U.S. Department of Health and Human Services 
Office of Inspector General 
The Risk of Misuse and 
Diversion of Buprenorphine 
for Opioid Use Disorder 
Appears to Be Low in 
Medicare Part D 
 
Ann Maxwell  
Deputy Inspector General 
   for Evaluation and Inspections 
May 2023, OEI-02-22-00160  U.S. Department of Health and Human Services 
O  ffice of Inspector General 
 
Data in Brief 
 
M  ay 2023, OEI-02-22-00160 
 
 
The Risk of Misuse and Diversion of Buprenorphine for Opioid Use 
Disorder Appears to Be Low in Medicare Part D    
Why OIG Did This Review 
Key Results 
Opioid-related overdose deaths in the United States remain a 
Almost all Medicare Part D  concern, with an estimated 82,310 deaths in 2021.1  As the country 
enrollees who received  continues to struggle with the opioid crisis, it is essential to ensure 
buprenorphine for the treatment  access to buprenorphine to treat individuals with opioid use 
of opioid use disorder received  disorder.2 
the recommended amounts.  
Buprenorphine has been shown to decrease illicit opioid use and 
Only a small number of enrollees 
opioid-related overdose deaths.3  However, there are concerns about 
either received very high 
access to this potentially life-saving medication.  Previous Office of 
amounts of buprenorphine or 
received buprenorphine at the  Inspector General (OIG) work has shown a need to increase the 
same time as they received high  number of Medicare enrollees receiving treatment for opioid use 
amounts of other opioids.  disorder.  OIG has found that just 18 percent of Medicare enrollees 
with a diagnosis of opioid use disorder received medication to treat 
Most prescribers ordered 
their opioid use disorder.4  Furthermore, Black, Hispanic, and 
buprenorphine for a limited 
number of Part D enrollees; very  Asian/Pacific Islander Medicare enrollees are less likely to receive 
few had patterns that raise  medication to treat their opioid use disorder than are White 
concern.  enrollees.5 
These findings further support 
At the same time, buprenorphine for the treatment of opioid use 
the recent repeal of the waiver
disorderhereafter referred to as buprenorphinehas the potential 
which was in place, in part, to 
for misuse and is at risk for diversion.  To address this risk, providers 
limit diversion of buprenorphine.  
were required to obtain a waiver through the Substance Abuse and 
This report also provides baseline 
Mental Health Services Administration (SAMHSA) to prescribe or 
information and 
administer buprenorphine in office-based settings and were limited 
recommendations that can assist 
in the number of patients they could treat.  This waiver is commonly 
the Centers for Medicare & 
referred to as the DATA waiver after the Drug Addiction Treatment 
Medicaid Services (CMS) and the 
Act (DATA) of 2000 that established the waiver program.  
U.S. Department of Health and 
Human Services (the  In December 2022, the Consolidated Appropriations Act, 2023, 
Department) as they work to  repealed the waiver requirement and the corresponding patient 
continue to improve access to  limits.6  This change comes alongside a wider effort by the 
buprenorphine, while also  Administration to expand access to treatment, in part, by eliminating 
ensuring that the risk of diversion  barriers.7  
and misuse remains low. 
This data brief provides information related to the risk of misuse and 
 
diversion of buprenorphine in Medicare Part D in 2021prior to the repeal of the DATA waiver.  
Prescribing of buprenorphine has been limited, in part, due to concerns related to misuse and diversion.  
Yet, up until now, there has been little information available on the extent to which buprenorphine may 
  be misused or diverted in Medicare.  This data brief describes the use of buprenorphine and looks at 
several measures to assess the risk of misuse and diversion of buprenorphine in Medicare.  
How OIG Did This Review 
We focused this review on Medicare Part D claims for buprenorphine indicated for the treatment of 
opioid use disorder in 2021prior to the repeal of the DATA waiver.  We did not include claims for 
buprenorphine indicated for pain.  Buprenorphine covered by Medicare Part D is generally prescribed in 
office-based settings and filled at retail pharmacies. 
What OIG Found 
Almost all Medicare Part D enrollees who received buprenorphine to treat their opioid use disorder 
received the recommended amounts.  Most enrollees received buprenorphine-naloxone combination 
products, which have a reduced risk of misuse or diversion; however, 16 percent of enrollees received 
buprenorphine monoproducts.  Only a small number of enrollees received very high amounts of 
buprenorphine or received buprenorphine at the same time as they received high amounts of opioids 
indicated for pain. 
