As a chronic pain patient and someone with a rare disorder under the NORD criteria, I would like this rule to take effect as I am constantly denied opioid pain management in the ER and told to go to a pain clinic by my primary care physician. I believe that all chronic pain patients deserve adequate relief so they aren't constantly living in pain where it impacts their lives.

Since when did my life become less important than an addicts life? Your removing opiates from pain patients so try and prevent addicts on the street from getting their hands on them and overdosing, it’s already been proven the overdoses are NOT coming from prescription medications, we have an fentanyl crisis not an opiate crisis and pain patients are committing suicide by the thousands due to being cut off or tapered down so low they can’t handle the pain. I’ve been on the same dose same opiate for 22 years and I’m being cut off. So I will have zero quality of life. And you don’t care as long as you can save that addict on the corner that isn’t asking to be saved. We’re paying the price and sadly you have lied to physicians and told them Washington state doesn’t have an MME limit yet your sanctioning them for prescribing over the 90MME limit and now physicians don’t trust you so they refuse to go back to treating pain regardless of how you word it. It’s a matter of time before the suicide deaths out number the overdoses because it’s happening already. Prescriptions have been cut down 96% yet the overdoses continue to rise so that tells you right there it’s not coming from prescription medications. I will no longer be able to play with my grandchildren, I will no longer be able to maintain my home living alone, my life will be nothing more than sitting in a chair, suffering, waiting to die. Pretty sad when we have to beg God to take us just to get some relief from the pain and nobody cares. You should be so proud.

I’ve been on pain meds for well over a decade, close to two now, and when my pain doctor just disappeared on me and all her patients, I and many were left panicking. It became horrifically clear how hard it’s become to get help EVEN for people on pain meds for almost 2 decades who have 0 abuse history and issues, who have never taken a single pill out of line- to get ANY help. My PCP “wasn’t comfortable” multiple pain docs that took weeks or more to get into “weren’t comfortable” or said “because the laws and crackdown on opiates… sorry.” I got so stressed over the fear of going into physical withdrawals from being suddenly cut off because my doctor just disappeared after this whole time managing my pain, because of her I got out of a walker and wheelchair I had been doomed to in my early 20s, I got so stressed because I was watching my meds disappear and kept being told no no no that I got SHINGLES from the stress. The living hell I was forced to go through for no damn reason. Do we not matter to anyone?? Of course help protect addicts but what about responsible pain patients suffering from horrific conditions?? I shouldn’t have my life at only 36 dangled over my head like this, I have enough torment just being alive as is. I have contemplated suicide so many times because of pain and what my disability has taken from me, and believe me, taking the only thing away from me that’s helping give me ANY quality of life back isn’t what’s going to stop me from ever doing that, it’ll cause it. Funny what being given stable housing when poor from disability and given STABLY prescribed medication can do for someone’s mental and physical wellbeing. An addict will go anywhere they can and risk anything to get those meds to use, why are we making it harder for people prescribed these meds for serious reasons to get them?? How is that helping anyone?? My sister died at 21 thanks to her taking unperscribed ativan that was laced with fentanyl, she was murdered by whoever did that to that ativan. Maybe if it hadn’t been so hard for her to get ativan for her serious anxiety symptoms, maybe she’d still be here. And maybe even if she was taking that more recreationally- I knew she had bad anxiety and was struggling to get it prescribed but she might also have been taking more than she should have knowing how she was unfortunately- but maybe at worst if she was taking it for the wrong reason, maybe if whoever she got that from had had an easier time at LEAST getting it from a doctor easier, maybe at least it would have been normal ativan and not laced to kill her. I don’t understand how making it harder to get life saving medication helps anyone, even addicts. All that does is kill and destroy the lives of responsible patients like me, and it also makes it harder for people like my sister to at least have found a way to get that from someone selling it from a real prescription at least. That just means less real and safe meds like that on the street and more $$$ in criminals making drugs that kills pockets. It was the same argument when it came to deciding legalizing marijuana here. They ultimately decided doing that meant less money in criminals pockets, more regulation with legalization and tracking that better, and more people who used that for pain being able to get it without risking jail or being laced and murdered. Unfortunately for me marijuana doesn’t help, it conflicts with a psych disorder I have and I just don’t like feeling the effects of being high like that at all. It’s beyond ridiculous that I’m someone who hates drugs for how many people I’ve lost, how many exes I’ve cried and begged to stop using and hurting themselves I’ve dealt with, being forced on adderol as a minor when wrongly diagnosed with adhd when it was a schizophrenia disorder that they forced an amphetamine on top of, I was forced to live in a literal nightmare world for 7 years as a minor and no one listened or cared, I’m lucky to be alive still and don’t know what even kept me here through literal hell.. just to end up like this. Apparently begging doctors when cut off from a drug that would cause severe physical withdrawal pain and sickness to help me. A drug that I’ve begged an ex to stop abusing and hated every second of watching people I loved misuse what I now NEED to function. It’s incredibly angering. They had no problems getting this illegally, while I ended up with shingles from the severe stress and panic of being cut off and it taking over a month to find a doc who finally emergency helped me and still he ended up tapering off my oxycode which was my ONLY breakthrough pain med because his clinic has a policy like most saying they can’t prescribe a benzo and opiate at the same time… which I was on for decades!! Do people not even understand how many people with pain disorders also have severe anxiety disorders?! So now we have to chose between dysfunctional pain or dysfunctional anxiety? I was forced to loss my oxycodone thanks to that, my sleep meds I need nightly are also a benzo. That also would mean being driven insane not sleeping again, I already can hardly sleep with the max amount of sleep meds allowed, that runs in my family, none of us can sleep even on the max amount of that and no one knows why. What’s funny is, I haven’t refilled my MONTH supply of oxycodone in almost a year now but I still have about 12 pills left. If that says enough about being a responsible pain patient. That WAS my breakthrough pain meds. That’s what I would take to be able to do my artistic shoots that I use to vent my really bad mental breakdowns, now I can’t without pain, or taking some of the last pills I might ever have. That was for a big day like the rare moments I can do something like go to a theme park or a fun event that I know I’ll have to try my hardest to function like a normal person for the day. That was to help me ideally NOT be in a wheelchair. That was so I can keep up with my bf and his family when camping one week the whole year. I have nothing for that once those couple pills I’ve clung to for almost a year now are completely gone. And for what??? An addict WILL find ways to get that same medication, will I? Clearly not. I know the risks and don’t want to end up like my sister, though that shouldn’t be something I’ve even have to risk or think about just to have more quality of life like anyone else. I envy everyone who doesn’t live like this and doesn’t personally understand the living hell that this has caused untold amounts of people in my shoes. PLEASE stop hurting us and help us. It’s already SO hard and feels like a fulltime job I can’t keep up with fighting advocating managing my body that’s trying to kill me. PLEASE help us make this life any less miserable. What about when WE end our lives because we couldn’t take the pain we are left in anymore??

Please stop the war on pain patients. Everyone deserves ADEQUATE pain relief.

I’ve been through it all. Having two doctor’s retire one because of the fear of the opioid crisis and 2016 guidelines. His partner although agreed I should be on the amount of pain meds didn’t want to prescribe them and refused to take over cause. I’ve had to search for doctors willing to keep me on my current amount which are very far and few because of the 1016 guidelines I’m over the mme amount. I’m one of the lucky ones that has some of my pain controlled for the most part. But that’s not without a fight. I don’t go to appt alone anymore cause being a female in pain I’m not always listened to. I e had my pharmacy that I’ve gone to for decades deny me my pain meds cause they didn’t agree I should be on them. The mme limit shouldn’t exist but instead a limit of how well pain can be controlled . Doctors are more then willing to do surgeries that most of the time just cause more problems then they fix. Please he chronic pain patients become people again.

I am commenting on the petition Maria Higginbotham submitted on behalf of all of us who have intractable incurable painful disabilities and all others who are suffering with needless pain after surgeries, from car accidents, end of life etc. Doctors in Washington state no longer treat pain. We all are being tortured instead of treated and I don't believe anything will reverse this now. I do hope the Washington medical commission can do something to force doctors to care about the disabled again. My story is the same as every other disabled person. i started having this daily gnawing pain 15 years ago. Before any opioids ever were prescribed we tried over the counter medicine, biofeedback, counseling, PT and many off use prescriptions until it was proven that only opioids would help me. Until 2021 I was stable at 120 me on a pain contract with zero problems with my primary care provider at Valley medical. After over 15 years at Valley and 7 years with this provider, she retired. No one at Valley would continue my care and honor my pain contract. I've been told that the doctors at Valley are required to sign a contract of employment that prohibits them from prescribing opioids. Since then I've been to 2 pain clinics with caregivers who don't care. I've been put on Suboxone, listed with OUD now in my records and red flagged at first pain clinic. The Clinic I'm at now refuses to go above 50mme (the latest CDC "guidelines"). I was stable at 120mme for 7 straight years with no red flags. I loved being with my huge family at holidays and our other gatherings, going to be with friends and I loved volunteering. I loved walking my little dog out in the sunshine, planting some vegetables and flowers, etc. Since 2021 I have done NONE of that. I can no longer grocery shop, clean house and it's too painful to shower as often as I should. This is not a life worth living. I no longer hold hope for a change because all the doctors have been schooled how to justify NOT prescribing and all they have to do is makeup whatever they want to say about you in the chart. I appreciate the effort WMC is working on these rules changes and completely agree with the need. I do feel the doctors and PAs in Washington need to somehow fear the DEA less, ignore the addiction doctors who know nothing about treating pain and you need to mandate stronger that they get back to the ethics and paths they took which includes to "cause no harm".

