American Academy of Hospice and Palliative Medicine (AAHPM) - Comment

The American Academy of Hospice and Palliative Medicine (AAHPM) is pleased to submit the attached letter in response to the call for public comment regarding FDA-2012-N-0548 and asks that the Drug Safety and Risk Management Advisory Committee carefully consider its contents as they review the public health benefits and risks of drugs containing hydrocodone. AAHPM is the professional organization for physicians specializing in hospice and palliative medicine, and our membership also includes nurses and other health care providers deeply committed to improving quality of life for patients facing life-threatening or serious conditions through the provision of palliative care. Palliative care often requires the delivery of timely and effective management of pain and other distressing symptoms. We are deeply concerned about and opposed to reclassification of hydrocodone-containing combination products as Schedule II controlled substances. AAHPM recognizes that these medications have been associated with some abuse, however they also have a proven and long-standing track record of being safe and effective analgesics for both acute and longer-term pain patients, when properly prescribed. AAHPM members are committed to stemming the tide of prescription abuse, misuse and diversion, but believe it is critical to consider the ways in which policy changes with this aim can have negative, unintended collateral effects. Medications containing hydrocodone in combination with other pain relievers are currently prescribed for both acute pain and chronic cancer and non-cancer pain, and we contend reclassification will jeopardize legitimate patient access to what has proven to be highly-effective treatment. Please address questions regarding AAHPM’s comments to Jacqueline M. Kocinski, Director of Health Policy and Government Relations, at jkocinski@aahpm.org or 847-375-4841.