Most prescribers ordered buprenorphine for only a limited number of enrollees, which could provide an 
opportunity to increase access.  Further, very few prescribers had patterns that raise concern.  Only 
35 prescribers ordered buprenorphine for multiple Part D enrollees who either received very high levels 
of buprenorphine or received buprenorphine at the same time as they received high amounts of 
opioids. 
What OIG Recommends  
Together, these findings suggest that the risk of misuse and diversion of buprenorphine in Medicare 
Part D is low.  These findings further support the recent repeal of the DATA waiverwhich was in place, 
in part, to limit diversion of buprenorphine.  The repeal of the waiver is a significant step towards 
increasing access to treatment. 
Further, the data in this report provide baseline information about buprenorphine utilization and 
prescribing that can assist CMS, the Department, and others as they implement changes related to the 
repeal and take other steps to improve access to buprenorphine, while also ensuring that the risk of 
misuse and diversion remains low.   
Accordingly, we recommend that CMS (1) monitor the use of buprenorphine and share information, as 
appropriate, with Departmental partners; (2) 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; 
(3)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 (4) follow up on the prescribers with
concerning patterns identified in this report.  CMS concurred with three of our recommendations. While
it did not indicate whether it concurred with the other recommendation, it did indicate ongoing activity
it felt was responsive. 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.  Over 1.1 million people enrolled in Part D had a
diagnosis of opioid use disorder in 2021.8
 Buprenorphine is a medication used to treat opioid use disorder.9  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).10  These medications have
been shown to decrease illicit opioid use and opioid-related overdose deaths.11
 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.12
 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 is commonly referred the DATA waiver after the
Drug Addiction Treatment Act (DATA) of 2000 that established the waiver program.13  It is
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.14
Providers were limited in the number of patients whom they were allowed to treat.15
 In late December 2022, the waiver requirement was repealed.16  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.17 FINDINGS 
Ensuring access to treatment for opioid use disorderincluding buprenorphineis 
critical to helping address the Nations opioid crisis.  At the same time, it is also 
important to ensure that diversion risks are limited. 
This data brief describes Medicare Part D enrollees use of buprenorphine.  It also 
looks at several measures to assess the risk of diversion, including the extent to which 
Part D enrollees received buprenorphine-naloxone combination productswhich 
have a reduced risk of misuse or diversion; the extent to which enrollees receive very 
high amounts of buprenorphine; and the extent to which enrollees receive 
buprenorphine at the same time as they receive high amounts of opioids indicated for 
pain.18  The data brief also looks at buprenorphine prescribing and the extent to which 
prescribers have concerning patterns. 
Almost all Medicare Part D enrollees who received 
buprenorphine for the treatment of opioid use disorder 
received the recommended amounts   
A total of 170,408 people enrolled in 
Medicare Part D received  97 percent of Part D 
buprenorphine in 2021.  Almost all of 
enrollees received the 
these enrollees97 percent
recommended amounts or 
received the recommended amounts 
less of buprenorphine 
or less of buprenorphine.  In general, 
buprenorphine products have a 
recommended daily dose range of 4 mg to 24 mg.19 
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.  A small number of 
enrollees received around 32 mg a day or more.  See Exhibit 1. 
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  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  
Part D enrollees most commonly 
40,000 received 16 mg per day of use
s
e
e
oll 30,000
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n
E
D 
t 
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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. 
On average, enrollees received a total of 7 months of buprenorphine in the year.  
About a quarter of enrollees received buprenorphine for the entire year. 
In addition, the majority of enrollees received buprenorphine from a few prescribers 
and pharmacies.  Over half of enrollees57 percentreceived buprenorphine from 
one prescriber and almost three quarters73 percentfilled their prescriptions at 
one pharmacy. 
Most enrollees received buprenorphine-naloxone combination 
productsthese products are generally recommended for the 
treatment of opioid use disorder 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 medication 
helps minimize the risk of misuse and diversion.20  It acts as a deterrent.  If the 
medication is crushed or dissolved for misuse, the naloxone blunts the effects of the 
buprenorphine.21  In total, 84 percentor 142,321 enrolleesreceived a combination 
product in 2021 through Part D.22   
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  Findings | 5  The remaining 16 percentor 28,087 enrolleesreceived medications that contain 
only buprenorphinei.e., buprenorphine monoproducts.  According to SAMHSA, 
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.23   
While SAMHSA recommends that buprenorphine monoproducts be used for patients 
who cannot afford treatment with combination products, it is important to note that 
the Part D enrollee copayment for the most common monoproduct was, on average, 
similar to the copayment for the equivalent combination product.  Specifically, for 
enrollees who are not in the Part D Extra Help program (also known as the Part D 
Low-Income Subsidy), the average copayment for a generic sublingual tablet 
containing 8 mg of buprenorphine was 24 cents, while the average copayment for an 
equivalent tablet with naloxone was 25 cents.  People receiving Extra Help also had 
similar copayments for sublingual tablets formulated with and without naloxone.  