Re: WAC 246-919 Opioid Prescribing Rules Submitted in Honor of Gretchen I. Introduction — Gretchen’s Story and Petition Background Last July, I filed a petition requesting specific changes to the WAC rules that govern opioid prescribing in our state. I filed this petition after watching a dear friend suffer from a forced taper that was initiated in 2022. I wanted to make changes that might save her. Unfortunately, in December 2024, she became ill with pneumonia and was taken to the University of Washington, weighing less than 100 pounds, unable to walk or swallow. She was diagnosed with ALS and passed away just 10 days later. I didn’t save her—but I hope my efforts might save the next patient suffering from a forced taper, bedridden in agonizing pain. This public comment is submitted in her honor. II. Purpose of the Petition This petition and rule revision project seek to protect chronic pain patients—especially those with rare, progressive, or palliative conditions—from the devastating consequences of rigid opioid policies. It proposes evidence-based revisions to WAC 246-919-850 through 985 that reflect clinical realities, uphold ethical treatment standards, and align Washington’s rules with national best practices. III. Core Concerns and Justifications The current opioid prescribing rules have resulted in patient abandonment, medication delays, and forced tapering—often without regard for individual medical needs. Substantial clinical and regulatory evidence supports reform: - FDA PMR 3033 (2025) found that patients using long-acting opioids under physician supervision showed

I have endometriosis. I’ve had 6 surgeries. My doctor finally send me to pain management. You know what pain management told me?! “We don’t treat that” it’s really painful, my life has changed so much. I can’t be a mother anymore. Other doctors have told me the same thing. “NO” when questioned, they all say they can’t because they’re being watched. Then when finally I was given some from my doctor after two years. Then the pharmacist decided I don’t need them?! Because they have laws they told me. Not ok. I need my life back. I need to care for my kids. Never before have I ever needed pain medication until now. And I am being denied and punished. Please help me. Please do something.

I have been suffering with pain from a number of chronic health issues. I have tried so many off label meds that didn't work and caused more complications from side affects. I finally started being treated with opioids and successfully so, however, I have been forced to taper to where I am undertreated. I am becoming less able to get out of the home and have asked my primary care Dr. to help me consolidate my treatment and even though it is within the current rules he has refused and has been pushing suboxone. Because I don't want suboxone, he will not help me. The pain clinic I go to tells me I am maxed out which is not true, according to what I read from Wa State med. Commissioners rules. I am looking at losing the bit of pain relief I do get because my PCP is unwilling to due his duty. I have also had troubles getting my prescriptions filled and have to go every 2 weeks instead of 28 days as it used to be. i have had no problems in my records. Now I am also being forced to see the pain clinic every 28 days because I am over 50 mme a day. I've been being treated since 2011 and have never had a dirty UA of any behavioral issues. It should not be so difficult for me or anybody, to be treated with an effective medication.

As a chronic pain, patient who has been on opioids and fentanyl patches for over a decade I can speak to the unfair, stigmas and judgment, the chronic pain patient’s face from providers who are afraid to prescribe near 90 MME. It’s thanks to my pain management that I have been able to volunteer for patient organizations related to my chronic illnesses, lobby in my state and Washington DC for legislation and policies affecting chronic pain, Rare, disease, Ehlers-Danlos Syndrome, and disability patients like myself and millions others. We know that patients who are doing well on their pain management should not be tapered to appease a specific MME number, if the patient is doing well and their pain is managed their pain management and medication should not change due to any bureaucratic rule. Providers are the ones who should determine patients pain management. For chronic pain patients who have been on opioids for years, it’s essential that providers understand that our postoperative or acute pain management will look different from a non-pain patient. Too often, my pain management provider has had to write pain medication for a postop surgery for which she did not do, has little understanding of, and is not her responsibility to manage the postoperative pain of; however, due to other providers, feeling the fear of being punished for providing over 90 MME, too often the responsibility falls, unnecessarily and inappropriately on my pain management doctor to manage my postoperative pain as well as my chronic pain. Please support our chronic pain community and our providers by ensuring language that empowers providers to prescribe as they see it for chronic pain, and postoperative pain for chronic pain providers, ensuring chronic pain patients aren’t unnecessarily punished, put through undo pain, or put at risk for suicide Due to unnecessary or inappropriate tapering of their pain medication. Thank you for your time and consideration, and please support this amended language.

I have multiple long term chronic illness. Im on palliative care for Breast Cancer and the effects of surgeries and chemotherapy left me debilitating pain! I didn’t ask for cancer and the pain BUT I AM ASKING FOR PAIN RELIEF!!! PLEASE DONT’T TAKE PAIN RELIEF FROM ME! CANCER ALREADY STOLE SO MUCH OF MY LIFE!! PLEASE! I take opioids just to get through daily life. I’m NOT an addict- I just want to live a semi-normal life without excruciating pain. I receive care from a pain clinic and without my regimen I truly wouldn’t have a quality of life. I can barely walk, bathe myself, dress myself or do daily tasks as it is. I BEG you to PLEASE allow me to live a decent quality of life. My medication allows me to get out of bed! I have spinal stenosis, hEDS, osteoporosis,osteoarthritis,degenerative disc disease,a fractured back, and that’s only a few that I deal with DAILY! I don’t get “ high” or any type of “euphoria” from my daily pain management routine. I GET PAIN RELIEF just to move around without excruciating pain! PLEASE LISTEN TO US CHRONIC PAIN PATIENTS!! We deserve to live with dignity and respect. With all due respect, WE AREN’T ADDICTS!!! We just want to live WITHOUT EXCRUCIATING DAILY PAIN just like you and your family. OPIOIDS CAN SAVE LIVES!!!! Sincerely, A CHRONIC PAIN PATIENT THAT JUST WANTS TO LIVE

Since the “opioid epidemic” began chronic pain patients have been collateral damage in the effort to find an answer to the opioid issue. They have had their medication cut or discontinued suddenly and for no reason. Most stable chronic pain patients have been taking opioids for years without issue and yet they were the ones who were punished for the opioid problem. Many chronic pain patients have either been forced to take street drugs or have ended their lives because of the situation created by the various regulatory agencies. This Commission and this rule are an opportunity to begin to rectify this by allowing doctors the freedom to treat pain patients without fear of prosecution and will allow chronic pain patients to have their pain treated with the proper doses of medication rather than some arbitrary MME number that is entirely too low for most chronic pain patients who have been taking opioids for many years. Please do the right thing and correct the mistakes that were made by the regulatory agencies and give chronic pain patients their lives back. This medication allows pain patients to live, to play with their kids, to interact with their family, to go to work, or even just to get out of bed. Give them their lives back. Thanks

Hello - I have a rare disease and several comorbidities. One of the difficulties of managing this condition is that many medications cause extreme side effects or do not function in the same manner they would for a “typical” patient. Over the last many years, I have tried 40+ medications to control pain and associated symptoms. I’m unable to safely tolerate many classes of mediations. I use opioids - safely and within my prescription limits because they offer the best pain relief I am able to tolerate. It often feels stigmatizing when discussing care, finding a new doctor (I’ve only had to switch once due to retirement, but finding clinics who are comfortable prescribing opioids was challenging). Chronic pain patients aren’t taking these meds for fun - I finally agreed to try them when I was unable to play with my children many years ago after trying everything else I and my care team could think of. We take them to lower pain (never to zero) and maintain whatever quality of life we can, often in the face of difficult, rare, life changing, and permanent injuries or diagnoses. Fighting the stigma on top of managing difficult conditions is exhausting and disheartening, and I’’d appreciate any rule changes that made that struggle slightly easier. Thank you.

