U.S. Department of Health and Human Services 
 Office of Inspector General 
 
 
Data Brief 
 
 September 2022, OEI-02-22-00390 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder 
Continue To Be Concerns for Medicare Beneficiaries 
Why OIG Did This Review 
Key Results 
As the nation continues to grapple with the effects of the COVID-19 
About 50,400 Medicare  pandemic, the opioid epidemic continues to surge.  In 2021, there were 
Part D beneficiaries  an estimated 81,502 opioid-related overdose deaths in the United 
experienced an opioid  Statesan all-time high.1  Accordingly, it is critical to monitor opioid 
overdose in 2021.  use and access to treatment for beneficiaries with opioid use disorder as 
Almost a quarter of Part D  well as access to the opioid overdose-reversal drug naloxone. 
beneficiaries received opioids 
This data brief provides important information on these topics for 
during the year. 
beneficiaries in Medicare Part D in 2021.  It builds on a series of data 
More than 1 million Medicare  briefs released by the Office of Inspector General (OIG).2 
beneficiaries had a diagnosis 
of opioid use disorder in  What OIG Found 
2021, yet fewer than 1 in 5 
About 50,400 Part D beneficiaries experienced an opioid overdose
received medication to treat 
from prescription opioids, illicit opioids, or bothduring 2021.  This 
their opioid use disorder. 
number is likely higher in that additional beneficiaries could have 
The number of Part D  overdosed but not received medical care that was billed to Medicare, or 
beneficiaries receiving 
their claims might have not yet been submitted to Medicare.  At the 
prescriptions for the opioid 
same time, the number of Medicare Part D beneficiaries who received 
overdose-reversal drug 
opioids in 2021 decreased to almost a quarter of beneficiaries, 
naloxone through Part D 
extending a downward trend from prior years.  Further, fewer Part D 
grew. 
beneficiaries were identified as receiving high amounts of opioids or at 
serious risk.  The number of prescribers ordering opioids for large 
numbers of beneficiaries at serious risk was steady.  Still, over 1 million Medicare beneficiaries had a 
diagnosis of opioid use disorder in 2021, and fewer than 1 in 5 of them received medication to treat 
their disorder.3  At the same time, the number of Part D beneficiaries receiving naloxone increased.   
What OIG Concludes 
There is clearly still cause for concern and vigilance, even as some positive trends emerge.  Monitoring 
opioid use and access to medications for the treatment of opioid use disorder as well as to naloxone 
are critical to addressing the opioid crisis.  A December 2021 OIG report recommended that the Centers 
for Medicare & Medicaid Services (CMS) take steps to improve access to medications for the treatment 
of opioid use disorder and other support services.4  We continue to call attention to the importance of 
implementing these recommendations and to ensuring access to treatment for opioid use disorder for 
Medicare beneficiaries.  OIG is also committed to continuing our work on opioid use and access to 
treatment. 
   
RESULTS 
 
Opioid overdoses remain a concern, with about 50,400 Part D 
beneficiaries experiencing an overdose in 2021 
In 2021, at least 50,391 Part D beneficiaries experienced an opioid overdose.  This is 
the number of Part D beneficiaries who received medical care for an opioid overdose, 
such as an emergency room visit, that was billed to Medicare.5  These overdoses were 
linked to prescription opioids, illicit opioids, or both. 
The total number of beneficiaries who experienced an opioid overdose is likely higher.  
Additional beneficiaries could have overdosed but not received medical care that was 
billed to Medicare.  For example, a beneficiary who suffered a fatal overdose alone 
would not be counted if there was no medical care billed to Medicare.  Further, if a 
beneficiarys claim had yet to be submitted to Medicare at the time that claims data 
was analyzed for this report (July 2022), then their overdose would not be identified. 
On average, about 4,800 beneficiaries per month experienced an overdose in 2021.  
However, in certain months the number was much higher.  Between April and July 
2021, more than 5,000 Part D beneficiaries per month received treatment for an 
opioid overdose that was billed to Medicare.  See Exhibit 1. 
Exhibit 1: At least 5,000 Part D beneficiaries experienced an opioid overdose 
per month between April and July 2021. 
5,404
4,972 5,069 5,058 5,161 4,968
4,823 4,795
4,534 4,554
4,298
4,172
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
 
Source: OIG analysis of Medicare data, 2022. 
 
