama administration finds it more convenient to deal with their associates in the health care industry rather then hear directly from the public.

Let us not be deceived but rather we should ask for more direct democracy-a greater voice in all aspects of pain care and not just accept the few crumbs that the Obama administration provides the public regarding pain

7/ 8/10 8:55am

Why do we need to politizice this whole process???? As far as I know this process started back in 2007, I don't think that the current administration was  in place back in 07.... And really,  the article has to do with the power of US the chronic pain patient's that took the time to write the FDA and send our concerns about their proposed new system, is NOT about politics! So let's thank Karen for another great informative article, and keep politics out of this forum.

7/ 8/10 10:19am

I don't believe he was being political at ALL...just stating the facts about this administration....should those facts as he perceives them be swept under the rug just because it mentions the Obama administration? Absolutely not...it could be ANY administration and probably has been in the past so I think your reprimand is out of line.

7/ 8/10 10:47am

I don't think he necessarily is politicizing this, however it IS somewhat political.  If you take the time to read the new health care legislation, it is very political and very scary!  There will be a time when the government will dictate what medicines it feels you can and cannot take, what you do and do not need.  There will be a time when even tho you have been on your pain meds for years, the government will decide you don't need them anymore.  I work there - I know...

7/ 8/10 12:33pm

This is an obvious hot point with many of us. I too have been using extended release for over 10 years now and the difference for me is between being completely bed bound, unable to have any sense of a life, to having a life that may be different than before but a life Trust me, I tried the every four hour meds such as Percodan for 15 years because I had no choice, no education to know that there was something better. I know for a fact it exasperated my pain levels and possibly aided in my pain being more difficult to manage. Had I been prescribed effectivve meds to begin with my body would not have reacted so negatively to the pain. Maybe the doc's just did not know either.

Since being on an extended release my life is as full and alive as I could expect, could hope for. But those 15 years I lost many moments due to intractable pain. I cannot do it again. The mere thought friightens me. It is like worryig about, "will my meds be filled this time" all over again.

 

I have signed a pain contract with my doc and have had no problems in all these years. I realize I am fortunate and believe me I am grateful.

 

We as a large group, a group of consumers of the medical industry and as with any business it is important that their cliets are listened to. This is the case with the current administration and all those involved in making decisions that effect our lives. We have to band together and fight this, as a large group of voices that will not be squelched I have to believe we will be listened to.

 

It may be political to many politcians, but to me it is personal and I refuse to let them politizize my freedom to live as best as I can, just like any other American.

 

Write, write, talk, and talk some more. Let those who need to know just how this effects you. In a personal way share your stories. Let's overwelm them with letters, questions, phone calls to your state representitives, etc... make your voice loud and strong. Our lives depend on it!

7/ 8/10 1:57pm

You are right the process shouldnt be politicized- it was the health care industry and government that politicize it as they seek to maximize their power. privelege and freedom to the detriment of those in pain. But pain care involves politics as much as anything does. I wish the feudal mischief of government and the health care industry would be spent when it comes to pain care-but obviously the Obama administration- just like the Bush administration politicizes pain care andis too far removed from the people suffering pain.

7/ 8/10 2:03pm

Obama hasof course largely kept in place those who who work on pain that worked on pain in the Bush administration- including dr tabak and story landis on the pain consortium. Dr Collins of NIH worked for bush and now works for Obama, The IOM is still run by the same people of the Bush administration. The facts are the facts- Obama and his staff dont have a real plan to help people with pain- neither did george Bush. I have no doubt some people love Mr Obama- if only those same people cared as much for people suffering pain

7/ 8/10 2:15pm

Thankyou for your support. I am critical of government and the health care industry because i see the prevalence of pain rising rapidly and too many people are still mistreated by health professionasl because they have pain. If the government or the health care industry had a real plan, at least, then i would be more of a believer but given their poor performance they deserve criticism and calls for substantive change, But if  the Obama administration or the President of the AMA or other medical organizations wish to debate the issue- here i am.

7/ 8/10 12:19pm

Miss Richards,

I am sorry that you feel that the very few who are abusers, fakers, and/or addicts should force all pain patients to be painted with the same brush. ** Agreeing to, for instance, random urine tests, presupposes abuse/lying.