Opioids are a necessary tool in the toolbox of chronic pain patients especially patients like myself with hypermobility spectrum disorders. This is a genetic collagen defect which is turning out to be much more common than previously thought. I was not diagnosed until almost 40 even though I have been having excruciating lower back spasms since I was 11. But guess what. Opioids have been part of my life for decades, but I have never become dependent. They exist as a key tool among many other tools that I use to manage myself. I am the success story I am because of opioids. Imagine dislocating your vertebrae and how excruciating it would be to feel like you are being torn apart without anesthetic. Imagine knowing for certain this will happen to you three to four times a year. Tell me how you would have the confidence to go out and exercise and do physical therapy and do all the things you need to do in life, If you didn't have pain management for those excruciating times. What happens to me is basically a spinal subluxation. The vertebrae move too far because the ligaments aren't doing their job to hold them together, So the muscles clamp down in pain pill spasm damaging the muscles, in a desperate attempt to hold the body together. The nerves in that area are extremely sensitive so the pain is excruciating, 10/10 pain. When I am down with one I cannot get out of bed to access food and water and the toilet. I am completely helpless with our opioids and would die. Once, my husband urged me to try harder and push through the pain in order to get out of bed... I did and was left screaming on the floor in agony, unable to lower myself to the floor or climb up to the bed for 15 excruciating minutes. It was mentally traumatic. With opioids it is still extremely painful but I managed to lift myself out of bed a couple times the first day a few more times the second day and on and on to make the two week long process to return to normal function. I have suffered extreme mental trauma when one time a doctor decided that I should not be prescribed opioids. It would be like going into surgery and suddenly being told you don't deserve anesthetic. Inhumane, barbaric, It is a war crime to deny pain meds to victims even in times of war. Why are responsible American citizens with legitimate disability and pain being treated less than enemies in war?

I have been suffering in silence because doctors will not prescribe hydrocodone for my chronic pain which I took as needed for many years and only at night with absolutely no issues from patient or doctor. I was always prescribed a count of thirty and used as needed which fluctuated in duration longer than thirty days. I would go back to my doctor when I needed it refilled. Over the past eight years it has been a struggling battle as doctors were becoming more and more fearful to prescribe. About four years ago, I was forced to chose either sign a form that said I would not abuse this opioid drug or be refused being prescribed the requested thirty day supply I had always been given before policies were regulated on doctors. I respectfully signed the document, but at the cost of my integrity as it then labelled me a seeker. I went to physical therapy as requested that did not help with my chronic pain. I was forced to try other medications that did not work because doctors refused to refill the opioid prescription. One drug I was prescribed caused more harm to me leaving me in more pain. I am now labeled a seeker because I keep asking to have my opioid prescription refilled that has not been refilled in over two years. I suffer in agony from the chronic pain, isolate, struggle at work because it is hard to put a full day in which I fear being let go. We have treated a controlled drug as if it is a street drug labelling everyone who seeks it an addict or a criminal. I respectfully ask that the rules, policies and regulations affecting the controlled opioids be rewritten with the understanding that patients and doctors do not abuse them.

To Whom It May Concern, I am writing to address the upcoming decisions regarding pain management guidelines. I am a lifelong friend of a chronic pain patient, a friendship spanning over 30 years. Over the past 11 years, I have witnessed my best friend’s physical health deteriorate. She suffers from SLE Lupus, Ankylosing Spondylitis, and is a carrier of the PalB2 gene. She was once an active individual, deeply involved with her family and friends, enjoying camping trips and weekend excursions. Today, there are days when she cannot even get out of bed. After beginning pain management, it took nearly 18 months to find a treatment plan that provided some relief. Although the regimen isn’t perfect, it has restored some quality of life, enabling her to participate in select activities if planned properly. I accompanied her to appointments and saw her endure a grueling trial-and-error process with various medications, infusions, and procedures. Eventually, a regimen of opioids, taken every six hours, allowed her to manage her pain. This treatment gives her the ability to complete everyday tasks such as showering, attending appointments, and other activities most of us take for granted. However, every two months, she faces immense anxiety over her upcoming pain management appointments, uncertain of what changes might occur. Despite her compliance—accurate biological samples, correct pill counts, timely refills, and consistent attendance, she constantly has to fight to maintain her medication. It feels unjust. She is prescribed only 80 MME, yet finding compassionate providers who treat patients with the care they deserve has become nearly impossible. When drafting the new guidelines, please ensure they explicitly state that withholding treatment or enforcing tapering without justification contradicts the rules and is unacceptable. Please remember that the choices you make will profoundly affect real individuals—mothers, fathers, sons, daughters, and friends. This could even impact your own loved ones. I implore you to consider what I have shared and trust that you will make the right decisions for people like my friend. Thank you for your time and thoughtful consideration.

Please hear the chronic pain patient cries. So many have lost crucial prescription pain medication from their doctors after the flawed CDC guidelines that they’ve admitted conflated prescription overdoses with illicit fentanyl overdoses to push thousands on addiction Medications. People within the CDC who helped to write those prescribing guidelines have been found to have been paid by the makers of the addiction medications and have high conflicts of interests! The DEA has been going after small time innocent doctors who are Treating their patients with prescription opioids who have severely painful disabilities, and illnesses where all other medications have failed. These people are not addicts and want their form of quality of life back. So many of these patients are US Veterans who’ve now sadly, committed suicide. And not just Veterans, you can read plenty of stories of Moms, Dads, Brothers, Sisters, friends, who’ve also sadly taken their own life as to not have to be punished to live in debilitating pain because the DEA has targeted and ruined so many kind & compassionate doctors and destroyed their careers and reputations for trying to help these people. And no everyone’s afraid to treat them. It has created a devastating environment for both Doctor & Patients alike. Please hear their cries! They’re trying to stand up to Bring awareness. But, Big Parma has bottomless pockets and are always able to control the narrative. Chronic pain patients are NOT drug seekers! They wants to be productive members of society. Please help us all! Thank you for your time!

As a 62 year old woman I have gone through a lot in my life. I raised 3 girls to adults and through college. During my 20-30's I had a total of 16 surgeries all major surgeries. I was given opioid medications for approximately 4-6 weeks so I could rest and heal and return to work and caring for my children. I didn't fear having to have the surgeries back then because I knew my doctors would take care of me and keep me comfortable. I still had pain but it was bearable. I had extra pain meds to take at night so I could sleep. After 9 surgeries on my intestines and bowel, advancement in medicine had a genetic testing that showed a problem that they could finally treat with medication. I never had to continue pain medication past the post op period. Fast forward 20 years, I get hit from behind by a semi truck fully loaded. My vehicle was knocked over 300 feet to another street. My back was broke, torn rotator cuff and knee. Thankful to be alive. For months I used Tylenol and Motrin for the horrific pain. I couldn't take the pain any longer. My primary care doctor prescribed me Norco 10 4 x a day and a small dose of long acting Hyslinga. After a few months, I was sent to a pain management doctor only because my primary care doctor told me he couldn't continue to prescribe for fear of arrest. My mouth drops as I had no idea of the new found opioid prescription hysteria. So I got to pain management. I figured pain management would continue my current treatment since I was comfortable and still able to work. Nope. Pain management insisted I get epidural injections because my insurance would cover it and it's supposed to help with back pain. I knew nothing about them and figured no Physicians could do anything that wasn't FDA approved. After several of these injections my pain was worse. Plus pain doctor stopped the long acting medication because of DEA fear. So then ablation was the next best thing. So I'm doing ablation. Oh my GOD. I thought I was going to die from the headache that lasted 3 months. I was miserable. Not only was my pain care destroyed, and since now I can not work, Medicare is being milked of thousands. THOUSANDS. Before Interventional Pain clinics, I paid an office visit and had a running prescription every 3 months. Medicare was charged for urine screens at pain clinic. I had to do pill counts like a toddler. So when I question why they were counting my pills, I was told ' to make sure you are not selling or diverting them". I was shocked. I laughed and said " well if I didn't need the medications I wouldn't have had all those 6" long needles jammed in my back all these years and I sure couldn't sell all the prescriptions for the amount I pay to come here". So pain doctor was then mad at me for speaking truth and common sense. I then learned of the DEA and Narxcare and how HIPAA doesn't protect your medical information if you are a pain patient. So another layer of discrimination. Isn't pain a symptom of something wrong in the body? Isn't pain a health care condition? I since learned that you are treated as addicts, pay a price as if you are an addict even if you are like me and never did an illegal drug in your life. Now, the " addicts" get synthetic Opioids to keep them comfortable. WTH??? So, I worked, raised a family, always obey the laws of the land , but I am a criminal because my body is broken? Doctors are being arrested because they meet face to face with people and try to control their pain? What country am I in now? So since my experience with pain and how pain patients are treated, I have poured myself into research. I have learned of the corruption of how the CDC guidelines came about and the damage they have caused. I have learned how PROP went from having to treat patients to making millions on opioid lawsuits. The most UN AMERICAN thing I have learned is that pain is not the number 1 cause of veteran suicide. UNACCEPTABLE. Totally. Treatable pain, and people are dying so that profiteers can try and have chronic pain patients labeled as addicts or the new profitable OUD diagnosis. All of this is disgusting for the medical community to sit back and allow. Then my mother had pancreatic cancer. I had to argue and fight and get ugly to get her pain controlled?? So she could pass away peacefully and not in screaming pain? Good Lord, please stop the madness and give our educated, licensed doctors the freedom to treat patients. Make it an actionable offense if they refuse to treat , not an offense if they treat pain. It is draconian and barbaric to allow anyone to suffer in pain when we have safe, effective and inexpensive Opioid medications that were invented for just this purpose. Yes there will be people that will abuse. Yes there will be overdoses. Just like with alcohol. Yet alcohol isn't a necessity yet still available even though deaths happen because of it. We all can live without having a beer. We can live if our bodies are injured or diseased and the pain is unbearable. Please bring mercy, compassion, and common sense back to chronic pain care. It IS a matter of LIFE or DEATH.