However, other combination productsnamely, generic and brand-name sublingual 
filmshad higher copayments than tablets.  See Appendix A for more information. 
A small number of people enrolled in Medicare Part D received 
very high amounts of buprenorphine or received buprenorphine 
at the same time as they received high amounts of other 
opioids 
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 2021.24  These patterns may indicate that 
enrollees are experiencing care coordination issues.  It could also mean that 
buprenorphine is being misused or diverted.25  These enrollees represent just 
0.7 percent of all enrollees who received buprenorphine in 2021.   
Few enrollees received very high amounts of buprenorphine   
In total, 323 Part D enrollees received more than 36 mg per day of buprenorphine, 
which is more than 50 percent higher than the maximum recommended daily dose.  
These enrollees received very high average daily dosages for more than 90 days.26  
Further, some of these enrollees received a very high number of days supply during 
the year.  For example, 41 enrollees received more than 14 months supply of 
buprenorphine in a 12-month period. 
The low number of enrollees who received very high amounts of buprenorphine 
suggests that misuse and diversion of buprenorphine is not widespread in Medicare 
Part D.27   
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  Findings | 6  Fewer than a thousand 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.28  However, a total of 927 enrollees 
received buprenorphine at the same time as they received high amounts of opioids 
indicated for pain.29  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 further suggests that misuse and diversion of buprenorphine is 
limited in Medicare Part D. 
Most prescribers ordered buprenorphine for a limited number 
of Part D enrollees; very few had patterns that raise concern  
Most prescribers ordered buprenorphine for only a few people enrolled in Medicare 
Part D.  In total, 39,199 prescribers ordered buprenorphine for Medicare Part D 
enrollees in 2021.  A third of these prescribers ordered buprenorphine for only 
one enrollee during the year.  Another third of these prescribers ordered 
buprenorphine for two to five enrollees.  Just 5 percent of prescribers ordered 
buprenorphine for more than 30 enrollees during the year.  
The low number of enrollees each prescriber treated may have been related to the 
patient limits set by the DATA waiver, which was eliminated at the end of 2022.30  
Also, providers may be hesitant to treat enrollees due to stigma around opioid use 
disorder or concerns about misuse and diversion.31  Given the large number of 
prescribers who ordered buprenorphine for just a few enrollees, additional steps may 
be necessary to meet the goal of increasing access to treatment.    
Just 35 prescribers had patterns that raise concern 
Just 35 prescribers had patterns that stood out from the norm and raise concern.  
They each ordered buprenorphine for multiple enrollees who either received very 
high levels of buprenorphine or received buprenorphine at the same time as they 
received high amounts of opioids indicated for pain.  Of these, only two prescribers 
ordered buprenorphine for more than five enrollees who received very high amounts 
of buprenorphine.  The remaining 33 prescribers ordered buprenorphine for more 
than 5 enrollees at the same time as these enrollees received high amounts of 
opioids. 
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  Findings | 7  These 35 prescribers may warrant further scrutiny.  However, the low number of 
prescribers with concerning prescribing patterns suggests that diversion of 
buprenorphine in Medicare Part D is low.   
 
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  Findings | 8  RECOMMENDATIONS 
Buprenorphine is an important medication for the treatment of opioid use disorder.  
It reduces opioid cravings and has been shown to decrease illicit opioid use and 
overdose deaths.  Ensuring that patients who need buprenorphine have access to it is 
critical to addressing the Nations opioid crisis.   
However, there are concerns about access to these medications, including 
buprenorphine.  OIG has found that very few Medicare enrollees with opioid use 
disorderjust 18 percentreceived medication.32  Furthermore, Black, Hispanic, and 
Asian/Pacific Islander enrollees are less likely to receive medication to treat their 
opioid use disorder than are White enrollees.33   
At the same time, it is important to ensure that diversion risks of buprenorphine are 
limited.  The findings of this report suggest that the risk of misuse and diversion of 
buprenorphine in Part D is low.  Notably, almost all of the people enrolled in 
Medicare Part D who received buprenorphine received the recommended amounts.  
