U.S. Department of Health and Human Services 
 
O  ffice of Inspector General 
 
 
 
 
 
The Risk of Misuse and 
Diversion of Buprenorphine 
for Opioid Use Disorder in 
Medicare Part D Continues to 
Appear Low: 2022 
 
Ann Maxwell  
Deputy Inspector General 
   for Evaluation and Inspections 
November 2023, OEI-02-24-00130  U.S. Department of Health and Human Services 
O  ffice of Inspector General 
 
Data in Brief 
 
N  ovember 2023, OEI-02-24-00130 
 
The Risk of Misuse and Diversion of Buprenorphine for Opioid Use 
Disorder in Medicare Part D Continues to Appear Low: 2022  
Why OIG Did This Review 
  Ensuring access to buprenorphine to treat individuals with opioid use disorder is a critical step in 
addressing the Nations opioid crisis.1   
  Buprenorphinethe most common medication used to treat opioid use disorderhas been 
shown to decrease illicit opioid use and opioid-related overdose deaths.  Yet, due to concerns 
that buprenorphine has the potential for misuse and is at risk for diversion, access to this 
medication has historically been restricted.   
  The Office of Inspector General (OIG) recently conducted an evaluation examining the use of 
buprenorphine in Medicare Part D in 2021 and found that buprenorphines risk of misuse and 
diversion appeared to be low.2   
  This data brief provides updated informationbased on prescription drug event data from 
2022on the use of buprenorphine in Medicare Part D and its risk for diversion.   
What OIG Found 
  As in 2021, almost all Medicare Part D enrollees who received buprenorphine for the treatment 
of opioid use disorder received the recommended amounts in 2022. 
  Most enrollees received buprenorphine-naloxone 
97 percent 
of 
combination products which are generally 
recommended to minimize the risk of misuse or   Part D enrollees received 
diversion.  the recommended amounts 
  Enrollees rarely received either very high amounts of  or less of buprenorphine for 
buprenorphine or buprenorphine at the same time as  opioid use disorder in 2022.  
they received high amounts of other opioids. 
What OIG Concludes 
  The findings from 2022 are similar to the findings from 2021.  Together, they suggest that the 
risk of misuse and diversion of buprenorphine in Medicare Part D continues to be low.   
  These updated data provide important information about buprenorphine utilization that can 
assist the Centers for Medicare & Medicaid Services (CMS), the U.S. Department of Health and 
Human Services (the Department), and others as they continue to take steps to improve access 
to buprenorphine, while also ensuring that the risk of misuse and diversion remains low. 
  Primer  Buprenorphine for the Treatment of Opioid Use Disorder 
  Opioid use disorder is a problematic pattern of opioid use that leads to clinically 
significant impairment or distress.  About 1.1 million people enrolled in Medicare had a 
diagnosis of opioid use disorder in 2022.3 
  Buprenorphine is a medication used to treat opioid use disorder.4  It suppresses 
withdrawal symptoms and relieves cravings.   
  Buprenorphine and other medications used to treat opioid use disorder are commonly 
referred to as medications for opioid use disorder (MOUD).5  These medications have 
been shown to decrease illicit opioid use and opioid-related overdose deaths.6 
  Buprenorphine is designated as a Schedule III controlled substancemeaning that it has 
the potential for abuse and is at risk for diversion, but has a lower risk than Schedule II 
controlled substances, such as oxycodone.7 
  Until recently, to prescribe or administer buprenorphine in an office-based setting, a 
provider had to obtain a waiver from the Substance Abuse and Mental Health Services 
Administration (SAMHSA).  This waiver was commonly referred to as the DATA waiver 
after the Drug Addiction Treatment Act (DATA) of 2000 that established the waiver 
program.8  It was also commonly referred to as the X-waiver. 
  To qualify for this waiver, providers were generally required to complete approved training 
and have the capacity to refer patients to counseling and other ancillary services.9  
Providers were limited in the number of patients whom they were allowed to treat.10  
  In late December 2022, the waiver requirement was repealed.11  In its place, all providers 
who apply for or renew their Drug Enforcement Administration (DEA) registration to 
prescribe controlled substances must take a one-time training on treating and managing 
patients with substance use disorders.12 
 
 
 