I appreciate that the voices of people suffering are finally being heard. My husband is a chronic pain patient and suffers so much with his pain. The doctor is force tapering him to the level that is comfortable to the doctor's own fear. My husband has rapid metabolism of medication and requires a higher level of pain medicine. We have chart notes, surgery notes, blood tests, and 3 doctors who agree to his rapid metabolism but we can't find a pain doctor to help my husband. Referrals to pain doctors are rejected when they see his pain needs. Our government is responsible for starting this "war on pain patients" and now the doctors are fully complicit. I implore to you to do what is right, and help the people who live in pain on a daily basis!

Hopefully they will do something soon for everyone suffering! I was used as a pin cushion having Medicare milked. The last procedure ended with me in the ER 4 months ago and I still have numbness in places I shouldn't have. The Dr who did the procedure didn't even answer calls from the ER Dr while he was caring for me. I have had numerous of these procedures and never This problem. Before I moved my pain control was managed with just medication and all of the rules and then some doctors thinking you are automatically an addict if you are on opioid they want to just do procedures when because of other comomorbidities I'm not even supposed to have these procedures but they are willing to risk my actual life. I've been in pain management 15 years and never not one failed drug test or write up or anything and with same Dr but I had to move out of the area and problem started with new Dr. They treated me not according to my pain but as Dr actually said their OFFICE POLICY. These doctors now have the taste of making the big bucks for procedures instead of just a refill appointment. I feel that's going to be the problem if anybody tries to straighten this out. We need primary care doctors to be able to prescribe again. Interventional pain clinic have the taste of making 10k off of Medicare in 15 minutes as opposed to the PCP making 100 for 10 minutes. So interventional pain clinics will never give up that big money. How did they get Medicare to pay for non fda approved epidural injection that can cause paralysis? Some more back scratching? Medicare pays millions in urine screens. Worthless urine screening. If anyone wanted to divert medicine they know when their doctors appointment is to have their medicine in their system. It is beyond ignorant to be paying for such workers urine screens. Plus 7k non fda approved epidural injection? Profiteers have hijacked Medicare and will milk the funds dry so the next generation will lose out on Medicare benefits. Why? Because there are millions of CPP. What use to cost 500 a year for treatment, has costed my insurance 58k so far this year and the results are not as good as just the medication alone. Opioid medicine works. It controls pain. Nothing else has worked as well. It is inexpensive. I've been put on Bupe and Suboxone medicine and neither of those worked for pain. Thankfully my doctor listened and put me back on my Opioid medicine after my blood pressure wouldn't come down due to pain. After only a few months on the bupe films my teeth melted out of my mouth. So add 9 k for my teeth to be pulled and now disgusting dentures. It is draconian how pain patients ate treated and members of PROP need prison time.

I am a long term Chronic Pain Patient who has suffered in pain and agony ever since the so called "opioid Crises" began. I was cut off ALL of my meds by my Doctor, despite my begging him to slowly taper me. I have been in search of any Physician to help me. I appealed to the Medical Commission many toms. All without success. Doctors who do not relieve pain is the new norm. I wholly endorse these new changes to the rules and can only hope that someday soon, I will be able to find adequate pain relief. My last attempt to find a doctor was yesterday. She told me they no longer prescribe opioids for pain. Suboxon is the new norm. She said she was "So Very Sorry " that I was prescribed opioids for over twenty years. I asked her, Why would you be sorry that 90% of my pain was relieved for over twenty years? These new young doctors are being Brainwashed in Medical School at a very young age. She kept saying we have found them to be ineffective (opioids) we have found them to not relieve pain, we have come to the conclusion that opioids are bad. I asked her, who is this "We" you are talking about, she said the instructors in medical school and her fellow doctors. I asked her Have you ever been prescribe opioids for pain, she replied no she had not. I asked her why would you take advice from someone who was never prescribed opioids for pain, over a patient who had taken them for over 20 years and found great relief. I thanked her for her time, she said, wait a minute, don't you want me to prescribe something for you High Blood Pressure, it is extremely high, I told her that if my High Blood Pressure killed me, it would be a Godsend that would finally relieve my Chronic Pain. I am contesting Medicare to refuse to pay for her services as she did nothing to relieve my pain

I am a chronic pain patient that has suffered under the newer opioid restrictions. I have CRPS, fibromyalgia, migraines, SPONDYLOLITHIASIS, plantar fasciitis- pain is my everyday existence. Before the 2016 guidelines that were interpreted as a mandate, I recieved good pain control. Since then, I have endured a failed spinal cord stimulator that began shocking me for 20 min at a time. I had to kill the battery to get it removed because medical professionals would not believe me- I had to show a video of me convulsing uncontrollably to prove it was happening. I have been prescribed every off lable drug for pain, instead of relief I got headaches, chronic kidney disease, weight gain and was told to use a keto diet to loose weight despite having a gfr of 60 or less. I have a slight advantage over most pain patient in that I have a nursing degree. I knew that following the keto diet advice would further damage my kidneys and make me require dialysis. I fired that prescriber. Currently, I have been seen by a pain clinic since 2022. The entire time, I have had minimal access to full agonist opioids (3) 5mg hydrocodone per day with belbuca. The hydrocodone is not enough, and the belbuca causes debilitating headaches. I take ubrelvy for the headaches (originally prescribed by the pain clinic PA, now by neurologist because the new PA refused to file insurance prior authorization paperwork) I have tried reducing buprenorphine dose at my request, stopping buprenorphine product - helped headaches but left me in pain from my chronic pain conditions, so still stuck not having quality of life. I have tried changing from 15 mme hydrocodone to 16 mme hydromorphone, but only recieved dosing 2 x per day. Which left 16 hrs per day in agony. I have switched to buprenorphine patch with 1/2 hydromorphone pill 4x day, and headaches return. The long acting MS backorder was sighted as the reason she would not order a trial of morphine when insurance denied restarting buprenorphine products. I get good relief with dilaudid 2mg 4x a day, yet they think that's too high of a dose. The same provider prescribed belbuca 300 twice a day, despite my complaints of headache with buprenorphine. Again, I had to ask each time for a dose reduction, they wanted to increase my dose despite me not tolerating it. They have continued prescribing buprenorphine for 3 yrs with reports of intolerance every check up. I do not experience intolerance with the full agonist opioids. I take my medication as prescribed, submit and pay for "random" drug screens at EVERY appointment. But am not really offered informed consent. I know the respiratory depression risk and have had dilaudid at much higher doses (180/month) without any problem, but I'm restricted to 2 per day and told that if I want long acting relief my ONLY option is a medication that I don't tolerate. The assault against opioids harms me EVERYDAY. ADDICTS have better access to opioids than I do. I'm being continually punished for the actions of addicts, who sought self medication from the streets. We need overdose deaths to record how the drugs were sourced (legal vs illicit), legitimate prescriptions are tracked and when they don't have a prescription it's obviously been acquired by illicit means. These death are the result of criminally acquired drugs, yet legal prescription are being restricted. Restricting legal access will never stop illicit acquisitions and OD's. But prohibiting legal access will push desperate pain patients to seek relief either through streets or suicide. Tolerance is developed in numerous medications- diabetics often require dose adjustments, blood pressure, blood thinners need frequent adjustments, yet when a pain patient needs adjusted dose they get labeled as an addict. I do not seek euphoria, but I do want to have more than 1hr of consistent pain relief where it doesn't take effort to distract me from pain. When your baseline is 6 or higher, quality of life declines sharply. ADL's become exhaustive and unmet. Bodies need to be moving, pain medication allows us to get OOB and be mobile. Restricting access is forcing us to be sedentary, which is a know risk factor for so many co-morbidities. Disability pay is poverty wages, traditional opioids are cheap, yet we are forced onto expensive buprenorphine products that rot our teeth, which Medicare will not treat, which leads to malnutrition. We need access to opioids, please allow changes to the language that will protect my access to these lifesaving medications.

My elderly mother was force tapered from only 40mg of hydrocodone to 20 several years ago and strong armed into infusions, more physical therapy, gross amounts of gabapentin (then pregablin) and high amounts of ibuprofen and additional Tylenol to "treat" her debilitating Rheumatoid Arthritis, Severe lower back damage with scoliosis, osteoarthritis and Fibromyalgia pain. I've watched her mobility worsen because of UNDER treated pain. Her primary Practitioner literally told us " I cannot prescribe more, it's against the law" and when I pressed her on that fallacy, she dropped my Mom by "referring" her to pain management which also is Not Treating her pain. They insist on epidural spinal injections that have NOT WORKED. This mindset is all over multicare network and it's slowly stealing my mom's mobility and giving her almost no quality of life. She's not the only one. I've talked to so many others experiencing the same neglect! People just don't know they can push back or question! They don't feel good enough to fight, don't know they even can. Without an advocate these patients just DIE suffering. I can go on and on with dates, times, experience so feel free to contact me! This has to stop now. Every single one of us is ONE injury or serious illness away from needing appropriate pain relief. None of us are getting younger. Please help us.