Most enrollees received combination products which have a reduced risk of misuse or 
diversion.  In addition, only a small number of enrollees received very high amounts 
of buprenorphine or received buprenorphine at the same time as they received high 
amounts of opioids indicated for pain.  Further, just 35 prescribers had buprenorphine 
prescribing patterns that raise concern.   
Together, these findings further support the recent repeal of the waiverwhich was in 
place, in part, to limit the diversion of buprenorphine.  The repeal of the waiver is a 
significant step towards increasing access to treatment coming at a time when opioid-
related overdose deaths remain near all-time highs, with an estimated 82,310 deaths 
in 2021.  Considering the magnitude of the opioid epidemic, it is critical that CMS and 
the Department use all of the tools at their disposal to address the crisis.  
Further, the data in this report provide baseline information about buprenorphine 
utilization and prescribing that can assist CMS, the Department, and others as they 
implement changes related to the repeal and take other steps to improve access to 
buprenorphine, while also ensuring that the risk of misuse and diversion remains low. 
We recommend that CMS: 
Monitor the use of buprenorphine and share information, as appropriate, with 
Departmental partners 
With the repeal of the DATA waiver, CMS can play a unique role in monitoring the 
impact changes in buprenorphine utilization and prescribing due to its access to 
timely claims data.  For example, using Medicare claims data, CMS can provide early 
insight into any improvements in access that follow the repeal.  CMS could also 
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  Recommendations | 9  provide early warnings to the Department and its partners if there are any changes in 
utilization or prescribing patterns that raise concern related to misuse or diversion. 
As such, CMS should use its existing analytic capabilities along with the results in this 
report as baseline data and a roadmap to conduct monitoring of the use of 
buprenorphine.  CMS should pay particular attention to any changes in these patterns 
and share this information with the Department and its partners, as appropriate.  For 
example, CMS could provide information to members of its existing cross-agency 
committees, such as the overdose prevention committee.  This analysis can provide 
CMS and its partners with early, timely information about changes in utilization and 
prescribing patterns and can help to identify continued barriers to access or concerns 
about misuse or diversion. 
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 
This report found that the risk of diversion of buprenorphine in Part D appears to be 
low.  It also found that most prescribers ordered buprenorphine for just a small 
number of Part D enrollees.  As noted, providers may be hesitant to treat patients due 
to stigma around opioid use disorder or concerns about misuse or diversion.    
Accordingly, CMS should inform providers about buprenorphine use in Medicare.  It 
should aim to dispel stigma and share the results of the reportespecially the results 
indicating a low risk of diversion and misuse in Medicare Part Dand other 
information to encourage providers to treat more enrollees who have opioid use 
disorder, as appropriate.   
To do this, CMS could conduct outreach to prescribers that explains that prescribers 
with a license from the DEA to prescribe controlled substances are no longer required 
to separately register to prescribe buprenorphine.  It could also share information 
about the low risk of misuse and diversion of buprenorphine in Medicare Part D.  CMS 
could consider conducting this outreach through a Medicare Learning Network 
publication or its annual letter to Medicare providers.  
Take steps to inform providers about the availability of buprenorphine 
combination products in Part D, which can minimize the risk of misuse and 
diversion 
Buprenorphine combination productsi.e., medications that contain both 
buprenorphine and naloxoneare recommended for most patients with opioid use 
disorder over buprenorphine monoproducts to minimize the risk of misuse and 
diversion.  However, 16 percent of Part D enrollees who received buprenorphine in 
2021 received only buprenorphine monoproducts. 
CMS should take steps to inform providers about the availability of buprenorphine 
combination products in Part D and remind prescribers that the use of these 
products, rather than monoproducts, can decrease the risk of misuse and diversion.  
As a part of its efforts, CMS should ensure that providers are aware of the availability 
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  Recommendations | 10  of buprenorphine combination products with relatively low copays, such as generic 
buprenorphine-naloxone sublingual tablets.  Providing this information to providers is 
particularly important in light of the repeal of the DATA waiver, as an increased 
number of providers are newly able to order buprenorphine for patients.   