 
 
  FINDINGS 
Ensuring access to buprenorphine while minimizing the risk of diversion is critical to 
addressing the opioid crisis. 
This data brief provides updated information from 2022 about Medicare Part D 
enrollees use of buprenorphine.  As we did in our prior work, to assess the risk of 
diversion, we determined the extent to which enrollees received the recommended 
amounts of buprenorphine; the extent to which enrollees received buprenorphine-
naloxone combination productswhich have a reduced risk of misuse or diversion; 
and the extent to which enrollees received very high amounts of buprenorphine or 
received buprenorphine at the same time as they received high amounts of opioids 
indicated for pain.  
As in 2021, almost all Medicare Part D enrollees who received 
buprenorphine for the treatment of opioid use disorder 
received the recommended amounts in 2022 
A total of 182,043 people enrolled in Medicare Part D received buprenorphine in 
2022.13  Almost all of these enrollees97 percentreceived the recommended 
amounts or less of buprenorphine.  See Exhibit 1.  In general, buprenorphine products 
have a recommended daily dose range of 4 mg to 24 mg.14  The same percentage of 
enrollees received the recommended amounts or less of buprenorphine in 2021.15  
Further, as in 2021, enrollees most commonly received an average daily dosage of 
buprenorphine of around 16 mg per day.  Enrollees also commonly received dosages 
of around 24 mg per day, followed by 8 mg per day and then 4 mg per day.  See 
Appendix A for more information about 2021 and 2022.   
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Findings | 4  Exhibit 1:  Most Part D enrollees received dosages of buprenorphine at or 
below the recommended range of 4 mg to 24 mg per day in 2022.  
Source: OIG analysis of Medicare Part D data, 2023. 
 