I also wish that you had used the correct terms.  Most pain patients do not become addicted.  Some may become physically dependent, an entirely different animal.*

No other medical treatments come with the caveat that 'we assume you are a liar, a faker, an addict or an abuser.' 

Thank you.

 


Carol Jay Levy, B.A., CH.t
author A PAINED LIFE, a chronic pain journey
founder, Women In Pain Awareness website, http://womeninpainawareness.ning.com/ founder, Women In Pain Awareness Group, facebook http://www.facebook.com/?ref=home#!/group.php?gid=111961795481256 member, cofounder with Linda Misek-Falkoff, PWPI, Persons With Pain International,
accredited to the U.N. Convention on the Rights of Persons with Disabilities
member U.N. NGO group, Persons With Disabilities

 

 

*Although most chronic pain patients who take opioids on a long-term basis will become physically dependent on them, very few will ever become addicted to them. The rare few who do develop a problem are often highly susceptible to addiction due to a genetic predisposition. In a review of 24,000 patients who were medically prescribed opioids, only seven could be found who got into trouble with them. So a chronic pain patient becoming addicted to opioid medications is definitely the exception rather than the rule.http://www.healthcentral.com/chronic-pain/coping-279488-5.html

 

**"Unfortunately, abusers are often very good at faking it, and there are no lab test that can accurately identify pain levels, so doctors are forced to do the best they can, utilizing tools like treatment agreements and random drug testing to make sure they're not contributing to someone's addiction problem."http://www.healthcentral.com/chronic-pain/treatment-290437-5_4.html

 

(These 2 articles seem to me to be at odds with each other.)

7/ 9/10 1:48am

Ms. Levy, can I conclude that you're not overweight, or a type 2 diabetic on insulin? :)

 

There most certainly are other medical treatments where your doctors assume you are lying.  I deal with that on a regular basis.

 

Agreeing to random testing, and the rest of the Narcotics Agreement protects your doctor, which protects your access to the medications that you need for pain management.  As long as every single pain patient is under the same agreement, there's nothing that presupposes any nefarious intentions or bad acts, it's simply the doctor's insurance policy that he doesn't have to trust his (or her) instincts.  If a doctor goes by his judgement alone, he only has to be wrong ONCE to have his entire practice shut down, to deprive hundreds of patients of desperately needed medical care.

 

Really, it's not personal.  If they used their judgement instead of having EVERYONE sign a Narcotics Agreement, THAT would be personal.

 

If you think those two article excerpts are at odds with each other, I suggest you read them again, perhaps with a more open mind.  Perhaps the reason that so few patients actually get into trouble with prescribed opioids is exactly BECAUSE the doctors use treatment agreements and random drug testing?  Anyone who even begins to show any signs of a problem does not get any more prescribed opioids, and so does not develop a full-blown addiction problem. 

 

And yes, I am a chronic pain patient, too.  I'm living the dream, too. :)

7/ 9/10 1:03pm

I am not sure what my weight has to do with it and no I am not a diabetic.  I imagine that the lyiing refers to keeping on your diet and taking the meds on time, correctly, etc.  That is not analogous to being presumed guilty because you are a chronic pain patient being prescribed narcotic medication.

Yes. patients do lie about many things.  It is only in this context that they are required to sign a form that obligates them to agreeing to actions that those who are addicts are required to do when in rehab, jail, or house arrest despite no evidence that they are addicts, only people in constant chronic pain.

My doctor does not require me to sign one.  He does pick and choose.  As a doctor he should know the indices showing which patients may be problematic, either with lying or with misusing narcotics.  I worked in an ER for years.  Most patients did not lie; the ones looking for narcotics were usually easy to pick out. If the woman down the street abuses her child do we then assume that all women abuse their children and treat them all as suspects and potential abusers?  Do we require them all to prove they are not abusers, require psych testing or supervisory visits to the home?

I have experience with both sides.  My neurologist lost his right to prescribe narcotics.  He was not selling them or overprescribing for fun.  He may have been overprescribing, but knowing him, it was to help his patients, not to do something nefarious.  On the other hand a pain doc, psychiatrist and pain clinic owner, was found to have over 5,000 narcotic pills in the clinic.  The police believe he had this cache to sell or distribute illegally.  Do we place all doctors iin his category then?  No, he is the unusual, not the constant.)

