Sybil KAthleen Marsh - Comment

As a physican trained in both Family Medicine and Addiction medicine and practicing Family Medicine, I suggest including not only ER/LA opiates but also short-acting opiates prescribed for longer than 2 weeks or quantitiy greater than 30-60 in the CE initiative. These parameters would exclude prescriptions for normal post-op or post-dentalwork pain, which normally are given for use as needed for 1-2 weeks without refills. Short acting opiates are frequently implicated in overdose deaths and repeat prescriptions for these are valued by both dependent and non-dependent drug abusers. It would be an unintended consequence of the ER/LA focus to drive physicians to inappropriately increase prescription of short acting opioids, especialy for chronic pain, because they appear to be exempt from the concerns expressed in the Blueprint.