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The following is a formal request for an administrative procedures review concerning the renewal of the “Public Health Emergency” declaration for the “opioid crisis,” submitted to multiple high-ranking U.S. government officials. Written by David Edward Smith, a patient suffering from intractable pain, the document argues that federal policies, particularly those stemming from the 2016 CDC Clinical Practice Guidelines, are fundamentally flawed, based on manipulated data and false assertions that wrongly attribute the overdose crisis to prescription opioids rather than illicit fentanyl.
The request details immense patient harm, medical complications, and deaths—including suicides—resulting from forced opioid tapers and restricted access to necessary pain medication, asserting that these policies violate the prohibition of federal interference with medical practice and may constitute international law violations against torture.
Furthermore, David Smith calls for investigations into conflicts of interest among the policy creators and the DEA’s alleged use of predictive policing software to target pain doctors, concluding that the entire government program is an unacknowledged public health emergency for pain patients.
Beyond the Headlines: 5 Shocking Truths About America’s Opioid Policies
Introduction: The Story We Think We Know
The public narrative of the “opioid crisis” is a familiar one, broadcast in headlines and political speeches for over a decade. It tells a story of rampant overprescribing by doctors who, influenced by pharmaceutical companies, flooded the country with powerful painkillers, leading to a national wave of addiction and overdose deaths. This story has driven a massive, government-led effort to restrict access to these medications, prosecute physicians, and fundamentally change how pain is treated in America.
However, a closer look at the data, the science, and the lived experiences of millions of chronic pain patients reveals a far more complex and counterintuitive story. A detailed petition submitted by a disabled patient to the federal government—the basis of this analysis—argues that the official narrative is not just incomplete, but dangerously wrong.
It contends that the policies enacted to solve one crisis have, in fact, created another: an unacknowledged public health emergency of untreated pain, suffering, and death. This article explores five of the most impactful truths from that petition, revealing a side of the opioid story that has been largely ignored.
1. The “Opioid Crisis” Is Actually an “Illicit Fentanyl Crisis.”
U.S. opioid policy is built on a foundation that the petition argues is demonstrably false: that prescription medications are the primary driver of overdose deaths. The document asserts this is a critical misidentification of the problem.
The true crisis, it contends, is one of illicit fentanyl analog compound poisonings, which has been incorrectly conflated with the medically appropriate use of prescribed opioids.
This claim is supported by several damning points. The petition states unequivocally that “prescription opioid medications” were never a causal factor in the rise of overdose deaths.
It points to federal data showing that as the per capita dose of prescribed opioids has dropped precipitously since 2010, the overdose death rate has “continued to skyrocket.”
Perhaps the most critical evidence comes from an admission within the Centers for Disease Control and Prevention (CDC) itself, the very agency that architected the nation’s policy response.
NOTICE OF A REQUEST FOR AN ADMINISTRATIVE PROCEDURES
“Researchers with the Centers for Disease Control and Prevention have acknowledged that the agency’s methods for tracking overdose deaths are inaccurate and have significantly overestimated the number of Americans that have died due to prescription opioids.”
This more than suggests that the entire policy framework—from doctor prosecutions to patient restrictions—is aimed at the wrong target, focusing on regulated medicines while illegal street drugs drive the actual death toll.
2. The “Cure” Is Causing an Uncounted Epidemic of Suffering and Death.
In the government’s effort to curb “overprescribing,” a devastating and largely uncounted wave of harm has been inflicted upon millions of legitimate patients. The petition details how individuals with chronic pain, cancer, and end-of-life conditions have been subjected to policies that have led to medical condition collapse, loss of the ability to perform basic daily activities, and forced tapers resulting in excruciating withdrawal and uncontrolled pain. For many, the consequences have been fatal, leading to death from medical complications or suicide.
Shockingly, patient outcomes were never tracked after these restrictive policies were rolled out. The petition highlights a chilling statistic: in 2016, 501,008 Medicare Part D patients were receiving 120 Morphine Milligram Equivalents (MME) or more per day; by 2022, that number had plummeted to 176,021. This leaves a staggering 324,987 patients unaccounted for.
The petition asks the vital, unanswered question: “What happened to the 324,987 patients who lost access…?”
This isn’t just a missing number; it’s a black hole in public health data, representing a complete failure of policymakers to account for the human cost of their interventions.
The suffering imposed by these policies has been so severe that it has been framed as a violation of fundamental human rights.
The General Assembly of the United Nations (UN), is on record as having declared that “untreated pain is tantamount to torture or cruel, inhuman or degrading treatment or punishment.”
3. A Key Policy Tool Has No Scientific Basis.
At the heart of the government’s regulatory crackdown is a tool that critics, cited in the petition, decry as having no scientific basis whatsoever: the “morphine milligram equivalent” (MME) chart. This system, foundational to CDC guidelines and DEA enforcement, attempts to create a universal conversion formula to compare the potency of different opioid medications.