Over the past decade I have dealt with nonstop issues getting my chronic pain addressed, since relocating home to Washington. I had a wonderful pain management clinic in Georgia that offered PT, counseling, opioid prescription pain relief and random drug testing. My quality of life is night and day different since relocating back for family. I had my surgery at Virginia Mason in Seattle in the fall of 08, due to nerve damage and chronic pain at the surgical site I was kept on opioid pain medication and muscle relaxers. This care transferred well when I went to Georgia. Upon return to Washington in 2014, I went back to Virginia Mason and they would no longer prescribe. I had to try psychological medicine with enormous side affects with no pain relief. I did injections in my back as well as the testing for nerve ablation, neither worked. Trying to find a provider to treat me took 7 years. 7 years of spending most days on a heating pad, nearly all of my daughters elementary year and into middle school.. The doctor I found at CHI Franciscan was wonderful, he had suffered a similar injury to my own. Under his care, I was referred to have steroid injections again, that again did not work. He prescribed oxycodone and skelaxin, but a lower dose than I had been on previously as he said he had to stay within certain limits. It was better than nothing. I could do more than the previous 7 years. Then chi Franciscan and Virginia Mason merged. Initially nothing changed, but abruptly, November of 24 my doctor was gone, no notice or explanation. The new doctor I was assigned to gave one script and said it was “policy” that I would receive no further medication and referred me again to their pain management clinic that only does injections/procedures. I left that day in tears, didn’t reschedule and fell into a deep depression for several months, stuck on a heating pad again majority of my days. I finally went on my chart and asked that new doctor to refer me to an outside pain clinic that would keep my treatment plan I had. I was elated when I saw the referral in my chart. Tried calling the new clinic several times to make an appointment, no response. Then I decided to go back in MyChart so I could print out the referral he sent; IT WAS GONE. So now I’m stuck. I have missed a good portion of my daughter’s life and now I’m going to loose the rest as she enters high school. All because of political agendas over a fake “opioid crisis”. Less than 1% of pain patients are addicts, less than 1%! People, like myself, are punished, our lives made miserable over nothing but propaganda. If it weren’t for my child, I don’t think I’d bother even trying anymore. Life isn’t enjoyable when you have no mobility, everything becomes sheer will to do, so only the basics, if that, get done. My back, bottom and back of thighs are discolored from living on a heating pad. I have severe muscle atrophy and weakness and no help. I sincerely hope that changes are made, to give us suffering a quality of life. No one should have to suffer endless pain.

Please stop demonizing people with chronic pain, while catering to IV drug users. After breaking my back, I was told to use advil and tylenol and offered injections and a nerve ablation. Not only did any of that not treat my pain, I now have life threatening issues because of it. Doctors should be treating pain, not bureaucrats.

I am writing in support of Maria Highenbotham's petition. It's beyond time pain patients are no longer treated like criminals for seeking care and pain relief. As a patient diagnosed with 3 rare chronic pain conditions, I need help to receive appropriate care. I am in pain on a daily basis. I have difficulty using the stairs in my home. I have difficulty sleeping because the pain increases at night. I am currently allowed 30 Percocet to last me two months. The majority of the time I just beat the pain but I also work full time and need to be able to function. I'm not allowed adequate pain relief and not given any alternatives while addicts are given free medication sometimes multiple times a day to save them from overdoses. Chronic pain patients with legitimate prescriptions are not the cause of the crisis. Research has proven this. The CDC admitted their statistics did not deliniate between deaths from illegally obtained drugs and deaths from prescription drugs. I have chest pain on a regular basis because of my conditions. When my pain flares up, I'm told by my doctors to go to the ER. I refuse to go because I am treated either like it's just anxiety and told to go home and think good thoughts. Or I'm treated like a criminal and a drug seeker and told to go home with no help. It is a right of every person to receive adequate medical care which includes appropriate and adequate care for pain.

Please keep the prescribing of opiates in the hands of providers, professionals who have been trained to assess the needs and conditions of their patients. An arbitrary underlying diagnosis (such as "cancer") is not the only reason for chronic pain: there are numerous common under-reported/ diagnosed conditions (such as Ehlers Danlos Syndrome), as well as many rare diseases, that leave patients suffering with chronic pain. Please allow ALL patients that suffer from pain the opportunity of relief, under the same compassionate and careful prescribing guidelines.

I support the recommended revision to opioid prescribing rules for MDs and PAs. The proposed changes promote individualized, evidence-based care by clarifying that stable, compliant chronic pain patients should not be forced to taper or discontinue opioid therapy, as doing so may cause harm and fall below the standard of care. Removing predetermined MME thresholds aligns with federal guidance and reflects current medical understanding, while proposed exemptions for patients with rare diseases ensure these individuals receive appropriate, compassionate care. These updates support both patient safety and provider accountability through clear, current, and effective regulation.

I hope this message finds you well and in great spirits. I am writing to express my deep concern regarding the ongoing unjust prosecution of physicians who have dedicated their lives to treating millions of suffering Americans. These actions not only undermine the essential trust between doctors and their patients but also threaten the very foundation of medical freedom in our nation. Many of these cases appear to be politically or financially motivated, with parallels to the false and unjust persecution you have personally endured. These hardworking doctors deserve our protection, not persecution, for their commitment to improving lives and upholding the Hippocratic Oath. I also urge you to direct Attorney General Pam Bondi to immediately disband the Health Fraud Prevention Partnership (HFPP), a public-private collaboration heavily influenced by the insurance industry. This organization wields unchecked power that compromises the autonomy of medical professionals and restricts patients’ access to necessary care. It poses a significant threat to the health and well-being of countless Americans. As someone who has tirelessly championed the rights of everyday citizens and battled against injustice, I believe you have the ability and the resolve to bring an end to these injustices. Your leadership in protecting medical freedom would resonate deeply with millions of Americans who value both their health and their liberty. Thank you for considering this important issue. I trust in your commitment to justice and the American people’s well-being, and I am confident that your decisive action will help restore fairness and integrity to our healthcare system.

Chronic Pain Patients have been suffering for over 9 yrs, since CDC 2016 Guidelines, the 2022 revision never changed a thing in any state that I'm aware of. I've contacted CDC & received in writing the following info: the guidelines were never intended for Chronic Pain Pts or Pain Management Dr's. It was for Acute Pain, Primary Care Dr's, ER Dr's, etc. Some of the examples listed were for pts who " may be" diverting....or possibly having an issue with OUD or Addiction. NOT Chronic Pain Pts w legitimate pain, following rules & protocols/regimens of treatment set for them. Those receiving benefits of pain relief especially when benefits were outweighing any consequences. Those who may be not receiving benefit, Diverting, suspected OUD, etc. COULD submit drug screen test, COULD be asked for pill counts, COULD Be asked to be seen every month or more often than those not having issues. NOT as a form of PUNISHMENT JUST BECAUSE THEY ARE A CHRONIC PAIN PATIENT! When did becoming a pain pt become a CRIME? or why are most, if not ALL CPPs looked at as Addicts drug seeking, not to be trusted, treated like Parolees, gaslit by Healthcare, whispered about in the halls of clinics, side eyed at the pharmacy, yelled at by Emergency rm techs, literally laughed at & ridiculed on social media, and I could go on!! Fact is ANYONE could become a CPP in any second of any day! Vehicle accident, work injury, bad diagnosis, etc. You or your loved one?? Your children?? Some you know will be affected! When did finding a dr to treat your pain at a level that's livable to you , therapeutic doses, not this 25 mme per day which is for a sprained ankle! Turn into something worse than a JOB INTERVIEW?? What gives Healthcare workers the right to belittle us? There are millions of pain pts, I think we pay quite a bit of everyone involveds salaries! Insurance premiums! Pharmaceuticals! Not to mention ice pks, heating pads, spinal stimulators, tens Units, etc. $$$ No one deserves to be belittled and while we are feeling our worse! Not everyone is on disability, many of us work full time plus jobs! Professional jobs. Entry level jobs. Doesn't matter. We are doing the best we can. Did some PATIENTS make the rest look bad? Sure! Did some Dr's deserve a sentence? Sure! But it's not all.pts or all Dr's! Some Dr's genuinely care for their pts. Should they have to worry about their reputations & homes? Not to the extent that they want nothing to do with CPPs! What happens when CPPs can't get the treatment they need? Some never leave their homes, never see Dr again, some completely deteriorate, some actually have unalived themselves. Some go to street for pain relief in other drugs & end up w ILLICITLY MANUFACTURED FENTANYL- which has been the downfall of PAIN MANAGEMENT!! It doesn't need to be this way! Without some guidance by the States & Federal Gov, CDC , and even the DEA, things will continue to go downhill. How many have to go from happy, productive Citizens to broken, degraded pain pts - to no fault of their own!! I don't believe any state truly knows how cpps are treated, living, dieing, and just wanting to end this life of pain . No other medical group or condition gets treated like this! There are medical conditions that are far worse than some of the pain patients but they at least get some respect, dignity, sympathy & empathy! It's time to let those who know best in this field to treat those who need them most!! I could repeat facts & statistics but feel yoy have that info & irs time to hear some truths from those living this daily and some fir decades! If we're all addicted, qe wouldn't be working, if we're all.diverting we wouldn't be in pain, if we're using street drugs, most wouldn't be around anymore. Mamy cpps have been dealing w their pain for 10,.20,.30 plus yrs. Still here, still healthy minus our pain issues, still raising our families, taking care of our homes- find me addicts that have all this going on & managing it while in some really bad pain 24/7. Thank you!