Follow up on the prescribers with concerning patterns identified in this report 
Although very few prescribers had patterns that raise concern, these prescribers may 
warrant further scrutiny.  In a separate memorandum, we will refer to CMS the 
providers who had buprenorphine prescribing patterns that raise concern.  CMS 
should review this information in conjunction with its ongoing efforts and take action, 
as appropriate. 
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  Recommendations | 11  AGENCY COMMENTS AND OIG RESPONSE 
CMS concurred with three of our recommendations.  While it did not indicate 
whether it concurred with the other recommendation, it did indicate ongoing activity 
it felt was responsive.
CMS did not explicitly indicate whether it concurred with our recommendation to 
monitor the use of buprenorphine and share information, as appropriate, with 
Departmental partners.   Rather, it provided reasons why this recommendation was 
not necessary.  CMS stated that it already has monitoring and information sharing 
processes in place which will continue.  These include quarterly Drug Trend Analysis 
and a national proactive data analysis project that is shared with Part D plan sponsors 
when unusual changes in utilization or spending are detected.  CMS also stated that, 
as OIG found buprenorphine misuse and diversion has been quite low, it has not risen 
to a level of investigative concern at this time.
While OIG is supportive of CMSs existing monitoring and information sharing 
processes, OIG recommends that CMS build on these existing efforts and conduct 
additional targeted monitoring of buprenorphine.  Doing so is of particular 
importance as the Department and its partners work to assess the impact of the 
repeal of the DATA waiver and take additional actions to address the continued 
opioid crisis.  As part of these efforts, CMS could, for example, provide information to 
members of its existing cross-agency committees, such as the overdose prevention 
committee.  These actions could help to identify and address continued barriers to 
access to buprenorphine or concerns about misuse or diversion in the wake of the 
repeal of the DATA waiver.  
CMS concurred with our recommendation 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.  CMS stated that it will seek to include this 
information in upcoming provider outreach.  
CMS also concurred with our recommendation to take steps to inform providers 
about the availability of buprenorphine combination products in Part D, which can 
minimize the risk of misuse and diversion.  CMS stated that it will seek to include this 
information in upcoming provider outreach. 
Lastly, CMS concurred with our recommendation to follow up on the prescribers with 
concerning patterns identified in this report.  CMS stated that it was pleased that only 
35 providers out of 39,199 were identified as having concerning prescribing patterns 
and that it will follow up on these 35 providers.  
For the full text of CMSs response, see Appendix B. 
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  Agency Comments and OIG Response | 12  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 Center for Disease Control and 
Preventions (CDCs) Morphine Milligram Equivalent (MME) conversion file. 
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, enrollees, and prescribers, 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 2021.34  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. 
Average Daily Dosage of Buprenorphine Analysis 
Next, we determined the amount of buprenorphine that each Part D enrollee received 
in 2021 by calculating each enrollees average daily dosage of buprenorphine.35   
To do this, we first calculated the total number of milligrams of buprenorphine in 
each prescription.36  We standardized buprenorphine products with higher 
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  Methodology | 13  bioavailability in order to sum dosages across different buprenorphine products.37  
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 2021 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 2021 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 2021. 
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.  
We also calculated the number of prescribers and pharmacies associated with each 
enrollees buprenorphine prescriptions in 2021. 
Buprenorphine Combination Product and Monoproduct Analysis 
Next, we identified which buprenorphine prescriptions were buprenorphine-naloxone 
combination products and which were buprenorphine-only monoproducts in 2021.   
Using this information, we determined the percentage of Part D enrollees who 
received at least one buprenorphine combination product in 2021 and the percentage 
who only received monoproducts. 
In addition, using the PDE records, we determined the number of PDE for each 
buprenorphine combination product and each buprenorphine monoproduct.  
We then calculated the average Part D copayment per unit of the most common 
buprenorphine monoproduct and the equivalent buprenorphine combination 
products for enrollees in 2021.38  The copayment per unit of these medications was 
calculated for enrollees with and without Extra Help.39 
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 2021.  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 2021. 
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  Methodology | 14  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 
2021.40 
Next, we determined the amount of opioids that each of these enrollees received in 
2021.  To do this, we calculated each enrollees average daily morphine milligram 
equivalent (MME) dose.41  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.42  We used the following equation: 
(SSSSSSSSSSSSSSh ppSSSS uuSSuuSS)(QQuuQQSSSSuuSSQQ dduuddppSSSSddSSdd)(MMMMMM ccccSSccSSSSdduuccSS ffQQccSSccSS)
MMMMMM = 
Next, we summed each enrollees MME (fDDorQQ QQedda cdduuhpp dppassuuySS ddo)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.  We considered enrollees to have received buprenorphine and high amounts 
of enrollees 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 2021. 
