As a part of my public advocacy on behalf of chronic pain patients, I “talk” with a lot of people on social media. Many are desperately searching for a doctor who will treat their pain. Many doctors have been terrorized by a DEA that has run amuck in its zeal to drive opioid analgesics out of common use and to persecute clinicians out of practice who employ such medications. Regrettably, some State Medical Boards have joined in the witch hunt.
The following is extracted from a longer patient narrative:
“I live in the state of Oregon and have been a chronic pain patient for almost 20 years. The Oregon State Medical Board is holding ALL physicians—including pain management specialists -- to the extremely low dose threshold of 90 Morphine Milligram Equivalent (MME) daily dose, based on the outdated 2016 CDC Guidelines.”
“If an Oregon physician crosses over that 90 MME dose threshold, they are issued a ’Complaint & Notice’ by the Oregon Medical Board -- which almost always then turns into a “Stipulated Order” In which the Medical Board directs that all of the physician’s patients must be “tapered to 90 MME or less, or transitioned to Buprenorphine.”
“The physician has absolutely no choice but to comply. If they do not follow the order, then further action will be taken against them, including possible loss of license, fines, etc… The only patients listed by the Oregon Board as exempt from the 90 MME in these ’stipulations’ are end-of-life, active cancer, or hospice patients.”
“The Oregon State Medical Board is causing patients dire harm with these Stipulated Orders, mandating widespread forced tapers that are strongly warned against by multiple Federal agencies. It is the patients that end up paying the price in dire harm, not the physician.”
I have verified each of the points raised by this patient, by consulting with Oregon State patient advocates who are in frequent contact with medical authorities and clinicians.
The present Medical Director of the Oregon Board (a key administrator who provides medical expertise to the Board, the Investigations program, and the Licensing program ) is Dr. David Farris. Farris has made any number of scientifically unsupported and prejudicial public remarks concerning patients and the relationship of the Medical Board to law enforcement. Likewise, the Medical Board is currently being advised by at least one rabidly anti-opioid “consultant,” Dr. Paul Coelho, who has in the past characterized all medical patients treated with opioids as “lotus eaters.”
This sorry record appears to continue and expand previous efforts of Oregon's Chronic Pain Task Force. The Task Force exemplified this same devaluing of patients and their needs, in their effort to mandate forced tapers of all Medicaid patients, regardless of the harm they suffered.
Lost in the deliberations of the Oregon Board are several inconvenient facts. Among those is that prominent leaders of several medical associations and academies published a letter in December 2018 that substantively discredited efforts by the Chronic Pain Task Force to mandate forced tapers on Oregon Medicaid patients.
Likewise of interest are several recently published papers. This new work establishes beyond any reasonable contradiction that there is no cause-and-effect relationship between rates of opioid prescribing by clinicians to their patients, versus either (a) hospitalizations for opioid toxicity or (b) mortalities in which a prescription opioid is involved. There has been no such relationship since at least as far back as 2012. As prescribing has declined by 60% since 2012, opioid-involved mortality has tripled. The so-called US opioid crisis is dominated by illegal street drugs -- now primarily illegally imported fentanyl – not by medical prescribing. Vulnerability to addiction is not driven by medical exposure, but by the conditions in which people live.
The Oregon Medical Board claims to be “aware of” the November 2022 published update to the CDC opioid prescribing guidelines, and to be updating their own “Opioid Philosophy” However, the Board ignores the fact that the CDC update is itself fatally flawed.
The November 2022 CDC guidelines fail to address genetically mediated variability in opioid metabolism between individuals, which produces an estimated 15-to-one range in minimum effective dose. Likewise, CDC has continued to use widely recognized junk science in Morphine Milligram Equivalent criteria which are unsupported by trials or by any form of real science. The American Medical Association has published profound disagreements with many of the conclusions that CDC writers drew from the literature that they cherry-picked to support their pre-existing political agenda of driving opioid pain relievers out of practice.
Although buprenorphine is FDA-approved for the treatment of pain as well as medication-assisted therapy for addiction, this medication is by no means a panacea for all pain patients. However, the Oregon Medical Board’s Summer 2021 Newsletter describes opioid taper and transfer to buprenorphine therapy as “new practice standards for the safety of our patients.” The Board’s current Statement of Philosophy on Pain Management advises: “Not all patients can be tapered to MME less than 90… As much as possible, patients should be transitioned to Medication-Assisted Treatment (MAT).”
This mandates a certain medication for all pain patients regardless of their individual needs. Even the CDC acknowledges that pain treatment must be individualized for each patient, in partnership with their doctor(s). Current Oregon Medical Board practice directly violates this principle with a one-size-fits-all mandate against the use of opioids in any context. It is highly apparent that the Oregon Medical Board is advocating for the effective desertion of patients who are already in agony.
Six academies and associations of medical professionals, representing over 650,000 practicing physicians and medical students have publicly declared that it is time to “end political interference in the delivery of evidence-based medicine.” The record of political interference, anti-opioid bias, and ignorance of well-established science among members of the Oregon Medical Board is glaring. Thus it is time for all members of this Board to resign or be fired for cause, due to their willful damage to patients and clinicians.