As someone living with Ehlers-Danlos Syndrome and running a support group for others with chronic illness across Washington and the Pacific Northwest, I urge you to support this bill. Many of us suffer from persistent, often debilitating pain. I’ve watched friends lose their lives—some by suicide—after being forcibly weaned off the medications that allowed them to function. Others have died misusing medications out of desperation. These are preventable tragedies. We’re not asking for unlimited prescriptions. We’re asking that providers be allowed to treat chronic pain based on the individual needs of their patients—without arbitrary restrictions tied to a cancer diagnosis. Personally, I recently broke a bone in my foot. I have a sensory processing disorder and don't always register pain the way others do, but even I have had moments of tears and immobility from the intensity of what I can feel. Yet I was offered no pain relief. Over-the-counter options are limited for me due to liver issues, and I’m already on daily aspirin and Celebrex. Many in my community have even fewer safe options. Pain management must be humane, individualized, and accessible. Please allow providers the freedom to prescribe appropriate medications to all patients with chronic pain, not just those with certain diagnoses. Thank you for considering the needs of people like me—and the many who can no longer speak for themselves.

Please support this bill returning to physicians the right to prescribe opioid medications as they believe is in the best interest of their patients. I have multiple chronic health conditions. Although I do not require constant pain medication, the current rules have so affected doctors that many of my doctors are afraid to prescribe opioids even for the occasional needs I have. Don't eliminate pain relief for virtually all legitimate users on the grounds that there are some who are abusing those meds.

Thousand of patients with severe intractable pain (chronic pain) are being harmed, stigmatized , tapered, taken off (without consent) the only medications , that properly treat these severe conditions, leaving patients like myself in torturous PAIN 24/7 I have numerous conditions , that cause me horrific pain. Diagnosed with severe spinal stenosis arthrosis, scoliosis, osteoarthritis DDD , fibromyalgia just to name a few. Since the guidelines, so many ppl have lost access to their life saving medication, that for many are now bedbound, no longer can work, unable to sustain life , cook , clean, shower , family time etc etc etc This is wrong on So many levels, many are being tortured. This has got to stop , we need the guidelines 86 . When is eough is enough? Isn't it time pain stigma ends ?! We need our Drs, the DEA, is only hendering the chain of medicine causing unnecessary stress, on both patients and Drs. Drs should not be living in fear of their livelihoods, this entire scheme puts shame , unnecessary pressures on Drs and patients alike, not to mention PTSD , Dr patient relations is being destroyed. Since the CDC guidelines in 2016 patients have been gaslighted, shamed, neglected, ignored, etc etc. Intractable pain, chronic pain is a serious medical condition that requires treatments, just like any other serious medical condition It's time it's taken seriously, our lives Matter ! We need our Drs who stand with us , believe in the sacred Oath to DO NO Harm . This is absolutely pertinent to the care of ppl in pain, cancer patients, rare diseases , vets etc Thank you Sincerely your's, RB

WMC needs to advise doctors that if they refuse to prescribe the proper amount of pain medicine based off the patients history with previous doctors and at the same level proven to work with stable proof in the medical records they will lose their license. With MRI, X-ray and CT scans in records and the previous doctor's pain contract never broken, no early refills and no bad urine tests on file doctors who lower doses anyways or refuse pain medicine completely need to specially be told they will lose their license. Falsifying medical records in the Drs mind to make the government happy is against the laws of their license. Refusing to honor and abide by the terms of a pain contract when taking over care for a chronic pain patient should be illegal. Making patients unstable by reducing the medication that has worked for years under another doctor should never be allowed and should be illegal and enforced by the law. It's been 4 years since I had 7 years stable on 120 me. When my doctor retired I was forced tapered to 50 me and my life has been ruined since then. Now my records falsly show I am stable at 50mme because that's the max I can get. If you consider not being able to shower without inflicting extreme pain on myself stable. Stable in not being able to grocery shop, do laundry, clean house and cook for myself. Stable in being stuck at home. Doctors and their clinics need to be forced to put us legacy patients all back on the higher doses that gave us quality of life.

I am suffering from several painful chronic conditions. Also major ptsd. My doctors have forced me to taper off my 5 \325 Norco x 6 per day. My pain was bearable. Not gone, but I could live. Now no pain meds, and they are tapering me off my lorazepam against my will. I am suffering so much physically and emotionally. The doctors don't want to hear it. I am 67 years old and wish I could pass away. This is not a life.

Please allow providers the freedom to prescribe pain medications to ALL patients with chronic pain as needed" . This could change so many lives!

Thank you for considering chronic pain patients who have been left out of decision making for over a decade as PROP pushed their agenda into all of our chronic pain doctor’s prescribing practices. I was diagnosed with an incurable, unpredictable and very painful condition over two decades ago. When my treatment began, it was individualized and I was able to commute 2 hours each day, work 10-12 hour days, raise two teenage children as a single parent-as well as attend to daily cooking/household responsibilities. Since the “opioid crisis”, manufacturers lawsuits and PROP mandating the more expensive buprenorphine as the gold standard of care for BOTH substance use disorder and chronic pain (despite no reliable data buprenorphine is truly effective for chronic pain) my medical ‘care’ has drastically changed. Also in spite of the fact that I tried in complete good faith to find an alternative effective medication/treatment (believe me- if there was an effective medication/treatment for my condition other than prescription pain medication, I would absolutely LOVE that. Dealing with not only the lowered dosages, but the abhorrent discrimination and hostile treatment by doctors makes this treatment the absolute LAST one I would select if I had any kind of a choice). As a brief illustration-this list is much longer, but I am giving the top highlights to save time: •Despite my body adapting to the medication (tolerance ~that EVERY doctor is aware of), my dosage has been lowered and lowered and lowered for zero medical reason. •I have been subjected to open door urine tests (in a HALLWAY, no less, with perfect strangers walking by the open door). •The medications I tried in good faith and with much initial hope caused intolerable side effects-one causing me to lose my driving skills to the point I couldn’t determine what side of the road I needed to drive on. One caused me to arrive at a classroom that I had been attending classes at every day for the last three months (for work) and being unable to find my way home (having to call my partner to give me turn by turn driving directions to find my way home). • Some of these side effects took WEEKS to leave my system. Conversely , prescription pain medications give me no disruptive side effects whatsoever- they relieve my pain so I can focus on details and my task at hand. •I am subjected to the PDMP; which (other than benzodiazepines & medications for things like ADHD) NO OTHER patients requiring critical life saving medications are subject to. •I am only allowed ONE pharmacy for my medication and if they don’t have it in stock, I am forced to go without. • In addition, when the prescription is finally filled, the ‘clock’ that my medication fill date is allowed gets reset to the new date. For example, if my fill date (exactly 28 days from the last fill date- which leaves you with zero medication at the beginning of the day until you can drive to the pharmacy and obtain the filled prescription) is Tuesday and the pharmacy is out until Friday, that means I am without medication Tuesday, Wednesday, Thursday and at least half of Friday as the pharmacist usually can not complete the prescription until the afternoon. This resets my new fill day to Friday instead of Tuesday. • Despite using the same pharmacy for over two decades, I am occasionally subjected to nasty comments, tones of voices and even made to go back to the end of the line if the pharmacy hires new people with anti-opioid bias (and there are more people that blame chronic pain patients whose only effective treatment is Rx pain medications for the deaths of their friends/family than not.) • So not only am I under-medicated for no medical basis, but I am treated like a criminal by the entire medical establishment from appointment setters to pharmacy staff. One particular pharmacy staffer would yell out the name of my medication when alerting me it was ready to pay for- making me vulnerable to any criminals within earshot that were inclined to assault me and steal my medication. Some would tell me they ‘were out of bags’ for me to conceal my medication in. These are hardly the only issues with this medication. Please believe me when I reiterate that I sincerely wish ANY. OTHER. MEDICATION. OR. TREATMENT. WOULD WORK FOR ME. LITERALLY ANY OTHER. To date, I have not found one in the least effective. So from two decades ago with the lowering of my medication dosage, the constant stress of when and IF I would have my medication this month, my ability to work has decreased from 50-70 hours per week to about 10. My income has decreased from about $130,000 per year to about $25,000. I had to declare bankruptcy and I lost every asset of value I owned. I have gained 30 pounds that I’m unable to lose (and can’t afford GLP medications as I don’t have commercial insurance. My average blood pressure has gone from 110/65 to 130/85. I believe this is my body’s indicator of chronic untreated pain and for any other condition, it might not be considered proper medical treatment. My sleep apnea has worsened causing greater pain levels and brain fog. I feel there is a significant lack of “care” in my medical care. Because I take a medication that other people abuse, I am held to a my higher standard of behavior & proof than any other patient taking a medication required for ANY quality of life. Depending on who is making decisions for me- with zero consultation with my doctor or I- people like the DEA or PROP can decide to lower the manufacturing quota to zero, the manufacturer of the medication can use any adulterant in the generic recipe which can render it less effective in my one-of-a-kind body chemistry and I literally have zero power to change any of this. If a patient with diabetes requires more insulin for her body chemistry, she gets it. If my body chemistry requires more pain medication, I am shamed, blamed and typically told I’m an addict and my only option is methadone or buprenorphine (despite having NO behaviors used to truly define substance use disorder). Sadly for me, after I gave in and tried both it was found that I am allergic to them. Also, the mandatory daily SUD meetings were both baffling, expensive and not helpful. I could not relate to any of the stories or suggested changes to my life. For example, I coukd not imagine taking a full bottle of medication without stopping to the point of overdose-as I heard more than once. (I wasn’t taking medication to avoid life; I was literally trying very hard to get physically to the point where I could live it to the fullest with less pain.) The use of morphine milligram equivalent (MME), when it is truly researched and the science behind it evaluated without bias, has no real validity. The concept is further eroded by the fact that everyone’s body chemistry and genetic ability to metabolize Rx pain medication is absolutely unique. Similar to snowflakes or fingerprints, no two humans metabolize pain medication exactly the same way. To equate a dosage exactly the same for a 280 pound male and a 130 pound female is ludicrous on its face. When you add in differing genetic makeups, it stretches the credibility beyond belief. There is literally no medical science to justify using MME in any guideline, yet that is what current chronuc pain treatment guidelines say: individualized care UP TO 50 MME- despite the fact that FDA has no individualized limit for these medications. In a further example of absolute discrimination between people with SUD and chronic pain, when SUD patients are treated with buprenorphine for THEIR medical condition-the MME allowed for them (despite the fact that buprenorphine IS LITERALLY an opioid) HAS NO MME CEILING LIMIT. Chronic pain care is rampant with discrimination as to who “deserves” effective treatment vs SUD treatment where it seems as if the system ‘bends over backward’ to benefit the person with SUD~despite the fact that overdose deaths from buprenorphine are now higher than those from oxycodone/hydrocodone. Again, NO other patients and NO other medications are singled out like chronic pain patients where Rx pain medications are the LAST RESORT. Imagine if a patient needing insulin or blood pressure medication was loudly & publicly harassed and her prescription not filled for days. I suspect this would be treated as malpractice. For patients with chronic pain we have absolutely no recourse. No attorney will even CONSIDER taking a case for a patient with chronic pain who has been under-treated with prescription pain medication. Not one. It is the polar opposite from our society’s approved lawsuits against pain medication manufacturers and doctors who prescribe these medications-lawsuits that have been filed by states attorney generals in virtually EVERY STATE. So, to come upon this petition for relief and to be able to make public my testimony of trying to not give up hope to have quality of life despite being undertreated by my medication of last resort, I am beyond thrilled. My hope is that the stories from me and other CP patients will finally provide a true understanding of what CP actually go through. It is my further hope that this will result in advocacy that actually overturns the discrimination and mistreatment we CPP have been living with for decades now. Lastly: All humans are vulnerable to this situation of untreated & under treated chronic pain. All of you are just one accident or incurable medical diagnosis away from being exactly where I am. It is my hope that you can work to make changes before this affects you or your loved one. I would not wish this situation upon anyone. Thank you for your kind consideration.