As for the articles I have read them.  One talks dependence and rareness of addition, the other presupposes addiction problems.

Your sentence "Anyone who even begins to show any signs of a problem does not get any more prescribed opioids, and so does not develop a full-blown addiction problem." is a perfect example of the problem.  You write 'addiction'.  Again most patients who develop a problem, and that is a minority, do not get addicted, although they may become physically dependent. It is even a more tiny minority that get addicted.It is not same thing and yet it is the reason of  presumption of guilt by association (with narcotics)

I appreciate your reply and the opportunity for discussion.

Thanks. Carol

 

 

Karen Lee Richards, Health Guide
7/ 9/10 2:50pm

Hi Ms. Levy,

I think there may be some misunderstanding so I'd like to clarify my position.  I have always spoken out against treating pain patients like suspected criminals.  See my article:  Guilty Until Proven Innocent

 

I'm not sure exactly where you think I used the wrong term.  In the Sharepost this comment is attached to, I don't believe I used the term addict, addicted or addiction at all.  And I don't believe I've ever referred to pain patients as addicts.  That is indeed a rare situation, as I indicated in my article on addiction vs. dependence that you referred to. 

 

I think part of the confusion may stem from the quote you referred to from my article on Treatment Agreements.  When I said "utilizing tools like treatment agreements and random drug testing to make sure they're not contributing to someone's addiction problem," I was not referring to the addiction problem of pain patients, but rather to the addiction problem of abusers who fake being in pain in order to get opioids.  Perhaps I should have worded it differently to be more clear. 

 

I absolutely agree that it's not fair for pain patients to be treated like addicts or potential addicts because of others who choose to abuse drugs.  But unfortunately, if most of us want to be treated with the medications we need, we have to deal with the system as it is.  Of course, I think we should keep fighting to change the system. 

 

It would be great if there was some way for doctors to easily separate the real pain patients from those just seeking drugs.  But I've read of studies done to test doctors' ability to do that and none of the doctors were consistently able to identify them correctly.  Personally, I'd rather see a few get drugs who shouldn't than let pain patients suffer needlessly.  But until the DEA stops the high-profile prosecutions of caring doctors who were fooled by some abusers, we're going to continue to have the problem. 

 

I hope I've been able to clarify my position.  If you have any other concerns, please let me know and I'll be happy to address them.

Karen

 

7/ 9/10 8:44pm

Dear Karen,

I just read that article.  Well put.  I am just sorry that it is the patients who see we are being treated as criminals but the government cannot (or will not). Unfortunately we are an easy population because many of us do not have the physical/emotional resources to put up a concerted fight against the DEA.

I cannot find the full article and it may well be I misunderstood to which group you were referring.

Thank you so much for your reply.

Carol

 

 

7/ 8/10 9:20pm

Thanks for the information. I am also a patient under the care of a pain management specialist. Whitout the extended release opioids I would have no quality of life. I do my best to keep my dose lower than I should take. I feel the FDA wants to treat me like a 3rd class citizen. Untill you have been in chronic pain you have no idea how life can be trying to live with chronic pain. I feel the FDA is looking at this as a substanance abuse problem and not trying to help the millions of americans who deal with chronic pain on a daily basis. I feel all pain meds should be treated equally and not single outextende release opiods because pain doctors rather treat you with extended release then with medications you take every 4-6 hours. My quality of life would be effected to the point I would be disabled for the rest of my life. Instead with the extended release I have as normal as a life as I can. I would like to know how to contact the FDA so I may have my input counted. 

Karen Lee Richards, Health Guide
7/ 9/10 1:38pm

I think the reason they've chosen to focus on the extended-release forms of the medications is because those are the ones that are most abused.  Addicts crush the tablets, which causes all of the drug to be released at once instead of gradually – this gives them more of a high. 

 

The link I gave to the FDA site where you can submit your comments showed up on the second page of the article, so I'm afraid people may have missed it. Here it is again – If you'd like to comment, just go to “Risk Evaluation and Mitigation Strategies for Certain Opioid Drugs” at regulations.gov, click on “Submit Comment” near the top of the page and share your thoughts and opinions.