Prescriber Analysis 
We identified all prescribers who ordered at least one buprenorphine prescription in 
2021.  We used the prescriber National Provider Identifier (NPI) on the PDE records to 
identify prescribers.  We considered each NPI to indicate a unique prescriber.43  For 
each prescriber, we counted the number of Part D enrollees for whom they ordered 
buprenorphine. 
Next, we identified prescribers who had prescribing patterns that stood out from the 
norm and raised concern.  To do this, we identified prescribers who either ordered 
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  Methodology | 15  buprenorphine for more than five enrollees who received very high amounts of 
buprenorphine or ordered buprenorphine for more than five enrollees who received 
buprenorphine at the same time that they received high amounts of opioids.   
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.  
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 Appears to Be Low in Medicare Part D 
OEI-02-22-00160  Methodology | 16  APPENDIX A 
Sublingual tablet buprenorphine combination products and 
monoproducts had similar copayments among Part D enrollees; 
however, for enrollees without Extra Help sublingual films have 
higher copayments than tablets 
Average Copayment Per Unit 
Enrollees 
Enrollees with  without 
Drug Label  Extra Help*  Extra Help 
Buprenorphine 8 mg sublingual tablet  $0.03  $0.24 
Buprenorphine-naloxone 8-2 mg sublingual tablet  $0.03  $0.25 
Buprenorphine-naloxone 8-2 mg sublingual film  $0.04  $0.77 
Suboxone 8-2 mg sublingual film**  $0.06  $2.15 
*Extra Help is also known as the Part D Low-Income Subsidy.
** Suboxone is a brand-name version of buprenorphine-naloxone.
Source: OIG analysis of Medicare Part D data, 2023.
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  Appendix A | 17  APPENDIX B 
Agency Comments 
Following this page are the official comments from CMS. 
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  Appendix B | 18    AGENCY COMMENTS
DATE:  April 24, 2023 
TO:  Ann Maxwell  
Deputy Inspector General for Evaluation and Inspections 
FROM:  Chiquita Brooks-LaSure 
Administrator 
SUBJECT:  Office of Inspector General (OIG) Draft Report: The Risk of Misuse and 
Diversion of Buprenorphine for Opioid Use Disorder Appears to Be Low in 
Medicare Part D (OEI-02-22-00160) 
The Centers for Medicare & Medicaid Services (CMS) appreciates the opportunity to review and 
comment on the Office of Inspector Generals (OIG) draft report. CMS is committed to ensuring 
that Medicare beneficiaries who have an opioid use disorder (OUD) have access to appropriate 
treatment, including medication-assisted treatment such as buprenorphine. Ensuring access to 
these benefits, while guarding against improper use and prescribing, is an important part of 
combatting the nations opioid epidemic, and CMS has been actively engaged in the work 
necessary to meet these goals.  
To that end, CMS was pleased that OIG found that almost all Medicare Part D enrollees who 
received buprenorphine for the treatment of an OUD received the recommended amounts, and 
that very few prescribers of buprenorphine (.089%) had patterns that raised concern. 
While CMS appreciates the positive findings in this report, there are additional monitoring and 
coordination efforts that CMS has taken that are not referenced in the report, which CMS 
believes are integral to the successful outcomes described in the report. For example, CMS 
monitors prescription drug use in Part D (including over-utilization and/or under-utilization of 
opioids, buprenorphine, and medication-assisted treatment (MAT)) through prescription drug 
event (PDE) data to oversee sponsors compliance with drug utilization review (DUR) 
requirements as described in 42 CFR  423.153. CMS also monitors complaints in the Complaint 
Tracking Module (CTM) in the Health Plan Management System to identify potential access 
issues. CMS may follow up with Part D plan sponsors that are outliers, or share information with 
Departmental partners, as appropriate. Other efforts include the quarterly Drug Trend Analysis, a 
national proactive data analysis project conducted by CMS in collaboration with the Plan 
Program Integrity Medicare Drug Integrity Contractor (PPI MEDIC), which detects unusual 
changes in specific drug utilization and total Medicare Part D drug spending for prescription 
drug event (PDE) records. The quarterly Drug Trend Analysis would identify any changes in 
buprenorphine use or prescribing. Any unusual changes would be reviewed for further action and 
included in the quarterly report sent to Part D plan sponsors.  