According to the petition, this entire concept is “unscientific, arbitrary, and capricious”
“Exercise extreme caution when switching hydromorphone concentrations or interchanging to other injectable opioid products (eg, morphine). Equianalgesic dosing conversions are based on limited data and do not account for patient specific factors (eg, end organ function, pharmacogenomics) or incomplete cross-tolerance between opioids. No equianalgesic dosing conversion factors are universally accepted.[7-8]”
The core flaw in the MME system is its failure to account for individual patient biology, specifically “CYP 450 genetic pleomorphism”—vast genetic differences in how individuals metabolize medications. A dose that is therapeutic for one person may be ineffective or excessive for another, regardless of what a generalized chart suggests.
This one-size-fits-all approach ignores basic pharmacology and can lead to dangerous clinical decisions. This flawed metric is sharply critiqued by an expert cited in the document.
“The CDC MME chart, in fact, the entire concept of morphine milligram equivalents may be convenient for bureaucrats, but because of differences in the absorption of different drugs into the bloodstream… it is not only devoid of scientific utility, but actually causes more harm than help by creating “guidelines” that are based on a false premise.” —Pharmaceutical research chemist Josh Bloom, the Director of Chemical and Pharmaceutical Science at the American Council on Science and Health
This reliance on a scientifically flawed tool becomes even more alarming when examining the alleged conflicts of interest behind the guidelines that promoted its use.
4. The Official Narrative Was Shaped by Potential Conflicts of Interest.
The very blueprint for America’s opioid policy, the 2016 CDC Guidelines, was not the product of broad medical consensus but allegedly the work of a small, conflicted group with a specific agenda. The petition alleges the guidelines were based on the opinions of a “small group of addiction medicine psychiatrists,” heavily influenced by the anti-opioid advocacy group “Physicians for Responsible Opioid Prescribing” (PROP).
The document details a particularly serious charge, alleging an “unethical and inappropriate conflict of interest” involving Dr. Leonard Palouzzi. While employed by the CDC and responsible for evaluating data on poisoning deaths, Dr. Palouzzi was allegedly a co-founder of PROP. The petition argues this created an “inappropriate and unethical working relationship” that raises profound questions about whether an unbiased, evidence-based process was subverted by a small group with a pre-determined agenda.
The source also highlights other alleged conflicts, including key figures serving as highly paid “expert witnesses” in opioid litigation against pharmaceutical companies—a role that financially benefits from a narrative of widespread prescriber misconduct. Further suspicion was raised by a House Oversight Committee investigation that obtained redacted documents, suggesting financial conflicts among members of the CDC’s Core Expert Group were known but not made public.
5. The War on Doctors Is Harming Patients.
The aggressive enforcement actions of the Drug Enforcement Administration (DEA) against physicians have created a “climate of fear” that is crippling pain management across the country.
Fearing prosecution, asset forfeiture, and the loss of their careers, many doctors have become unwilling to prescribe opioids—even when medically necessary—or have stopped treating pain patients altogether.
The petition argues that the Department of Justice (DOJ) and DEA are prosecuting doctors in a manner inconsistent with the Supreme Court’s 2022 ruling in XIULU RUAN v. UNITED STATES.
That decision established that to convict a doctor for unlawful prescribing, the government must prove the doctor knowingly or intentionally acted in an unauthorized manner. Yet, prosecutions continue, creating a chilling effect on the entire medical community.
Most alarmingly, the source presents evidence that the DEA may be using secret A.I. predictive policing software to target doctors. This software reportedly uses proprietary algorithms to flag legal and medically sound practices as “aberrant” or “criminal behavior.”
These flags include the number of patients seen, the distance a patient travels, and the prescribing of a “trinity” of drugs, including a narcotic with a sedative, muscle relaxer, or, amazingly, an antibiotic. The result is a system where doctors are treated as potential criminals for practicing standard medicine, leaving patients abandoned and desperate.
As Dr. L. Joseph Parker, now incarcerated A Texarkana Physician was sentenced today to 87 months in prison, followed by three years of supervised release on two counts of Distribution of a Schedule II Controlled Substance Without an Effective Prescription and 12 months in prison, followed by one year of supervised release on two counts of Distribution of a Schedule V Controlled Substance Without an Effective Prescription, all to run concurrently.
The Honorable Chief Judge Susan O. Hickey presided over the sentencing hearing in the United States District Court in Texarkana. Dr. L. Joseph Parker, MD, after being maliciously prosecuted, describes the devastating outcome:
“The evidence is clear. In their misguided attempts to stop prescription opiate overdose, which accounts for less than five hundred deaths per year, the US federal government is killing tens of thousands. They may be killing them quietly and indirectly, but those patients are dead just the same.”
Conclusion:
A Crisis of a Different Kind
The evidence presented in the petition paints a disturbing picture. It suggests that well-intentioned federal policies, built on a flawed understanding of the overdose crisis, have been misapplied with devastating consequences. By focusing on prescription medications instead of illicit fentanyl, relying on unscientific metrics, and creating a climate of fear among doctors, these policies have systematically dismantled pain care in America, leaving a vulnerable population to suffer in silence.
This raises a profound and urgent question that demands a national conversation. In our effort to solve the overdose crisis, have U.S. government policies unintentionally created a new, unacknowledged public health emergency of untreated pain and patient suffering?
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