 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Results | 2  Almost a quarter of Part D beneficiaries received opioids in 2021 
In 2021, almost a quarter of Part D beneficiaries received at least one prescription 
opioid through Medicare Part D.  Twenty-three percent of beneficiaries12.1 million 
of the 51.6 million beneficiaries enrolled in Medicare Part Dreceived opioids.  This is 
an overall decrease from 2020, when 24 percent of beneficiaries received opioids 
through Part D, and it continues a downward trend from prior years.  From 2016 to 
2019, the proportion of beneficiaries receiving opioids declined from 33 percent to 
26 percent.6  (See Appendix A for information about opioid use in each State.) 
Part D paid for 61.4 million opioid prescriptions, an average of 5.1 prescriptions per 
beneficiary receiving opioids in 2021.7  This total number is a decrease from 2020, 
when Medicare paid for 63.4 million opioid prescriptions.  It is also a decline from 
previous years.  From 2016 to 2019, the number of opioid prescriptions exceeded 
66 million annually.8 
Similarly, overall Part D spending for opioids also decreased.  Part D paid about 
$2.6 billion for opioids in 2021, compared to $2.7 billion in 2020. 
Almost 200,000 Part D beneficiaries received high amounts of 
opioids in 2021 
In 2021, a total of 199,169 beneficiaries received high amounts of opioids through 
Medicare Part Di.e., each beneficiary had an average morphine equivalent dose 
(MED) of greater than 120 mg a day for at least 3 months.  MED is a measure that 
converts all the various opioids and strengths into one standard value.  These 
beneficiaries did not have cancer and were not in hospice care.9 
The number of beneficiaries receiving high amounts of opioids is a decrease from 
2020, when 225,463 beneficiaries received high amounts.  It is also a decline from 
previous years.  (See Appendix B for more information about previous years.) 
Although beneficiaries may receive opioids for legitimate purposes, these amounts 
raise concern as opioids carry a number of health risks.10  CDC recommends that 
prescribers use caution when ordering opioids at any dosage and avoid increasing 
dosages to the equivalent of 90 mg or more MED a day for chronic pain or carefully 
justify the decision to increase to this level.11 
About 23,000 beneficiaries were at serious risk because they 
received extreme amounts of opioids or appeared to be doctor 
shopping  
Two subgroups of beneficiaries in particular are at serious risk of misuse or overdose: 
(1) beneficiaries who receive extreme amounts of opioids and (2) beneficiaries who 
appear to be doctor shopping.  Other Part D beneficiaries may also be at serious risk 
but do not fall into either group. 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Results | 3  A total of 23,186 beneficiaries were in these subgroups.12  (This does not include 
beneficiaries who have cancer or were in hospice care.)  Specifically, 
21,493 beneficiaries received extreme amounts of opioids (i.e., had an average daily 
MED greater than 240 mg for 12 months) and 1,805 beneficiaries appeared to be 
doctor shopping (i.e., received high amounts of opioids and had 4 or more prescribers 
and 4 or more pharmacies).  A total of 112 beneficiaries were in both groups. 
The number of beneficiaries at serious risk in 2021 (23,186 beneficiaries) declined 
21 percent from 2020, when OIG identified 29,306 beneficiaries.13  Of note, the larger 
drop occurred in the number of beneficiaries who received extreme amounts of 
opioids.  In 2021, there were about a fifth fewer beneficiaries who received extreme 
amounts of opioids than in 2020.14  (See Appendix B for more detailed information.) 
Receiving extreme amounts of opioids or receiving high amounts of opioids from 
multiple prescribers or pharmacies raises concern.  It may signal that a beneficiarys 
care is not being monitored or coordinated properly or that a beneficiarys care needs 
to be reassessed.15  It may also indicate that a beneficiary is seeking medically 
unnecessary drugsperhaps to use them recreationally or to divert themor that a 
beneficiary is addicted to opioids and at risk of overdose. 
Furthermore, a beneficiarys receiving high amounts of opioids and having multiple 
prescribers and pharmacies may indicate that prescribers are not checking the 
beneficiarys opioid history before prescribing.  States maintain databasescalled 
prescription drug monitoring programsthat track prescriptions for controlled 
substances.16  Prescribers can check these databases before ordering opioids to 
determine whether a beneficiary is already receiving opioids ordered by other 
prescribers.17 
Raising particular concern, a total of 244 beneficiaries had an average daily MED of 
more than 1,000 mg a day for the entire year. 
About 100 prescribers had questionable opioid prescribing for 
beneficiaries at serious risk  
A total of 26,245 prescribers ordered opioids for at least 1 beneficiary at serious risk 
of opioid misuse or overdose (i.e., a beneficiary who received extreme amounts of 
opioids or appeared to be doctor shopping in 2021).  The vast majority of these 
prescribers each ordered opioids for only one or two of these beneficiaries.  Some 
prescribers ordered for many more. 
A total of 98 prescribers stand out as having questionable prescribing; they were far 
outside the norm with their prescribing and warrant further scrutiny.  They ordered 