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   Appendix B | 19 In addition, CMS has relationships with Departmental partners through which we share 
information on cases and strategies, when appropriate. CMS convenes ad hoc meetings with our 
law enforcement partners to discuss emerging and ongoing fraud schemes. As OIG found in this 
report, buprenorphine misuse and diversion has been quite low, and therefore has not risen to a 
level of investigative concern at this time. However, these ongoing monitoring efforts will ensure 
that any changes can be identified and addressed proactively.  
Combatting the opioid epidemic is a priority for the agency, and we appreciate that the OIG 
recognizes the success of CMS many ongoing efforts, which will be key in moving this effort 
forward.  
OIGs recommendations and CMS' responses are below. 
OIG Recommendation  
CMS should monitor the use of buprenorphine and share information, as appropriate, with 
Departmental partners. 
CMS Response  
CMS has in place comprehensive monitoring and information sharing processes, and these have 
continued after the repeal of theDrug Addiction Treatment Act (DATA) waiver. As described 
 
above, these efforts include the quarterly Drug Trend Analysis, a national proactive data analysis 
project shared with Part D plan sponsors that detects unusual changes in specific drug utilization 
and total Medicare Part D drug spending for prescription drug event (PDE) records, including 
changes in utilization or prescribing patterns that raise concern related to misuse or diversion, ad 
hoc meetings with our law enforcement partners to discuss emerging and ongoing fraud schemes, 
and monitoring over-utilization and/or under-utilization of opioids, buprenorphine, and 
medication-assisted treatment (MAT), and tracking access issues. CMS will continue to monitor 
this area for any changes. As OIG found in this report, buprenorphine misuse and diversion has 
been quite low, and therefore has not risen to a level of investigative concern at this time. Due to 
the current efforts by CMS, we continue to recommend that OIG remove this recommendation.  
OIG Recommendation  
CMS should 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. 
CMS Response  
CMS concurs with this recommendation and will seek to include this information in upcoming 
provider outreach.  
OIG Recommendation  
CMS should take steps to inform providers about the availability of buprenorphine combination 
products in Part D, which can minimize the risk of misuse and diversion. 
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    Appendix B | 20 CMS Response  
CMS concurs with this recommendation and will seek to include this information in upcoming 
provider outreach. CMS appreciates OIGs finding that most enrollees already received 
buprenorphine-naloxone combination products. 
OIG Recommendation  
CMS should follow up on the prescribers with concerning patterns identified in this report. 
CMS Response  
CMS concurs with this recommendation. CMS is pleased to note that OIG found that only 35 
providers out of 39,199 had concerning prescribing patterns (.089%). While OIGs findings 
underline that nearly all providers prescribing buprenorphine to Medicare Part D beneficiaries 
are doing so appropriately, we will follow up on the 35 providers that OIG identified.  
CMS thanks OIG for their efforts on this issue and looks forward to working with OIG on this and 
other issues in the future. 
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            Appendix B | 21 ACKNOWLEDGMENTS AND CONTACT 
Acknowledgments 
Margaret Himmelright and Jason Kwong served as the team leaders for this study.  
Others in the Office of Evaluation and Inspections New York Regional Office who 
conducted the study include Miriam Anderson.  Office of Evaluation and Inspections 
headquarters staff who provided support include Althea Hosein, Michael Novello, 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 Appears to Be Low in Medicare Part D 
OEI-02-22-00160  Acknowledgments and Contact | 22  ENDNOTES 
1 CDC, Provisional Drug Overdose Death Counts, January 1, 2023.  Accessed at https://www.cdc.gov/nchs/nvss/vsrr/drug-
overdose-data.htm on January 12, 2023. 
2 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 December 21, 2022.
3 Buprenorphine is also separately indicated for pain.  Buprenorphine products indicated for pain are different from 
buprenorphine products indicated for the treatment of opioid use disorder.  
4 OIG, Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries, 
OEI-02-22-00390, September 2022. 
5 OIG, Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder, OEI-02-20-00390, 
December 2021.  
6 P.L. No. 117-328  1262.  Also see SAMHSA, Removal of DATA Waiver (X-Waiver) Requirement, January 25, 2023.  Accessed at 
https://www.samhsa.gov/medications-substance-use-disorders/removal-data-waiver-requirement on March 9, 2023. 