Most enrollees received buprenorphine-naloxone combination 
products which are generally recommended to minimize the risk 
of misuse or diversion 
Medications that contain both buprenorphine and naloxonei.e., buprenorphine 
combination productsare recommended for most individuals receiving 
buprenorphine for opioid use disorder.  
The  addition of naloxone to the  Exhibit 2:  83 percent of 
medication helps minimize the risk of  enrollees received buprenorphine 
misuse and diversion.16  These  combination products.  
products are generally recommended 
for the treatment of opioid use  17%
disorder to minimize the risk of misuse 
or diversion.  
In total, 83 percentor 
150,813 enrolleesreceived a 
combination product in 2022 through 
Part D.17  See Exhibit 2.  This is very 
83%
similar to the percentage of enrollees 
who received a combination product 
Source: OIG analysis of Medicare Part D data, 2023. 
through Part D in 2021.18   
The remaining 17 percentor 31,230 enrolleesreceived medications that contain 
only buprenorphinei.e., buprenorphine monoproducts.  According to SAMHSA, 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Findings | 5  buprenorphine monoproducts should be reserved for patients such as pregnant 
patients, patients who are allergic to naloxone, and patients who cannot afford 
treatment if the combination product is required.19 
Enrollees rarely received either very high amounts of 
buprenorphine or buprenorphine at the same time as they 
received high amounts of other opioids 
A very small number of enrollees1,409either received very high average daily 
dosages of buprenorphine or received buprenorphine at the same time as they 
received high amounts of opioids indicated for pain in 2022.20  These enrollees 
represent just 0.8 percent of all enrollees who received buprenorphine in 2022.21 
Few enrollees received very high amounts of buprenorphine    
Only 278 Part D enrollees received an 
average of more than 36 mg per day  Fewer than 300 
of buprenorphine, which is more than 
 enrollees averaged more than 
50 percent higher than the maximum 
recommended daily dose.  These  36 mg per day of 
enrollees received very high average  buprenorphine.  
daily dosages for more than 90 days. 
Enrollees with cancer or sickle cell disease; those receiving palliative care; and those in 
hospice care were not included in this analysis. 
A similar number of enrollees323received very high amounts of buprenorphine in 
2021.  The low numbers in both 2021 and 2022 further suggest that misuse and 
diversion of buprenorphine are not widespread in Medicare Part D.22  
A small number of enrollees received buprenorphine and high 
amounts of opioids indicated for pain  
The majority of Part D enrollees who received buprenorphine for opioid use disorder 
did not receive any opioids indicated for pain.23  However, 1,135 enrollees received 
buprenorphine at the same time as they received high amounts of opioids indicated 
for pain, a similar number to that for 2021.24  Each of these enrollees received opioids 
with an average morphine milligram equivalent (MME) of greater than 50 mg while 
they received buprenorphine for more than 90 days during the year.  Receiving 
buprenorphine for opioid use disorder at the same time as opioids indicated for pain 
may indicate coordination-of-care issues or diversion.   
Nonetheless, the small number of enrollees receiving buprenorphine and high 
amounts of opioids indicated for pain in 2021 and in 2022 further suggests that 
misuse and diversion of buprenorphine are limited in Medicare Part D. 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Findings | 6  CONCLUSION 
The findings from 2022 are similar to the findings from 2021.  Together, they suggest 
that the risk of misuse and diversion of buprenorphine in Medicare Part D continues 
to be low.   
Further, this information about buprenorphine utilization can assist CMS, the 
Department, and others as they continue to take steps to improve access to 
buprenorphine, while also ensuring that the risk of misuse and diversion remains low.  
For example, the Departments Behavioral Health Care Coordinating Council can use 
these data when developing future Department guidelines related to buprenorphine 
prescribing.  
Considering the magnitude of the opioid epidemicwith an estimated 83,894 deaths 
in 2022it is critical that CMS and the Department use all of the tools at their 
disposal to address the crisis.  As such, we continue to call upon CMS to implement 
the recommendations in our prior data brief, including to:  
  inform providers about buprenorphine use and the low risk of diversion to 
encourage providers to treat more Part D enrollees who have opioid use 
disorder;  
  take steps to inform providers about the availability of buprenorphine 
combination products in Part D, which can minimize the risk of misuse and 
diversion; and   
  monitor the use of buprenorphine and share information, as appropriate, with 
Departmental partners.25 
In response to these prior recommendations, CMS concurred with the first two.26  
While CMS did not indicate whether it concurred with the last recommendation, it did 
indicate ongoing activity it felt was responsive.  OIG is currently awaiting updates 
from CMS about actions it is taking to implement the three recommendations.
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Conclusion| 7  METHODOLOGY 
We based this study primarily on five data sources: Medicare Part D Prescription Drug 
Event (PDE) records, the First Databank, the Medicare Enrollment Database, the 