This is an outcry yes please help pain refugees get what is needed to help them have a small portion of their lives back . Many have died , many are being tortured to ☠️ Pain stigma need to End ! . Painful conditions require treatments just like any other serious medical condition.. Pain Matters! Period ... Do no harm is a oath Drs need to live by the health and well-being is crucial n critical for giving proper care . .This is dire , we also need the guidelines for prescribing to be 86

From: Susan Hope In Support of the Petition Submitted by Maria Higginbotham I am writing to share my personal experience and to support the petition filed by Maria Higginbotham. I speak not just for myself, but for the many patients across Washington who have been abandoned or harmed under current opioid prescribing policies. My pain journey started when I was a child. I lived back east and was frequently bit by ticks. My grandparents were frequently taking me to the doctor but it wasn’t until late adulthood I found out I have Lyme disease along with other medical problems. For more than 24 years, I was safely and responsibly prescribed two opioid medications, along with a muscle relaxer (Soma) and a benzodiazepine (Klonopin). These medications allowed me to function and maintain some quality of life despite serious medical conditions and long-standing PTSD. I never misused my medications, and I lived with stability for decades — until my doctor retired. The first doctor who took over my care — the one I now refer to as the “Superman cape doctor” because he said he was leaving to go fight the opioid crisis — reduced all of my medications drastically in a single visit. He cut both opioid medications, my Soma, and my Klonopin by more than half in both dose and quantity. I had done nothing wrong. There was no medical reason given. It was simply because I was taking those medications. That same pattern continued with the next doctor at the same clinic. She is younger and told me directly that “opioids don’t help pain.” She also wants me off my medication — not because of any issue with me, but because of her belief system. Like the first doctor, she keeps pushing Suboxone, even though I do not have an addiction and have repeatedly told her I will never go on that drug. Every appointment with her gives me panic attacks. I avoid going to the doctor now because I do not feel safe or respected. Since being destabilized, my PTSD has worsened dramatically. I experience severe overstimulation — everything is too loud, too bright, too overwhelming. I’ve become housebound and bedbound. I rarely see my children or grandchildren anymore. I don’t go out. I don’t enjoy life. My insurance doesn’t approve surgeries anymore, and I feel like I’ve been discarded. I’m 65 years old. I did everything right. I took my medications safely for decades. And yet I’ve been treated like a criminal — not a patient. This is what happens when policies override clinical care and humanity. Please pass the petition that Maria submitted. It reflects the truth for so many of us who have no voice left. We deserve compassion, not punishment. Respectfully, Susan Hope Washington State

I am disabled by severe, chronic pain and am writing in support of the petition for requested changes of opioid prescribing rules to MD WACs 246-919-850 through 246-919-985 and PA WACs 246-918-800 through 246-918-935. The war against the opioid epidemic has resulted in chronic pain patients becoming unintended victims of unnecessarily strict prescribing regulations. I have a rare, genetic disorder that’s getting progressively worse. It’s incurable & treatment is limited. It mostly affects my joints, spine, muscles, and nerves. I grew up in a spine brace & now (at 50 yrs old) use a cane, walker, and/or wheelchair when necessary. Although I’ve long had some level of disability, in recent years I’ve become so immobilized by pain that I rarely leave home. A short trip to run errands puts me in agony for days. It hurts too much to go out with friends- I’ve lost them. I’m afraid to do simple activities & cause myself more pain. It wouldn’t be this bad if I still had access to opiates. I have NO history of substance use disorder. I dislike the side effects of opiates, so took them as sparingly as possible when they were prescribed. I was a responsible patient for years, and fortunately wasn’t physically dependent on them, because I was cut-off without a taper in 2016 through no fault of my own; the clinic closed. Then the new federal guidelines came out and most doctors became too afraid to prescribe opioids at all for chronic pain & even for acute pain. Despite worsening pain & degeneration, I’ve been unable to get a prescription for opioids since 2016 (except once for 5 days post-surgical). It’s dangerous and cruel to cut stable patients off of pain medications, especially without tapering. Since 2016, I’ve gone to a few pain management clinics & tried various non-opioid methods that insurance would cover: injections, gabapentinoids, antidepressants, corticosteroids, physical therapy, chiropractic, OTC meds, etc. But none would eventually prescribe opioids when alternative treatments were insufficient, even during flares or injuries. I’m exhausted from relentless pain & being treated like a drug-seeking addict. Frankly, I’m not sure how much longer I can endure this constant agony with no relief in sight. The drastic overkill is unnecessary and harmful. Please consider these changes to the opioid prescribing rules so they aren’t an obstacle to adequate healthcare.

As a husband caregiver to a chronic pain patient living with rare diseases, including a connective tissue disease, impacting every aspect of her health, causing disability, and severe daily chronic and acute pain, I have seen how difficult it is for chronic pain patients to receive adequate and effective pain management and care. Please adopt Maria Higgenbottom’s amendments so that opioid prescribing serves best the Patient’s healthcare, and ensures patients are not unnecessarily tapered, or taken off of their pain medication and pain management program, which we know so often leads to unnecessary suicides with an understandable lack of hope from the patient’s perspective. Being a caregiver husband means that I am the one to pick up my wife’s pain medication’s, and so often I hear that they do not have enough of her pain medication in stock, and it leaves a scrambling to call our doctor to get another prescription to another pharmacy to ensure the continuation of my wife’s pain, medication and management, and it can leave me feeling hopeless for helping her. Please protect chronic pain patients and their providers ensuring both can provide the proper level of pain management for each patient, as we know every patient is unique and different and needs a different uniquely tailored to Care, especially in pain management.

