SUBJECT: HHS–OS–2018–0027; Request for Public Comments on the Pain Management
Best Practices Inter-Agency Task Force Draft Report on Pain Management
Best Practices: Updates, Gaps, Inconsistencies, and Recommendations
Dear Dr. Singh:
On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of
Neurological Surgeons (CNS), we appreciate the opportunity to comment on the above-referenced
report. We are generally in agreement with the conclusions of the report, which we believe are solidly
grounded in evidence and a recognition of real-world medical practice. We thank the Task Force for its
thorough and thoughtful analysis and recommendations to address our nations opioid epidemic and to
offer realistic options for patients living with pain. The AANS and the CNS believe that the report
supports our view that reasonable mechanisms can be created to curb inappropriate opioid prescribing
practices while still preserving access to opioids to those patients who would likely benefit from them. In
addition, we commend the Task Force for its recognition of promising new and existing non-opioid
therapies, including devices, to treat pain and for its backing of adequate reimbursement for pain care.
Comments on Specific Recommendations
Section 2.1.1 Acute Pain General Comments. The AANS and the CNS support the Task Force
recommendations to mitigate opioid exposure in the perioperative period and the emphasis on
individualized treatment as the primary goal of acute pain management. We agree with efforts to
encourage appropriate reimbursement for pain psychology services to help identify issues that lead to
opioid problems and poor surgical results. Ultimately, the surgeon and the patient must weigh the risks
and benefits of acute pain control for an individual patient
…
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