Inter-Agency Task Force Draft Report on Pain Management Best Practices: Updates, Gaps, Inconsistenci

Docket ID: HHS-OS-2018-0027 Agency: Department of Health and Human Services (HHS)

In response to request for public comments about Inter-Agency Task Force Draft Report on Pain Management Best Practices: Updates, Gaps, Inconsistencies, and Recommendations . The Draft Report I believe that at this point in time (2019), a patient centered, ethically sound, multimodal management of individuals suffering with pain should include the option of medical cannabis in states that make it an options for their citizens. As a physician, practicing in the state of Pennsylvania, I have found that patients with various chronic pain conditions, including Migraine, Fibromyalgia and various arthritic conditions have had significant benefit in outcomes important to them including function and well being as result of including medical cannabis in their management. Most impressive are the results for individuals with severe pain, refractory to various of the procedures outlined in the report. These patients have undergone multiple surgeries, required high doses of Opioids with only partial relief. Medical Cannabis, lowers pain intensity, often helps them function better and facilitates improved sleep. The addition of medical cannabis is usually well tolerated. My clinical experience of close to a hundred patients, is consistent with the conclusions of the National Academy of Medicine’s Committee on the Health Effects of Marijuana that, "In adults with chronic pain, patients who were treated with cannabis or cannabinoids are more likely to experience a clinically significant reduction in pain symptoms." Additionally, There is a growing body of literature, consisting of basic science, animal models, clinical studies, population studies and anecdotal evidence as to the potential role of cannabis in the medical setting in general and in the management of pain in particular. Various national and international entities, based on systematic review of relevant studies have recommended a role for medical cannabis, others have questioned the evidence for any role. Regardless of the "lack" of evidence based that meets "usual" criteria for inclusion in guidelines, more and more individuals suffering with pain conditions, pay out of pocket to have access to medical cannabis. For example. A study that appeared in Health Affairs, (One of the authors is member of the Task force) noted that there were at least 813,917 individuals who had sought legally certified medical cannabis in 2017 and of those chronic pain accounting for 62.2 percent of all patient-reported qualifying conditions. The study found that “of all patient-reported qualifying conditions, 85.5 percent had either substantial or conclusive evidence of therapeutic efficacy.” In a study prepared for the prepared for the Colorado Department of Revenue . Light et al. (2014) reported that 94 percent of Colorado medical marijuana ID card holders indicated “severe pain” as a medical condition. Similar findings about users of medical cannabis were reported in Minnesota. A study by Boehnke et al., (2016) reported survey data from patrons of a Michigan medical marijuana dispensary suggesting that medical cannabis use in pain patients was associated with a 64 percent reduction in opioid use . Similarly, Bradford and Bradford’s, (2016) analyses of prescription data from Medicare Part D enrollees in states with medical access to cannabis suggest a significant reduction in the prescription of conventional pain medications . They conclude that “Combined with the survey data suggesting that pain is one of the primary reasons for the use of medical cannabis, these recent reports suggest that a number of pain patients are replacing the use of opioids with cannabis, despite the fact that cannabis has not been approved by the U.S. Food and Drug Administration (FDA) for chronic pain.” As a citizen, I believe that an expert task force, tasked to inform congress in its efforts to address the challenges of pain management and opioid use has the responsibility to address the challenges and opportunities associated with medical cannabis.