National Claims History File, and Part C Encounter Data.  We also used U.S. Food and 
Drug Administration (FDA) drug labels and the Centers for Disease Control and 
Preventions (CDCs) Morphine Milligram Equivalent (MME) conversion file.  We 
compared the results of this analysis to the results from the prior OIG data brief, The 
Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder Appears to Be 
Low in Medicare Part D (OEI-02-22-00160), which used the same methodology to 
review data from 2021.  
PDE records are for prescriptions that enrollees received through Part D.  They do not 
include prescriptions paid for through other programs, prescriptions paid for in cash, 
or illicitly purchased drugs.  Part D sponsors submit a PDE record to CMS each time a 
drug is dispensed to a person enrolled in their plans.  Each record contains 
information about the drug and enrollee, as well as the identification numbers for the 
pharmacy and the prescriber.  For the purposes of this study, we use the term 
prescription to mean one PDE record. 
To obtain descriptive information about the drugs and enrollees, we matched PDE 
records to data from the First Databank, the National Claims History File, Part C 
Encounter Data, FDA drug labels, and CDCs MME conversion file.  The First Databank 
contains information about each drug, such as the drug name, strength of the drug, 
and therapeutic class (e.g., medication for opioid use disorder).  The National Claims 
History File contains claims data from Medicare Parts A and B, including diagnosis 
codes.  Part C Encounter Data contain medical claims data, including diagnosis codes, 
for Medicare Advantage plan enrollees.  FDA drug labels indicate dosing equivalents 
between buprenorphine products.  CDCs MME conversion file contains information 
about each opioid drugs morphine milligram equivalence. 
Identifying Medicare Part D Enrollees with Buprenorphine 
Using the PDE records, we first identified people enrolled in Medicare Part D with at 
least one prescription for buprenorphine indicated for the treatment of opioid use 
disorder with a date of service in 2022.27  We did not include prescriptions for 
buprenorphine indicated for pain in this study.  For the purposes of this study, we use 
the term buprenorphine to mean buprenorphine indicated for the treatment of 
opioid use disorder. 
 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Methodology | 8 
  Average Daily Dosage of Buprenorphine Analysis 
Next, we determined the amount of buprenorphine that each Part D enrollee received 
in 2022 by calculating each enrollees average daily dosage of buprenorphine.28   
To do this, we first calculated the total number of milligrams of buprenorphine in 
each prescription.29  We standardized buprenorphine products with higher 
bioavailability in order to sum dosages across different buprenorphine products.30  
We then determined the milligrams per day of buprenorphine for each prescription 
by dividing the total number of milligrams by the total days supply. 
Next, we summed each enrollees milligrams of buprenorphine for each day of the 
year on the basis of the dates of service and days supply on each PDE record.   
We then calculated the days of use of buprenorphine for each enrollee.  Each calendar 
date in 2022 with a day supply of buprenorphine is considered a day of use.  
For example, an enrollee who received a day supply for each date in 2022 had 
365 days of use.  
We then divided the total milligrams of buprenorphine over the year by the total 
number of days of use to get the average daily dosage of buprenorphine per day of 
use in 2022. 
Next, we identified the recommended range of buprenorphine.  To do this, we 
reviewed FDA-approved drug labels of buprenorphine and buprenorphine-naloxone 
products indicated for the treatment of opioid use disorder.  
Buprenorphine Combination Product and Monoproduct Analysis 
Next, we identified which buprenorphine prescriptions were buprenorphine-naloxone 
combination products and which were buprenorphine-only monoproducts in 2022.   
Using this information, we determined the percentage of Part D enrollees who 
received at least one buprenorphine combination product in 2022 and the percentage 
who only received monoproducts. 
Identifying Part D Enrollees Who Received Very High Amounts of 
Buprenorphine 
We considered enrollees to have received very high amounts of buprenorphine if 
their average daily dosage of buprenorphine was more than 36 mg for more than 
90 days in 2022.  This analysis excluded enrollees who had a diagnosis of cancer or 
sickle cell disease; had a hospice stay; or received palliative care at any point in 2022. 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Methodology | 9 
  Identifying Part D Enrollees Who Received Buprenorphine and 
High Amounts of Opioids Indicated for Pain 
We identified enrollees who received buprenorphine indicated for the treatment of 
opioid use disorder at the same time as they received opioids indicated for pain in 
2022.31 
Next, we determined the amount of opioids that each of these enrollees received in 
2022.  To do this, we calculated each enrollees average daily morphine milligram 
equivalent (MME) dose.32  The MME converts opioids of different ingredients, 
strengths, and forms into equivalent milligrams of morphine.  It allows us to sum 
dosages of different opioids to determine an enrollees daily opioid level. 
To calculate each enrollees average daily MME, we first calculated the MME for each 
prescription.33  We used the following equation: 
 
