In a letter to the Centers for Disease Control and Prevention (CDC), the president of the American Chiropractic Association (ACA), Anthony Hamm, D.C., commends the regulatory agency for recommending use of conservative pain management strategies — such as spinal manipulation — as a preferred initial treatment option for pain management in its proposed 2016 Guideline for Prescribing Opioids for Chronic Pain.

Hamm observes there is “no evidence showing a long-term benefit of opioids in pain and function for chronic pain with outcomes examined at least one year later,” and that on the contrary, volumes of evidence show potential harm associated with the increasing use of prescription opioids.

Hamm cited a 2015 report published in the Journal of the American Academy of Orthopedic Surgeons (JAAOS) that found increased use of opioids has led to unanticipated consequences, such as a tolerance among some patients to the drug hydrocodone and negative treatment outcomes for conditions such as work-related musculoskeletal disorders, joint replacements and spine surgery.

In addition, the president of the Arlington, Virginia-based ACA points to recent research suggesting that rising prevalence of chronic pain and/or opioid use by U.S. combat soldiers after deployment is cause for serious concern. The study, published online as a research letter in JAMA Internal Medicine, is accompanied by an editorial recommending that the goal should be nothing short of a “cultural transformation” in how pain is managed.

The Centers for Disease Control and Prevention (CDC) in the Department of Health and Human Services (HHS) has announced the opening of a docket to obtain public comment on the draft CDC Guideline, which summarizes scientific knowledge about the effectiveness and risks of long-term opioid therapy, and provides recommendations for when to initiate or continue opioids for chronic pain; opioid selection, dosage, duration, follow-up, and discontinuation; and for assessing the risk and addressing the harm of opioid use. The draft Guideline also identifies important gaps where more research is needed.

To develop its recommendations, CDC says it conducted a systematic review of the benefits and harms of opioids and developed the draft Guideline using the Grading of Recommendations Assessment, Development, and Evaluation (GRADE) framework. The agency then drafted recommendations and consulted with experts on the evidence to inform the recommendations, hosting webinars in September 2015 and also providing opportunities for stakeholder and peer review of the draft. For more information on prescription drug overdose, visit http://www.cdc.gov/drugoverdose/prescribing/guideline.html.

The Guideline, which was published in the Federal Register last month, is intended for use by primary care providers treating patients suffering from chronic pain (pain lasting longer than three months or past the time of normal tissue healing) in outpatient settings, and is intended to apply to patients ages 18 or older with chronic pain, and does not include palliative and end-of-life care. The Guideline is not intended to apply to patients being treated for active cancer, is not a federal regulation, and adherence will be voluntary.

“Chiropractic physicians are well positioned to play a vital role in the conservative management of acute and chronic pain. They offer complementary and integrative strategies, as well as guidance on self care, that can provide needed relief for many who suffer from pain,” Hamm wrote in the ACA’s letter of formal comment.

An ACA release notes that the comments submitted by Hamm on behalf of the ACA are part of the chiropractic profession’s ongoing efforts to educate the public about the value of non-invasive, non-pharmaceutical treatments for pain management and health enhancement before moving on to higher risk options.

The ACA notes that this healthcare model encourages, when appropriate, use of more cost-effective and safer approaches as an alternative to potentially addictive medications, surgery, and other invasive procedures for pain management and health enhancement.

The ACA observes that healthcare quality watchdog organizations have begun to recognize the value of this conservative approach, noting that in 2015, the Joint Commission, which certifies more than 20,000 healthcare organizations and programs in the U.S.,, revised its pain management standard to include chiropractic services. They report that more than 33.6 million Americans sought chiropractic care in 2014, compared to a previously reported estimate of 20.6 million in 2012.

Hamm says in his letter that the ACA strongly believes that federal government healthcare policy should encourage the use of — and provide access to — conservative, non-drug, non-surgical chiropractic services. Specifically, he said:

• Outdated statutory language in Medicare should be changed to allow chiropractic physicians to practice and
be reimbursed to the fullest extent of their licensure, training and competencies.

• Doctors of Chiropractic should be appointed as officers in the commissioned Regular Corps and the Ready Reserve Corps of the Public Health Service.

• Make clear the intent of Sect. 2706 in the Affordable Care Act, to allow patients to see the provider of their choice when seeking treatment for pain and other musculoskeletal conditions.

• Expand access to chiropractic services in the Department of Veterans Affairs and Department of Defense healthcare systems.

• Expand access to chiropractic services in all other federal health programs, including research programs related to pain management.

Comments received by the CDC from the ACA and other groups will be used by the agency to ensure scientific quality and feasibility of the recommendations.

Interested parties may submit comments, identified by Docket No. CDC-2015-0112, by either of the following methods:

• Federal eRulemaking portal: http://www.regulations.gov. Follow the instructions for submitting comments.
• Regular Mail: National Center for Injury Prevention and Control, CDC, 4770 Buford Hwy NE, Mailstop F-63, Atlanta, GA 30341;  Attn: Docket CDC-2015-0112.

Note that all submissions received must include the agency name and docket number. Relevant comments will be posted without change to http://regulations.gov, including any personal information provided. For access to the docket to read background documents or comments received, go to http://www.regulations.gov.