opioids for the highest numbers of beneficiaries at serious risk.  Specifically, 
68 prescribers each ordered opioids for at least 27 beneficiaries who received extreme 
amounts of opioids in 2021.  Further, 35 prescribers each ordered opioids for at least 
6 beneficiaries who appeared to be doctor shopping.  Five prescribers ordered 
opioids for high numbers of beneficiaries in both groups at serious risk. 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Results | 4  The number of prescribers with questionable prescribing for beneficiaries at serious 
risk was steady, with 98 prescribers with questionable prescribing.  By contrast, 
between 2016 and 2020 the number of prescribers with questionable opioid 
prescribing declined by about 30 percent each year.  (See Appendix C for more 
information about previous years.) 
Although opioids may be necessary for some patients, prescribing to an unusually 
high number of beneficiaries at serious risk raises concerns.  It may indicate that 
beneficiaries are receiving poorly coordinated care and could be in danger of 
overdose or dependence.  It may also signal that prescribers are not checking State 
prescription drug monitoring databases, or that these databases do not have current 
data. 
Prescribing to an unusually high number of beneficiaries at serious risk could also 
indicate that the prescriber is ordering medically unnecessary drugs that could be 
diverted for resale or recreational use.  Another possibility is that the prescribers 
identification has been sold or stolen and is being used for illegal purposes. 
In total, these 98 prescribers ordered 50,554 opioid prescriptionstotaling 
$15.1 million of Part D costsfor beneficiaries at serious risk in 2021. 
More than one million Medicare beneficiaries had a diagnosis of 
opioid use disorder in 2021 
In 2021, 1.1 million Medicare beneficiaries1,100,884had a diagnosis of opioid use 
disorder.18  Opioid use disorder is a problematic pattern of opioid use that leads to 
clinically significant impairment or distress.19  It is a chronic condition that can be 
treated with certain medications that have been shown to decrease illicit opioid use 
and opioid-related overdose deaths.  When these medications are combined with 
behavioral therapy or counseling, it is referred to as medication-assisted treatment 
(MAT).20   
Diagnosing opioid use disorder requires a thorough evaluation that may include 
checking a patients history of opioid prescriptions or testing a patients urine.21  
To receive a diagnosis, a patient must meet two or more diagnostic criteria, such as 
craving opioids or taking opioids in larger amounts or over a longer period than 
intended.22 
Fewer than 1 in 5 Medicare beneficiaries with an opioid use 
disorder diagnosis received medication to treat their opioid use 
disorder in 2021 
Fewer than 1 in 5 Medicare beneficiaries with opioid use disorder received medication 
for this disorder in 2021.  A total of 194,860 Medicare beneficiaries out of the 
1.1 million diagnosedabout 18 percentreceived a medication to treat their opioid 
use disorder in an outpatient setting.  Currently, three medications are approved by 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Results | 5  the Food & Drug Administration (FDA) for the treatment of opioid use disorder: 
buprenorphine, methadone, and naltrexone.  The FDA recommends that all three of 
these medications be available to all patients because certain medications may be 
more appropriate for some patients than others.23  These medications are sometimes 
referred to as medications for opioid use disorder (MOUD). 
Methadone for the treatment of opioid use disorder can only be administered or 
dispensed by opioid treatment programs.24  Because methadone for the treatment of 
opioid use disorder is not dispensed by a pharmacy, it is not covered by Part D.25  
Buprenorphine for the treatment of opioid use disorder can also be dispensed or 
administered at opioid treatment programs.  It can also be prescribed or administered 
in office-based settings by providers who obtain a waiver through the Substance 
Abuse and Mental Health Services Administration (SAMHSA).26  The dispensing and 
administration of naltrexone is not subject to these restrictions.  Both buprenorphine 
and naltrexone are covered by Part D.   
The overall proportion of beneficiaries with opioid use disorder receiving medication 
increased from 2020 to 2021.  In 2020, about 16 percent of Medicare beneficiaries 
received medication in outpatient settings, compared to about 18 percent in 2021.27  
Nonetheless, this low proportion may indicate that beneficiaries have challenges 
accessing treatment.  
Most beneficiaries received medication to treat their opioid use 
disorder in office-based settings, covered by Medicare Part D 
Of the 194,860 Medicare beneficiaries who received medication to treat their opioid 
use disorder, close to three-quarters of them141,327 of 194,860received their 
medication in office-based settings.  This includes beneficiaries whose providers 
ordered prescriptions that were filled at pharmacies as well as beneficiaries whose 
providers directly administered the medications (e.g., long-acting, injectable 
medications).  The vast majority of beneficiaries140,876had their medications 
covered by Medicare Part D.  A small number of beneficiaries2,540had their 
medication covered by Part B or C.28  See Exhibit 2. 
   