7/ 8/10 11:11pm

my chronic small bowell obstruction, pancreatitis and infections around my stomach. i have been useing these med's for 7 yr's. these health problems are related to a serious birth defect in my small intestine/pancrease and the on going problems. thru time, i am not on as stong a mediciene as before. i have  worked to lower the dose & type of pain releiver. i have tried new option procedures. when i go to the hsopital every 3-4 weeks, they see i am not trying to get one by them. i agree that the problem of abuse & addiction with opiods is out of control. i live by very strict guidlines to make sure i am not part of the problem. i don't mind i it will stop some teenager from taking these pills. i just want to makesure that all of a sudden, my pain mgmt. docotor,  gi surgeons say that your paint mgmt plain will nolonger be available because of the abuse of others. i do other methods of mediation & relaxiation to work with the opiods i take. as one person's health issue's may have the same name to another persons health problem, the same treatment is usally not the same.

7/ 8/10 11:48pm

I take Oxycontin and have for several years to control a lot of different pain sources, including FMS and back pain. My general internist handles prescribing with occasional consults with a physiatrist at Maine Medical Center.

 

The drive to the physiatrist is 160 miles round trip. Especially in winter, it would be impossible.

 

 

9/ 2/10 4:50am

Thank you, Ms. Richards, for your lead article that provided the background and the Internet link to FDA documents needed to get me quickly up to speed on this important topic. As both a chronic pain sufferer for the past few years and as an opioid researcher and drug addiction specialist for over 35 years, I have quite a bit of 'opinion' (based on research and analysis) to weigh-in on this issue. (FYI: Among other things, I identified the site in the brain nearly 30 years ago where opiates work to produce their potent rewarding effects that can lead to addiction as well as demonstrate how physical dependence and addiction -- as viewed as compulsive drug-taking behavior -- are actually very much different. I went on to develop a theory of addiction suggesting that cocaine and heroin actually work on different parts of the same brain system; this general model remains paradigmatic in the field of drug addiction today. Now, I've clearly identified myself to my colleagues and my students. Cool) I was very pleased to learn from your article that I haven't missed the new deadline for open commentary.There is little worse than learning that an important issue has been decided without at least having the opportunity to try to make a positive difference in the proceedings. (Perhaps the "little worse" only applies to us academicians on most topics.)

 

In case it's not clear (as it wouldn't be from my main area of expertise), I am very strongly in support of patients' rights to adequate medication for the management of chronic pain and I feel that 'addiction through therapeutic opioid use' has been greatly exaggerated. I have not yet written my commentary, but one should appear in the next few weeks on my ASNet Discussion Forum which can be assessed through our home page at www.AddictionScience.net and which will be forwarded to my colleagues on the FDA advisory panel. I am also very pleased that your efforts have apparently led to pro-patient revisions in the guidelines already. Keep up the good work and I'll try to 'lend you a helping hand.'

I'll keep you posted (pun intendedWink) on my progress. (OK, laugh a little . . . it does help manage the pain.)

9/ 2/10 7:02pm

I look forward to your commentary. This has been a long time, hot issue for many of us, including myself.

I am most interested in how an addict speacilst who is also experiencing chronic pain deals with his life.

I have been using pharmaceutical treatments for over 25 years for my daily pain, almost always they have been classified as a narcotic. Today and for the last 10 years I have been treated with slow released opiods, never having a problem on my end.

However, I did discover that one internist I saw for a couple of years was arrested for sexually abusing some female patients who he also presribed opiods to. I was lucky in that he never tried to touch me but knowing his personality I can see how he would use the patient's medications as a carrot to dangle in front of them. I am disgusted that this man even took my pulse let alone treated me for two years.

The very people we are supposed to be able to rely on not only have valid concerns that are then exaggerated, but some of them even make it more painful to live a life and also try to receive treatment. I believe that many phyicians sabatoge many lifes while under their own sworn oath to "first do no harm"

Being a chronic pain patient is a definite decline into second class society, only because of our society, medical communities, governments local and national, and sometimes even our own families make us so.

To hear from a person who has his feet in both worlds will be intetresting.

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By Karen Lee Richards, Health Guide— Last Modified: 06/07/11, First Published: 07/07/10