The bipartisan National Association of Attorneys General, whose members have been battling the opioid crisis on numerous legal fronts, has sent a letter to the federal government objecting to parts of a recent draft report on pain management.

The draft report was prepared last December by a panel of experts appointed by the U.S. Department of Health and Human Services and called the Pain Management Best Practices Inter-Agency Task Force. The department gave the public 90 days, ending April 1, to comment on the report before it sends its recommendations to Congress.

The attorneys general letter says “it's incomprehensible” that the draft report weakens and deviates from guidelines published by the Centers for Disease Control and Prevention that are aimed at decreasing the risk of opioid misuse. The April 1 letter was signed by 39 bipartisan state and territory attorneys general.

“As a matter of public safety, there is simply no justification to move away from the guidelines to encourage more liberal use of an ineffective treatment that causes nearly 50,000 deaths annually,” the letter states.

The organization received an acknowledgment that the letter was received, “but we haven't received any additional official response at this point,” Allison Gilmore, chief communications officer for the group, told Corporate Counsel Friday.

The report would leave it solely up to a provider's judgment to determine the exact dose and duration of opioid use. In contrast, the center's guidelines call for documentation, monitoring, and consultation with a pain management expert to determine dosage and duration.

“As attorneys general, we have witnessed the devastating effect of unfettered opioid manufacturing, distribution and prescribing on our public health, social services and criminal justice systems,” the letter says. “The well established risks associated with higher doses of opioids, prescriptions of longer duration, and concurrent prescriptions of opioids and benzodiazepines demand continued constraints.”

The letter includes other concerns, such as pointing out that the report does not offer a reason for departing from the evidence-based guidelines. It also does not explicitly state that there is no completely safe opioid dosage.

“Moving away from the guidelines at this critical time would undermine ongoing legislative initiatives, as well as refinements to standards of medical care,” the letter says.

By Friday the letter still was not included on the 215 government webpages displaying public comments about the report.

A department representative, who asked not to be named, said the task force “is in the process of reviewing the comments it received on its draft recommendations, which it will take into consideration as it drafts its final recommendations. The task force plans to release its final recommendations in May.”