7 Office of National Drug Control Policy, National Drug Control Strategy, April 2022.  Accessed at 
https://www.whitehouse.gov/wp-content/uploads/2022/04/National-Drug-Control-2022Strategy.pdf on January 12, 2023. 
8  OIG, Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries, 
OEI-02-22-00390, September 2022. 
9 Buprenorphine products indicated for pain are different from buprenorphine products indicated for the treatment of opioid 
use disorder. 
10 Methadone and naltrexone are also approved by the Food and Drug Administration (FDA) for the treatment of opioid use 
disorder.   
11 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 7, 2022. 
12 For more information about controlled substance scheduling, see DEA, Drug Scheduling.  Accessed at 
https://www.dea.gov/drug-information/drug-scheduling on February 9, 2023. 
13 The Drug Addiction Treatment Act of 2000 was enacted under Title XXXV of the Childrens Health Act of 2000, P.L. No. 106-
310. 
14 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). 
15 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 
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  Endnotes | 23  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). 
16 P.L. No. 117-328  1262.  
17 P.L. No. 117-328  1263.  
18 This analysis is based on Medicare claims data.  We did not review medical records. 
19 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 
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.    
20 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 February 1, 2023.  Also see SAMHSA, Buprenorphine Quick Start Guide.  Accessed at 
https://www.samhsa.gov/sites/default/files/quick-start-guide.pdf on November 8, 2022.  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 February 1, 2023.  
21 SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use Disorder, 2021. 
22 A total of 7,433 (4 percent) of Part D enrollees received both buprenorphine combination products and monoproducts. 
23 SAMHSA, Buprenorphine Quick Start Guide.  SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use 
Disorder, 2021.   
24 Five 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 2021. 
25 According to SAMHSA, higher doses of buprenorphine may heighten diversion risk.  SAMHSA, Treatment Improvement 
Protocol 63: Medications for Opioid Use Disorder, 2021. 
26 Enrollees with cancer or sickle cell disease; those receiving palliative care; and those in hospice care were not included in this 
analysis. 
27 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/download/21349/medications-to-treat-opioid-use-disorder-research-
report.pdf?v=99088f7584dac93ddcfa98648065bfbe on October 25, 2022.  
28 This analysis excluded buprenorphine indicated for the treatment of pain. 
29 Enrollees with cancer or sickle disease; those receiving palliative care; and those who were in hospice care were not included 
in this analysis.   
30 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).  
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  Endnotes | 24  31 SAMHSA, Practical Tools for Prescribing and Promoting Buprenorphine in Primary Care Settings, 2021.  SAMHSA Publication 
No. PEP21-06-01-002.  Accessed at https://store.samhsa.gov/sites/default/files/pep21-06-01-002.pdf on February 6, 2023.  
Also see National Academies of Sciences, Engineering, and Medicine; Health and Medicine Division; Board on Health Sciences 
Policy; Committee on Medication-Assisted Treatment for Opioid Use Disorder; Mancher, M., Leshner, AI, editors, Medications 
for Opioid Use Disorder Save Lives. Ch.5.  Washington (DC): National Academies Press (US), March 30, 2019.  Accessed at 
https://www.ncbi.nlm.nih.gov/books/NBK541389/ on February 6, 2023. 
32 OIG, Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries, 
OEI-02-22-00390, September 2022. 
33 OIG, Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder, OEI-02-20-00390, 
December 2021.  
34 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. 
35 We limited this analysis to oral buprenorphine products. 
36 We included buprenorphine dispensed in 2020 with days supply in 2021.  This analysis excluded prescriptions for implant 
and injection buprenorphine. 
37 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, 2002.  Accessed at 
https://www.accessdata.fda.gov/drugsatfda_docs/label/2016/204242s009lbl.pdf on December 14, 2022.    
38 For each buprenorphine product, we divided the total copayments by the total quantity dispensed. 
39 We considered an enrollee to have receive Extra Help (also known as the Low-Income Subsidy) if they had at least 1 PDE in 
2021 with more than $0 of low-income subsidy. 
40 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 2021, 
buprenorphine PDE and other opioid PDEs had days supply that fell on the same calendar day. 
41 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 April 27, 2023. 
42 We included opioids dispensed in 2020 with days supply in 2021.  This analysis excludes prescriptions for injection, 
intravenous, and intrathecal opioids, as well as opioids indicated as medications for opioid use disorder. 
43 For our analysis, we counted prescribers in group practices separately. 
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  Endnotes | 25