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Results | 6  Exhibit 2: Part D covered almost all of the beneficiaries who received  
office-based medication to treat their opioid use disorder. 
   Beneficiaries*  Percentage of Total* 
Part D  140,876  99.7% 
Part B or C  2,540  2%  
  Total  141,327 
* Beneficiaries and percentages do not sum to the total and 100%, respectively,  
because some beneficiaries received medications from Part D and from Part B or C. 
Source: OIG analysis of Medicare data, 2022. 
 
Most beneficiaries who received medication in office-based settings received 
buprenorphine.  In total, 134,031 beneficiaries received buprenorphine.  As previously 
mentioned, in order to prescribe buprenorphine in office-based settings prescribers 
are required to obtain a special waiver from SAMHSA.  An additional 
8,762 beneficiaries received naltrexone.29  See Exhibit 3. 
 
Exhibit 3: Most beneficiaries who received office-based medication to treat 
opioid use disorder received buprenorphine. 
   Beneficiaries*  Percentage of Total* 
Buprenorphine  134,031  95% 
Naltrexone  8,762    6% 
  Total  141,327 
* Beneficiaries and percentages do not sum to the total and 100%, respectively,  
because some beneficiaries received both buprenorphine and naltrexone. 
Source: OIG analysis of Medicare data, 2022. 
A smaller number of beneficiaries received medication from 
opioid treatment programs 
A smaller number57,482 of the 194,860received their medication from opioid 
treatment programs in 2021.30  See Exhibit 4.  This marked the second year in which 
Medicare covered treatment services provided at opioid treatment programs.  Prior to 
2020, opioid treatment programs were not a provider type recognized by Medicare.31  
SAMHSA requires opioid treatment programs to provide adequate medical, 
counseling, vocational, educational, and other assessment and treatment services in 
addition to providing medication.32 
   