(SSSSSSSSSSSSSSh ppSSSS uuSSuuSS)(QQuuQQSSSSuuSStt dduuddppSSSSddSSdd)(MMMMMM ccccSSccSSSSdduuccSS ffQQccSSccSS)
MMMMMM = 
Next, we summed each enrollees MME( fDDoQQrtt edda ddcuuhpp ppdssauuSSydd o)f the year based on the dates of 
service and days supply on each prescription. 
For each enrollee, we then calculated the number of days on which they had both 
buprenorphine and other opioids. 
We then calculated each enrollees average MME over these days of overlap.  We 
divided the total MME for the days of overlap by the total days of overlap for each 
enrollee. 
Lastly, we identified the enrollees who received buprenorphine and high amounts of 
opioids indicated for pain.  We considered enrollees to have received buprenorphine 
and high amounts of opioids indicated for pain if their opioids had an average daily 
MME of greater than 50 mg over the days of overlap and had more than 90 days of 
overlap.  This analysis excluded enrollees who had a diagnosis for cancer or sickle cell 
disease; had a hospice stay; or received palliative care at any point in 2022. 
Limitations 
This analysis is based on Medicare claims data.  We did not review medical records or 
independently verify the accuracy of the Medicare claims data for this study.  The 
analysis does not include data on buprenorphine or opioids that enrollees may have 
received from sources other than Medicare Part D.  
 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Methodology | 10 
  Standards 
We conducted this study in accordance with the Quality Standards for Inspection and 
Evaluation issued by the Council of the Inspectors General on Integrity and Efficiency.  
 
