ACS CAN submitted comments regarding the Proposed 2022 CDC Clinical Practice Guideline for Prescribing Opioids. While we support certain changes in the Guideline - including a clearer exemption for cancer patients and patients receiving palliative care - we continue to have concerns about the misapplication of this and the previous Guideline.
Opioid Taxes and the Importance of Maintaining Access for Cancer Patients & Survivors
Cancer and Pain Treatment
Pain is one of the most feared symptoms for cancer patients and survivors - nearly 60 percent of patients in active treatment and 30 percent of patients who have completed treatment experience pain. Pain can be caused by the cancer itself, for instance when tumors interfere with normal body function. Pain can also be caused by cancer treatments. Research has concluded that about one-quarter of women who have had breast cancer surgery have significant and persistent breast pain six months after the procedure.
Despite the fact that millions of cancer patients and survivors experience chronic pain, it remains a highly stigmatized issue. But given proper attention most pain can be treated and relieved. Integrative pain care that includes non-drug therapies along with medications is effective in keeping patient pain under control. While not the only tool, opioid medications are recognized as a mainstay of treatment for moderate to severe cancer pain and can be a beneficial treatment for managing serious, persistent pain for patients in active cancer treatment as well as cancer survivors. If not treated, chronic pain can have long-term negative effects, including prolonged recovery and a weakened immune system. It can also affect a patient’s quality of life; their ability to eat, sleep, work and carry on every aspect of their daily life.
ACS CAN supports balanced policies that address the public health concerns relevant to the opioid epidemic that do not harm patient access to medications that they need to treat pain appropriately.
Some state policymakers have recently considered instituting taxes on opioid drugs. New York passed a law in 2017 that taxed opioid manufacturers and distributors and used the tax income to fund opioid addiction and treatment and prevention efforts, though the law was struck down by a federal judge. Several other states have debated this type of policy. Proponents argue these taxes are a method of raising needed funds to address the opioid epidemic in the U.S. Opponents raise concerns that such taxes are not well-tailored to cause behavior change in opioid users and might discourage generic manufacturers from selling opioids.
ACS CAN Position
It is critical that cancer patients and survivors have access to the pain treatments they need, including opioids when clinically appropriate. ACS CAN does not oppose opioid taxes, as long as the cost of the tax is not levied on to the consumer or passed onto the consumer in the form of higher costs.
 Institute of Medicine. (2011). Relieving Pain in America: A Blueprint for Transforming Prevention, Care, Education and Research. National Academy of Sciences.
 Miaskowski C, Cooper B, Paul SM, et al. (2012). Identification of Patient Subgroups and Risk Factors for Persistent Breast Pain Following Breast Cancer Surgery. J Pain; 13(12) pp 1172-1187.
 Randazzo, Sara. Federal Judge Strikes Down New York Tax on Opioid Industry. Wall Street Journal. December 19, 2018. https://www.wsj.com/articles/federal-judge-strikes-down-new-york-tax-on-opioid-industry-11545253207