CDC Guidelines: Drug Urine Tests for Pain Patients - Open Comment Until 1/13/16

The CDC has issued and open comment period for its 2016 proposed guidelines, intended to be used by primary care physicians, in prescribing pain medication (related to opioids).

While there are many guidelines, of immediate concern is those related to Guideline #10.

This guideline requests that drug urine tests be given to ALL pain patients using opioid prescriptions; with chronic pain being considered that which is longer than three months.

(Category B patients, according to the guideline, are those with active cancer, palliative, and end-of-life conditions. Cat. B patients are not expected to follow any of the other guidelines but #10. This fact is buried into the document with a “*” and the press release continues to make the false statement that the guidelines do not pertain to these groups, ignoring the single guideline that does.)

The short summary of the guideline softens the language found in the actual guideline, which discusses how insurance companies may not cover the costs of the urine drug testing, and that there are known issues with inaccurate readings (such as false positives and false negatives). Certain over the counter medication can result in flagging patients as having had speed (cold medicines) and cannabis (ibuprofen). For pain patients who happen to be parents and caregivers who care for a pain patient, incorrect results could result in CPS and APS investigations, for one example. Those with certain pensions, parole, or other situations may be unduly harmed by the risk of incorrect test results.

The more often these tests are requested, the greater the chance one will face an inaccurate result. Those who may partake privately in a substance without addiction issues may be unfairly labeled, and those who take certain herbal or alternative medicines – such as some Traditional Chinese Medicine tinctures – may find themselves excluded from pain management because of their intake of legal substances like California Poppy tinctures or Cannibals prescriptions.

The urine drug tests are designed to check for illicit substances, as well as other prescriptions (not necessarily other pain medication), and also to monitor the prescribed drug in the system. Presumably, too much or too little would indicate that the patient is misusing or abusing their pain medication. This does not take in account that some medication (such as patches) does not show up properly in all patients who are taking it correctly, or that patients can miss or add a dose depending on the daily situation in a reasonable and rationale manner. The accusation of the test could led to investigations of illicit sales of prescription medication, or a substance abuse issue. While this could be true, is this wide-net going to catch and harm the reputation of innocent persons? The potential for mistakes is there.

The ACLU has taken up the issue in the past when medical boards, or other regulating bodies, have made it a legal requirement. Guidelines are not mandated by law but doctors protect themselves from liability through following them. Guideline #10 suggests tests at least annually, but makes suggestions of performing frequent urine collection in order to test randomly. As mentioned before, insurance companies are not universal in the coverage of these tests.

Doctors can finically benefit from requiring the tests, as well as from the scheduling of additional visits, which could be lucrative in certain patients; whereas those who are not (and perhaps could be of more risk) may not receive the necessary attention to avoid signs of addiction – or – by their very nature of being non lucrative and high risk, the doctor may seek reasons as to not provide pain management care, which the guidelines provide ways in which a doctor can reduce their liability without guidance for how a patient can provide a rebuttal over their care. As medical records with doctor notes pass along from one doctor to another, many patients often report that a damaged reputation follows them and impairs their ability to request a sincere reevaluation of their situation. Pain patients have their prescriptions maintained in a State run databases, which can be viewed by doctors within the same State to determine the pain medication history.

Please consider sharing your comments (until 1/13/16) on the proposed guidelines at:

http://www.regulations.gov/#!documentDetail;D=CDC-2015-0112-0001

You can read more at (with guidelines quotes and important page numbers):

http://www.inspire.com/NetiNeti/journal/cdc-requests-pcps-mandate-drug-urine-test-for-all-pain-patients/

Or coverage of the CDC at: http://www.painnewsnetwork.org/search?q=cdc

These are quotes from the guideline:

"10. When prescribing opioids for chronic pain, providers should use urine drug testing before starting opioid therapy and consider urine drug testing at least annually to assess for prescribed medications as well as other controlled prescription drugs and illicit drugs. "

"*All recommendations are category A (apply to all patients outside of active cancer treatment, palliative care, and end-of-life care) except recommendation 10 (designated category B, with individual decision making required); see full guideline for evidence ratings."

"Category A recommendation: Applies to all persons; most patients should receive the recommended course of action,

Category B recommendation: Individual decision making needed; different choices will be appropriate for different patients. Providers help patients arrive at a decision consistent with patient values and preferences and specific clinical situations"

Here is a snippet of the expanded text for guideline #10, I made some spaces so that it is easier to read:

"Urine drug testing results can be subject to misinterpretation and might sometimes be associated with practices that might harm patients (e.g., stigmatization, inappropriate termination from care) Routine use of urine drug tests with standardized policies at the practice or clinic level might destigmatize their use. Although random drug testing might also destigmatize urine drug testing, experts thought that truly random testing was not feasible in clinical practice. Some clinics obtain a urine specimen every visit, but only send it for testing on a random schedule. Experts noted that in addition to direct costs of urine drug testing, which are often not fully covered by insurance and can be a burden for patients, provider time is needed to interpret, confirm, and communicate results. "