 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Methodology | 11 
  APPENDIX A 
Exhibit A1:  Most Part D enrollees received dosages of buprenorphine at or 
below the recommended range of 4 mg to 24 mg per day in 2021. 
Part D enrollees most commonly 
40,000 received 16 mg per day of use
s
e
e
oll 30,000
r
n
E
D 
t 
r
a
P 20,000
e 
r
a
c
di
e
M
10,000
0
0 4 8 12 16 20 24 28 32 36 40 44
Average Milligrams Per Day of Use of Buprenorphine
 
Source: OIG analysis of Prescription Drug Event data, 2023. 
 
 
 
 
 
 
 
 
 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Appendix A | 12  Exhibit A2:  Number of Medicare Part D enrollees receiving buprenorphine 
for opioid use disorder, by average milligrams of buprenorphine per day, 
2022   
Average milligrams    Average milligrams 
per day  Enrollees  per day  Enrollees 
< 0.5  37    32  675 
1  1,200    33  559 
2  5,688    34  383 
3  2,516    35  132 
4  10,012    36  118 
5  2,450    37  76 
6  6,665    38  53 
7  2,268    39  35 
8  14,101    40  28 
9  3,498    41  19 
10  2,718    42  14 
11  2,630    43  14 
12  8,311    44  5 
13  4,389    45  3 
14  3,317    46  3 
15  3,755    47  2 
16  38,590    48  14 
17  13,563    49  9 
18  3,457    50  10 
19  2,659    51  7 
20  4,927    52  2 
21  3,790    53  3 
22  2,520    54  1 
23  2,606    55  1 
24  16,004    58  1 
25  11,196    59  1 
26  4,369    62  1 
27  821    68  3 
28  484    69  1 
29  358    73  2 
30  290    77  1 
31  224    99  1 
  Source: OIG analysis of Medicare Part D data, 2023. 
  Note: For more information about these calculations, see the Methodology.  To calculate the averages across different   
  buprenorphine products, we standardized buprenorphine products with higher bioavailability.     
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Appendix A | 13  ACKNOWLEDGMENTS AND CONTACT 
Acknowledgments 
Miriam Anderson served as the team leader for this study.  Others in the Office of 
Evaluation and Inspections New York Regional Office who conducted the study 
include Margaret Himmelright and Jason Kwong.  Office of Evaluation and Inspections 
headquarters staff who provided support include Robert Gibbons, Chris Galvin, and 
Sara Swisher.  
This report was prepared under the direction of Jodi Nudelman, Regional Inspector 
General for Evaluation and Inspections in the New York Regional Office, and 
Nancy Harrison and Meridith Seife, Deputy Regional Inspectors General. 
Contact 
To obtain additional information concerning this report, contact the Office of Public 
Affairs at Public.Affairs@oig.hhs.gov.  OIG reports and other information can be found 
on the OIG website at oig.hhs.gov. 
Office of Inspector General 
U.S. Department of Health and Human Services 
330 Independence Avenue, SW 
Washington, DC 20201 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130  Acknowledgments and Contact | 14  ENDNOTES 
 