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Results | 7  Exhibit 4: Most beneficiaries received medication from office-based settings 
to treat their opioid use disorder. 
   Beneficiaries*  Percentage of Total* 
Office based  141,327  73% 
Opioid treatment programs  57,482  29%  
  Total  194,860 
* Beneficiaries and percentages do not sum to the total and 100%, respectively, because some  
beneficiaries received treatment from both settings. 
Source: OIG analysis of Medicare data, 2022. 
 
Most beneficiaries who received medication from opioid treatment programs
55,213received methadone.  As mentioned previously, opioid treatment programs 
are the only providers allowed to administer or dispense methadone for the 
treatment of opioid use disorder.  A smaller number3,194received 
buprenorphine.  Just 21 received naltrexone.  See Exhibit 5. 
Exhibit 5: Most beneficiaries who received treatment from opioid treatment 
programs received methadone. 
   Beneficiaries*  Percentage of Total* 
Methadone  55,213  96% 
Buprenorphine  3,194  6% 
Naltrexone  21  0.04%  
  Total  57,482 
* Beneficiaries and percentages do not sum to the total and 100%, respectively, because  
some beneficiaries received more than one type of medication. 
Source: OIG analysis of Medicare data, 2022. 
The number of beneficiaries receiving prescriptions for the 
overdose-reversal drug naloxone through Part D grew in 2021 
The number of beneficiaries receiving naloxone prescriptions through Part D grew in 
2021.  This continues an upward trend that has occurred in every recent year other 
than 2020, when there was a slight decrease.  Naloxone is a medication that can 
reverse the effects of an opioid overdose.  Overdoses occur when high doses of 
opioidsalone or in combination with other substancescause breathing to slow to 
dangerous levels or to stop altogether.  When naloxone (such as the brand-name 
drug Narcan) is administered in a timely fashion, it can save lives by blocking the 
effects of opioids and restoring normal breathing.33 
A total of 445,561 Part D beneficiaries received a naloxone prescription in 2021, 
compared to 377,549 beneficiaries in 2020.  See Exhibit 6.  This represents an 
18 percent increase in the number of beneficiaries receiving naloxone.  Additional 
beneficiaries may have received naloxone other than through Part D.34 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Results | 8  Exhibit 6:  The number of beneficiaries receiving naloxone through Part D 
increased in 2021. 
445,561
378,926
377,549
222,805
89,866
37,031
7,201 9,401 6,870 5,346 5,889 11,548
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
 
 
Source: OIG analysis of Medicare data, 2022. 
 
The total number of prescriptions for naloxone also increased, reaching 
503,003 prescriptions in 2021a 19 percent increase from 2020.  Increasing access to 
naloxone is a priority of the Administration.35  It recommends ensuring that harm 
reduction organizations have access to naloxone and the use of data-driven efforts to 
ensure that naloxone is supplied to areas that most urgently need it.  
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Results | 9   
CONCLUSION 
 