I apologize for duplicate comment, I tried to edit my original but couldn’t. Please accept this as my official comment. From: Susan Hope In Support of the Petition Submitted by Maria Higginbotham I am writing to share my personal experience and to support the petition filed by Maria Higginbotham. I speak not just for myself, but for the many patients across Washington who have been abandoned or harmed under current opioid prescribing policies. For more than 24 years, I was safely and responsibly prescribed two opioid medications, along with a muscle relaxer (Soma) and a benzodiazepine (Klonopin). These medications allowed me to function and maintain some quality of life despite serious medical conditions and long-standing PTSD. I never misused my medications. I have no history of addiction — only a past history of cigarette use. I lived with stability for decades — until my doctor retired. The first doctor who took over my care — the one I now refer to as the “Superman cape doctor” because he said he was leaving to fight the opioid crisis — reduced all of my medications drastically in a single visit. He cut both opioids, my Soma, and my Klonopin by more than half, in both dose and quantity. I had done nothing wrong. There was no medical reason given. It was simply because I was taking those medications. That same pattern continued with the next doctor at the same clinic. She is younger and told me directly that “opioids don’t help pain.” She also wants me off my medications — not because of any concern about my behavior or my health, but because of her belief system. She keeps pushing Suboxone, even though I’ve told her repeatedly that I do not have an addiction and will never go on that drug. Every appointment with her gives me panic attacks. I avoid going to the doctor now because I do not feel safe or respected. Eventually, I tried calling the original clinic in Anacortes, where my longtime doctor used to work. There are many doctors in that office, so I hoped one might be willing to take over my care. But when I called and told the receptionist I was looking for a new primary care provider, she didn’t ask for my name. The very first thing she asked was, “Do you take any opioids or benzos?” I paused and said, “Yes…” And immediately, she said, “None of our doctors are prescribing those anymore.” That moment hit me hard. It was clear that patients like me are being screened out — not based on our behavior, but based on the medications we need to survive. It was frightening and deeply dehumanizing. I also want to explain that I didn’t start out needing daily pain medication. For years, even before the last 24 years of consistent use, I would try to tough it out. I avoided meds as much as I could and would only take opioids in short bursts when absolutely necessary. I’ve always believed in natural health, exercise, and using as little medication as possible. But now that I can’t get adequate pain relief, I’m no longer able to exercise at all. My health has declined. I’ve gone from being active to being mostly bedbound. The truth is, I’ve had pain since childhood. My grandparents took me to doctors over and over again because they could see something was wrong. But no one could figure it out. Years later, I learned I had chronic Lyme disease — likely from repeated tick bites growing up back East. I now know that was the source of my lifelong pain. But for most of my life, it went undiagnosed. Since being destabilized, my PTSD has worsened dramatically. I experience extreme overstimulation. Everything is too loud, too bright, too overwhelming. I rarely see my children or grandchildren anymore. I don’t go out. I don’t enjoy life. My insurance no longer approves surgeries, and without adequate care, I’ve been discarded by the very system I trusted. I am 65 years old. I followed every rule. I was a compliant, careful patient. And I’ve been treated like a criminal — not a human being. This is what happens when rigid policy replaces clinical care, compassion, and common sense. Please pass the petition Maria submitted. It reflects the truth about what’s happening to real people like me. We deserve compassion, not punishment. Respectfully, Susan Hope Washington State

I have been in significant, life altering pain for more than half of my life. I tried quite literally everything under the sun prior to seeing a doctor about the pain I am experiencing. Any OTC patch, cream, spray, rub, and medication I could find. I tried Chiropractic adjustments, Physical Therapy, meditation, stretching, heat, cold, aquatic therapy, you name it, I tried it. Then, I tried multiple prescription meds before I ever relented to try opioid pain meds. Several of those, as well as some of the other things I tried before, actually made things worse for me due to experiencing adverse effects (some rare) and a couple of life threatening events. I can't take a variety of medications because I have reactions to them. Either adverse effects or outright allergies, including anaphylaxis. When my doctor started me on opioid pain medication, it was the first time that I can truthfully say that I got real pain relief. After a couple of years of adjustments, we found the combination and dosages that worked for me. Well enough that I was preparing to get my first ever job. Then, my doctor got wind of the CDC's guidelines coming out and I was cut in half overnight. I experienced further reductions after that due to the demands of my insurance. I am now at a level where I am getting by. Not living. Not thriving. But I am getting by. Now, I hear that pain patients are being cut down even further to 50MME and I am frightened because I know what that will mean for me. I already spend my days feeling like a piece of furniture more than a human being. I live in fear that I, like countless others, will find myself without adequate pain relief or perhaps without any pain relief at all. That would be indescribably devastating for me and others who are still fortunate enough to receive this valid medical treatment that provides us with enough relief to maintain some semblance of a life. I urge you to institute protections for pain patients before the proverbial other shoe drops. You have the power to help us and we implore you to use it. As pain patients, we come from all walks of life. Every type of person there is can and does experience life changing chronic pain. We don't deserve to be treated as second class citizens simply because we have one or a combination of health conditions that cause pain that we did not ask for, do not want to have, and have few options that can provide real and actual pain relief for the vast majority. I implore you to please preserve that capability for us. The bottom line is it isn't about the type of medication, it's about the quality and breadth of the relief that the medication provides to us. If there were comparable alternatives, it wouldn't be such an issue, but at current, there are none that provide proper relief to as many chronic pain sufferers as pain medications do. Please understand, we just want to reclaim some of our former ability, and these medications help us do just that. Thank you for your time and careful consideration.

This WHOLE ENTIRE ISSUE & what it ALL BOILS DOWN TO is genetics!! 1% of the population are ultra rapids & another 3 % of the population are rapid metabolizers of medications. This is our genetics & we have no control over this. (Btw- this has nothing to do with how fast pple metabolize food- the 2 are not related). The other 96% of the population are regular or slow metabolizers of meds & everyone is making rules & regulations & leaving 4% of the population out completely. We are being discriminated against & every civil right is being broken for us! The doctors that are treating us are the ones going to prison because AI is being used while breaking HIPPA to do so, to snuff them out! So many people are being tortured to dealth. Having heart attacks, strokes & worse- dying!! Not to mention suicides! Yall doing this are pure evil & dont forget we are fighting for you too. Disease & injury comes without warning or notice & in a blink of an eye you could be us!! Before more die, and just FYI tens of thousands have already died…. FIX THIS!!!!! You have blood on yr hands & God is watching y’all!

I wish to add the following to my previous comment. These changes do not go far enough. In relation to Drug Testing, We are all disgusted with being treated like Criminals. Do we Drug Test each Physician, before they come to work? How about the Police Officers, or Senators, ect. These people are in a position of power and authority. How about we Drug Test EVERYONE who seeks medical care of ANYKIND. WE could DRUG TEST all of the patients who arrive at an EMERGENCY entrance. And we could DENY ALL of them medical treatment. Perhaps we could go door to door each and every day, and DRUG TEST EVERYONE on the planet! Federal Laws forbid the denial of medical care to anyone currently using an illicit drug. I call your attention to: DEPARTMENT OF JUSTICE Office of the Attorney General 28 CFR PART 35 Nondiscrimination on the Basis of Disability in State and Local Government Services AGENCY: Department of Justice. ACTION: Final rule. Paragraph (b) of {35.131 Illegal use of drugs. provides a limited exception to the exclusion of current illegal users of drugs from the protections of the Act. It prohibits denial of health services, or services provided in connection with drug rehabilitation to an individual on the basis of current illegal use of drugs, if the individual is otherwise entitled to such services. A health care facility, such as a hospital or clinic, may not refuse treatment to an individual in need of the services it provides on the grounds that the individual is illegally using drugs, but it is not required by this section to provide services that it does not ordinarily provide. For example, a health care facility that specializes in a particular type of treatment, such as care of burn victims, is not required to provide drug rehabilitation services, but it cannot refuse to treat a individual's burns on the grounds that the individual is illegally using drugs. Public hospital districts are governmental entities established by Washington State statute. Federal Law supersedes State Law. I brought this to the attention of the Medical Commission, many years ago. And nothing was done to correct this injustice.

I support Maria Higginbotham petition and plead with the commission to stop the unethical treatment of patients, give them the rights they deserve. I am 81 years old and the past couple years I’ve been dealing with severe back pain, it breaks my heart to see what my daughters have suffered through. I have 2 daughters in their 60’s who have struggled for over 20 years with severe intractable pain due to an aggressive and destructive disease that destroys collagen. They have both had numerous surgeries and I have watched as their lives have become about doctors appointments and stress going to the doctor. They have had their medication tapered even though they were stable and had not done anything wrong. The doctors said it’s because the state won’t let them prescribe as much as they need to have some quality of life. I don’t understand how they can do this and leave patients suffering wishing their lives would end. This is not what doctors are supposed to do