1 Increasing access to buprenorphine to treat opioid use disorder is a goal of the Administration.  See Office of National Drug 
Control Policy, The Biden-Harris Administrations Statement of Drug Policy Priorities for Year One, 2021.  Accessed at 
https://www.whitehouse.gov/wp-content/uploads/2021/03/BidenHarris-Statement-of-Drug-Policy-Priorities-April-
1.pdf?fbclid=IwAR2TBk34U_XRqlqK_pAYnUd_9f7zY3IbCQI9KxI6S5eYeRJdFzl9B09hZ84 on October 30, 2023.  
2 The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder Appears to Be Low in Medicare Part D (OEI-02-22-
00160) May 16, 2023.  
3  The Consistently Low Percentage of Medicare Enrollees Receiving Medication to Treat Their Opioid Use Disorder Remains a 
Concern (OEI-23-00250) forthcoming. 
4 Buprenorphine products indicated for pain are different from buprenorphine products indicated for the treatment of opioid 
use disorder. 
5 Methadone and naltrexone are also approved by the Food and Drug Administration (FDA) for the treatment of opioid use 
disorder.   
6 SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use Disorder, 2021.  Accessed at 
https://store.samhsa.gov/sites/default/files/SAMHSA_Digital_Download/PEP21-02-01-002.pdf on November 1, 2023. 
7 For more information about controlled substance scheduling, see DEA, Drug Scheduling.  Accessed at 
https://www.dea.gov/drug-information/drug-scheduling on November 1, 2023. 
8 The Drug Addiction Treatment Act of 2000 was enacted under Title XXXV of the Childrens Health Act of 2000, P.L. No. 106-
310. 
9 Prior to April 2021, all providers were required to complete approved training and have the capacity to refer patients to 
counseling and other ancillary services.  The Department of Health and Human Services (HHS) released new practice guidelines 
in 2021 that exempted eligible providers from these requirements if they are treating 30 or fewer patients.  See 86 F.R. 22439.  
Congress has since repealed the need for a waiver.  See 21 U.S.C.  823(g)(2)(B)(iii)(I)-(II), repealed by Consolidated 
Appropriations Act, 2023,  1262, P.L. No. 117-328 (Dec. 29, 2022). 
10 Before late December 2022, with a waiver, practitioners could treat up to 100 patients with buprenorphine in the first year, 
although most qualified practitioners were limited to treating up to 30.  In subsequent years, a practitioner could treat up to 
275 patients.  See 42 CFR  8.610.  In December 2022, Congress repealed the need for a waiver.  See 21 U.S.C.  
823(g)(2)(B)(iii)(I)-(II), repealed by Consolidated Appropriations Act, 2023,  1262, P.L. No. 117-328 (Dec. 29, 2022). 
11 P.L. No. 117-328  1262.  
12 P.L. No. 117-328  1263.  
13 These data are based on an analysis of Medicare Part D prescription drug event records for buprenorphine indicated for the 
treatment of opioid use disorder.  We did not include buprenorphine indicated for pain.   
14 Most buprenorphine products have recommended daily dosages ranging from 4 mg per day to 24 mg per day, based on 
their FDA-approved manufacturer labels.  See SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use 
Disorder, 2021.  In addition, some buprenorphine products have higher bioavailability, meaning that they enter into the 
bloodstream more quickly, allowing for lower dosages.  For this analysis, we standardized buprenorphine products with higher 
bioavailability to have the same recommended range as other buprenorphine products have.  In addition, to accommodate 
 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130   Endnotes | 15    
early refills of prescriptions, we considered an enrollees average daily dosage to be about 24 mg per day of use if it did not 
exceed 26 mg per day.  
15 In 2021, a total of 170,408 people enrolled in Medicare Part D received buprenorphine.  Almost all of these enrollees
97 percentreceived the recommended amounts or less of buprenorphine.  The Risk of Misuse and Diversion of Buprenorphine 
for Opioid Use Disorder Appears to Be Low in Medicare Part D (OEI-02-22-00160) May 16, 2023.  
16 Daily buprenorphine monoproducts carry a higher risk of diversion than do buprenorphine combination products.  SAMHSA, 
Buprenorphine, 2023.  Accessed at https://www.samhsa.gov/medication-assisted-treatment/medications-counseling-related-
conditions/buprenorphine on November 1, 2023.  Also see SAMHSA, Buprenorphine Quick Start Guide.  Accessed at 
https://www.samhsa.gov/sites/default/files/quick-start-guide.pdf on November 1, 2023.  Separately, naloxone is a medication 
used to reverse opioid overdoses.  See SAMHSA, Naloxone, 2023.  Accessed at https://www.samhsa.gov/medications-
substance-use-disorders/medications-counseling-related-conditions/naloxone on November 1, 2023. 
17 A total of 8,228 (5 percent) of Part D enrollees received both buprenorphine combination products and monoproducts. 
18 In total, 84 percentor 142,321 enrolleesreceived a combination product through Part D in 2021.  The Risk of Misuse and 
Diversion of Buprenorphine for Opioid Use Disorder Appears to Be Low in Medicare Part D (OEI-02-22-00160) May 16, 2023.  
19 SAMHSA, Buprenorphine Quick Start Guide.  SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use 
Disorder, 2021.   
20 Four enrollees received very high average daily dosages of buprenorphine and also received buprenorphine at the same 
time as they received high amounts of opioids indicated for pain in 2022. 
21 A total of 1,245 enrollees either received very high average daily dosages of buprenorphine or received buprenorphine at 
the same time as they received high amounts of opioids indicated for pain in 2021.  These enrollees represented just 
0.7 percent of all enrollees who received buprenorphine in 2021.  The Risk of Misuse and Diversion of Buprenorphine for Opioid 
Use Disorder Appears to Be Low in Medicare Part D (OEI-02-22-00160) May 16, 2023.  
22 It is also noteworthy that, according to the National Institute on Drug Abuse, data suggest that the bulk of buprenorphine 
misuse (use without a prescription) is for the purpose of controlling withdrawal and cravings for other opioids and not to get 
high.  See National Institute on Drug Abuse, Medications to Treat Opioid Use Disorder Research Report, December 2021.  
Accessed at https://nida.nih.gov/publications/research-reports/medications-to-treat-opioid-addiction/what-treatment-need-
versus-diversion-risk-opioid-use-disorder-treatment on November 16, 2023.  
23 This analysis excluded buprenorphine indicated for the treatment of pain. 
24 In 2021, 927 enrollees received buprenorphine at the same time as they received high amounts of opioids indicated for pain.  
The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder Appears to Be Low in Medicare Part D (OEI-02-22-
00160) May 16, 2023.  Enrollees with cancer or sickle cell disease; those receiving palliative care; and those who were in hospice 
care were not included in this analysis in 2021 or 2022.   
25 The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder Appears to Be Low in Medicare Part D (OEI-02-22-
00160) May 16, 2023.  
26 Ibid. 
27 Additional Medicare Part D enrollees may have also received buprenorphine.  For instance, some enrollees may have 
received buprenorphine covered by Medicare Part B, such as through opioid treatment programs.  Others may have paid out 
of pocket for buprenorphine to treat their opioid use disorder.  Buprenorphine indicated for pain was not included in this 
analysis. 
28 We limited this analysis to oral buprenorphine products. 
 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130   Endnotes | 16    
29 We included buprenorphine dispensed in 2021 with days supply in 2022.  This analysis excluded prescriptions for implant 
and injection buprenorphine. 
30 To account for buprenorphine products with higher bioavailability, we standardized the milligrams across all products to be 
equivalent to Suboxone.  For example, according to the FDA drug label, one Zubsolv 5.7 mg buprenorphine/1.4 mg naloxone 
sublingual tablet provides equivalent buprenorphine exposure to that of one Suboxone 8 mg buprenorphine/2 mg naloxone 
sublingual tablet.  Therefore, in our analysis we consider one of these Zubsolv tablets to have 8 mg of buprenorphine.  For 
more information, see Orexo US, Inc., Zubsolv: Highlights of Prescribing Information, 2021. Accessed at 
https://www.accessdata.fda.gov/drugsatfda_docs/label/2021/204242s019lbl.pdf on November 20, 2023.    
31 We did not include buprenorphine indicated for pain in this analysis.  We considered enrollees to have received 
buprenorphine at the same time as they received other opioids if, after the first day supply of buprenorphine in 2022, 
buprenorphine PDE and other opioid PDEs had days supply that fell on the same calendar day. 
32 For more information on calculating opioid dosage, see CDC, Calculating Total Daily Dose of Opioids for Safer Dosage.  
Accessed at https://stacks.cdc.gov/view/cdc/38481/cdc_38481_DS1.pdf on October 30, 2023. 
33 We included opioids dispensed in 2021 with days supply in 2022.  This analysis excludes prescriptions for injection, 
intravenous, and intrathecal opioids, as well as opioids indicated as medications for opioid use disorder. 
Data Brief: The Risk of Misuse and Diversion of Buprenorphine for Opioid Use Disorder in Medicare Part D Continues to Appear 
Low: 2022 
OEI-02-24-00130   Endnotes | 17