 
The opioid epidemic continues to grip the nation.  There is clearly still cause for 
concern and vigilance, even as some positive trends emerge.  In 2021, at least 
50,400 Part D beneficiaries experienced an opioid overdose.  At the same time, the 
number of Medicare Part D beneficiaries who received opioids in 2021 decreased to 
approximately a quarter of a million beneficiaries, extending a downward trend from 
prior years.  Further, fewer Part D beneficiaries were identified as receiving high 
amounts of opioids or at serious risk of misuse or overdose.  The number of 
prescribers ordering opioids for large numbers of beneficiaries at serious risk was 
steady.  
Still, over 1 million Medicare beneficiaries had a diagnosis of opioid use disorder in 
2021, and fewer than 1 in 5 of them received medication to treat their opioid use 
disorder.  This low proportion may indicate that beneficiaries have challenges 
accessing treatment.  At the same time, the number of Part D beneficiaries receiving 
the opioid overdose-reversal drug naloxone, increased.   
Monitoring opioid use and access to treatment of opioid use disorder and to 
naloxone has always been critical to fighting the opioid crisis in this country.  Ensuring 
access to medications to treat opioid use disorder remains a top priority of OIG.  
OIG recently recommended that CMS do more to ensure access to treatment, 
including by (1) conducting additional outreach to beneficiaries to increase awareness 
about Medicare coverage for the treatment of opioid use disorder; (2) taking steps to 
increase the number of providers and opioid treatment programs for Medicare 
beneficiaries with opioid use disorder; (3) assisting SAMHSA by providing data about 
the number of Medicare beneficiaries receiving buprenorphine in office-based 
settings and the geographic areas where Medicare beneficiaries remain underserved; 
and (4) creating an action plan and taking steps to address disparities in the 
treatment of opioid use disorder.36 
We continue to call attention to the importance of implementing these 
recommendations and to ensuring access to treatment for opioid use disorder for 
Medicare beneficiaries.  We are encouraged that CMS is taking steps to address these 
recommendations and is committed to promoting access to prevention and 
treatment services for opioid use disorder.  For instance, in April 2022 CMS released a 
Behavioral Health Strategy that includes goals of strengthening equity and quality in 
behavioral health care and improving access to substance use disorders prevention, 
treatment, and recovery services.37  Also underway is the Value in Opioid Use Disorder 
Treatment Demonstration Program which aims to increase Medicare beneficiary 
access to opioid use disorder treatment services, improve physical and mental health 
outcomes, and reduce program expenditures.38  We also encourage CMS to continue 
to take steps to increase the use of naloxone among Medicare beneficiaries.39   
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Conclusion | 10  In addition, OIG is committed to working with our law enforcement partners and with 
CMS.  We will refer prescribers with questionable opioid prescribing to CMS, as 
appropriate.  We are also committed to continuing our work on access to treatment 
and to increasing the use of the overdose-reversal drug naloxone.40 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Conclusion | 11   
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 use the Center for 
Disease Control and Preventions (CDCs) Morphine Milligram Equivalent (MME) 
conversion file. 
PDE records are for prescriptions that beneficiaries 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 beneficiary enrolled in their plans.  Each record contains 
information about the drug and beneficiary, as well as the identification numbers for 
the pharmacy and the prescriber. 
To obtain descriptive information about the drugs, beneficiaries, and prescribers, we 
matched PDE records to data from the First DataBank, the National Claims History 
File, Part C Encounter Data, 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., an opioid).  The National Claims History File contains 
claims data from Medicare Parts A and B, including diagnosis codes and prescribed 
medications.  Part C Encounter Data contain medical claims data, including diagnosis 
codes and prescribed medications, for beneficiaries enrolled in Medicare Advantage 
plans.  CDCs MME conversion file contains information about each opioid drugs 
morphine milligram equivalence.41  For the purposes of this study, we use the term 
prescription to mean one PDE record. 
Analysis of Opioid Overdoses 
To determine the number of Part D beneficiaries who had an opioid overdose in 2021, 
we used inpatient and outpatient (including professional) claims data from the 
National Claims History File and Part C Encounter Data.  We considered a beneficiary 
to have had an overdose if the beneficiary had at least one claim from Medicare Part 
A, B, or C with a diagnosis of an opioid poisoning from prescription or illicit opioids in 
2021. 
Analysis of Proportion of Part D Beneficiaries Receiving Opioids 
Using the PDE records and Medicare Enrollment Database, we determined the 
proportion of the Part D beneficiaries who received opioids in 2021.  First, we 
determined the proportion of beneficiaries enrolled in Part D nationwide who 
received at least one opioid.  We then determined the proportion of beneficiaries 
enrolled in each State who received at least one opioid. 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Methodology | 12  Analysis of Part D Beneficiaries Receiving High Amounts of 
Opioids 
We determined the amount of opioids that each beneficiary received in 2021.  To do 
this, we calculated each beneficiarys average daily morphine equivalent dose (MED).42  
The MED converts opioids of different ingredients, strengths, and forms into 
equivalent milligrams of morphine.  It allows us to sum dosages of different opioids to 
determine a beneficiarys daily opioid level. 
To calculate each beneficiarys average daily MED, we first calculated the MED for 
each prescription (i.e., for each PDE record).43  To do this, we used the following 
equation: 
 
