I have read your description of the proposed electronic clinical quality measure (eCQM) for potential opioid abuse. I write as a technically trained non-physician subject matter expert in chronic pain and opioid policy, with 20 years of experience in medical research analysis, operations research and advanced technology evaluation. I have multiple published papers in this field.

I advise you in the strongest possible terms to withdraw this proposed algorithm and fire the idiots who proposed it. This "measure" is in fact nothing more than a creation out of thin air and surmise, thinly disguised by a layer of gobbledygook and specious "statistics". Patients who have been interviewed as test cases for the "measure" have correctly identified it as a dressed-up excuse for doctors who seek to deny opioid therapy to pain patients for whom no other viable medical alternatives exist. This reality is strongly signaled by the divergence between doctor assessments of the reliability of science involved, versus patient responses to the measure.

The biases of the development team are also revealed by their selection of references supporting development of the quality measure. The 2016 CDC Opioid Prescription Guidelines are widely recognized by many medical professionals to be founded upon political bias, cherry-picked research "findings", and conflations of fact which violate the research standards of the CDC itself. Perhaps the largest and most glaring fundamental error of the guidelines is their failure to acknowledge and account for the effects of genetic polymorphism in natural variations of opioid metabolism between individuals.

Genetic polymorphism in liver enzymes which accomplish opioid and other metabolism is well established by an ample published literature. This physiology renders moot, any attempt to identify thresholds of addiction risk versus opioid dose. By contrast each patient must be worked up and managed individually.

As established by a recently circulated AHRQ Draft Systematic Review, there are presently no viable non-pharmacological replacements for opioids in medical management of chronic pain. From other sources, we also know that medically managed patients do not comprise a significant source for the prevailing "opioid crisis". To restrict opioid prescriptions to people who comprise no significant risk of addiction serves no medical or ethical purpose and may properly be viewed as a violation of human rights.

It is time for your organization to face reality and dance. There is no one-size-fits-all chronic pain patient. Nor is there a one-size-fits-all opioid dose regime which can protect doctors from censure or challenge by government bureaucrats who understand little of medical science or practice. Grow a freaking backbone, people! Burn this specious "quality measure" to the ground and DO NOT START OVER!