(SSSSSSSSSSSSSSh ppSSSS uuSSuuSS)(QQuuQQSSSSuuSSQQ dduuddppSSSSddSSdd)(MMMMMM ccccSSccSSSSdduuccSS ffQQccSSccSS)
MMMMMM = 
Next, we summed each beneficiarys ME(MMDQQ fQQoddr  edduuacpphpp ssduuSSaddy) of the year based on the dates 
of service and days supply on each PDE record.  We refer to this as the daily MED.  We 
excluded from this analysis beneficiaries who had a diagnosis of cancer or a hospice 
stay at any point in 2021.44 
We analyzed the MED data using the same criteria that we used in our previous 
analysis of the 2016, 2017, 2018, 2019, and 2020 data.45  We began by determining 
the extent to which beneficiaries received high amounts of opioids.  To do this, we 
calculated each beneficiarys average daily MED over each 90-day period in 2021.  
We determined that beneficiaries received high amounts of opioids if they exceeded 
an average daily MED of 120 mg for any 90-day period and had received opioids for 
90 or more days in the year.  The MED of 120 mg exceeds the 90-mg MED level that 
CDC recommends avoiding for patients with chronic pain. 
We then determined the extent to which these beneficiaries received extreme 
amounts of opioids.  We calculated each beneficiarys average daily MED over the 
entire year.  We considered a beneficiary who exceeded an average daily MED of 
240 mg for the entire year and had received opioids for 360 days or more to have 
received an extreme amount of opioids. 
Next, we determined the extent to which beneficiaries appeared to be doctor 
shopping.  To do this, we calculated the total number of prescribers and pharmacies 
from which each beneficiary received opioids in 2021.  We considered beneficiaries to 
have appeared to be doctor shopping if they exceeded an average daily MED of 
120 mg for any 90-day period; received opioids for 90 or more days in the year; and 
received opioids from four or more prescribers and four or more pharmacies.   
Lastly, we compared the number of beneficiaries who received high amounts of 
opioids and who were at serious risk of opioid misuse or overdose to the numbers of 
beneficiaries whom we had previously identified in our analyses of the 2016, 2017, 
2018, 2019, and 2020 data. 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Methodology | 13  Analysis of Part D Beneficiaries at Serious Risk of Opioid Misuse 
or Overdose  
We also identified beneficiaries at serious risk of opioid misuse or overdose.  We 
analyzed the data for 2021.  We considered a beneficiary to be at serious risk if the 
beneficiary received extreme amounts of opioids or appeared to be doctor shopping. 
We considered a beneficiary to have received an extreme amount of opioids if the 
beneficiary exceeded an average daily MED of 240 mg for 2021. 
To identify beneficiaries who appear to be doctor shopping, we calculated the total 
number of prescribers and pharmacies from which each beneficiary received opioids 
in 2021.  We considered beneficiaries to have appeared to be doctor shopping if the 
beneficiary exceeded an average daily MED of greater than 120 mg MED for 3 months 
and received opioids from four or more prescribers and four or more pharmacies.  
We identified prescribers and pharmacies based on their National Provider Identifier 
(NPI) numbers. 
Once identified, we compared the beneficiaries identified as being at serious risk in 
2021 to the beneficiaries identified as being at serious risk in 2016, 2017, 2018, 2019, 
and 2020. 
Identification of Prescribers With Questionable Prescribing  
For this analysis, we identified prescribers who ordered opioids for a high number of 
beneficiaries at serious riski.e., beneficiaries who received extreme amounts of 
opioids and beneficiaries who appeared to be doctor shopping.  We considered these 
prescribers to have questionable prescribing patterns that warrant further scrutiny.  
We used the NPIs on the PDE records to identify prescribers.  We considered each NPI 
to be a unique prescriber.46 
In total, 19,460 prescribers ordered opioids for beneficiaries who received extreme 
amounts of opioids and 9,028 prescribers ordered opioids for beneficiaries who 
appeared to be doctor shopping.  For each of these prescribers, we calculated the 
number of beneficiaries in each group for whom the prescriber ordered opioids.  We 
then identified the prescribers who ordered opioids for the highest number of 
beneficiaries in each group.  All of these prescribers are extreme outliers in terms of 
the number of beneficiaries to whom they prescribed opioids in one of the groups at 
serious risk.  These prescribers were more than 3 standard deviations above the mean 
and in the top 0.3 percent. 
Analysis of Beneficiaries Receiving Medication to Treat Their 
Opioid Use Disorder 
We used Medicare Parts A and B Claims Data and Part C Encounter Data to determine 
which Medicare beneficiaries had a diagnosis of opioid use disorder in their 2021 
claims.  We considered beneficiaries to have opioid use disorder if they had a 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Methodology | 14  diagnosis code categorized as opioid abuse (F11.1) or opioid dependence (F11.2) 
on any claim during 2021. 
We then determined the extent to which these beneficiaries received medication to 
treat their opioid use disorder through Medicare in 2021. 
Prescription Drug Event Records.  We first used the PDE records to identify the 
number of beneficiaries who filled prescriptions for medications for opioid use 
disorder at pharmacies in 2021.  Drugs filled at pharmacies are covered by Part D.  
They may be covered by standalone prescription drug plans (PDPs) or prescription 
drug plans that are part of Medicare Advantage plans (MA-PDs). 
Medicare Claims and Part C Encounter Data.  We then used Medicare Part B Claims 
Data and Part C Encounter Data to identify the number of beneficiaries who were 
prescribed medications for opioid use disorder through opioid treatment programs or 
in a providers office. 
Analysis of Trends in Part D for Naloxone 
Next, we identified all PDE records for naloxonea drug that reverses opioid 
overdoses.  We calculated the total number of beneficiaries who received naloxone 
and the number of prescriptions for naloxone from 2010 to 2021. 
Limitations 
This analysis is based on Medicare claims data.  It is not based on a review of medical 
records.  The analysis does not include data on opioids, medications to treat opioid 
use disorders, or naloxone that beneficiaries may have received from sources other 
than Medicare. 
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. 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Methodology | 15   
APPENDIX A 
 
State Data 
Exhibit A: Alabama had the highest proportion of beneficiaries receiving opioids 
through Medicare Part D, while New York and Hawaii had the lowest proportion. 
Proportion of Beneficiaries in Each State and Nationwide Who 
Received Opioids Through Medicare Part D in 2021 
 
Alabama  36%  Iowa  23% 
 
Arkansas  33%  Ohio  23% 
 
Louisiana  32%  Arizona  23% 
 
Mississippi  32%  Virginia  22% 
 
Oklahoma  30%  Alaska  22% 
 
Kentucky  30%  Illinois  22% 
 
Georgia  30%  Nevada  22% 
 
Tennessee  29%  Wisconsin  22% 
 
Missouri  28%  South Dakota  22% 
 
South Carolina  28%  North Dakota  22% 
 
Kansas  28%  Maryland  21% 
 
Indiana  27%  New Mexico  21% 
 
Utah  27%  Delaware  20% 
 
North Carolina  27%  California  20% 
 
Idaho  26%  Minnesota  20% 
 
Texas  25%  Pennsylvania  20% 
 
West Virginia  25%  Connecticut  18% 
 
Oregon  25%  District of Columbia  18% 
 
Montana  24%  Maine  18% 
 
Wyoming  24%  Massachusetts  18% 
 
Michigan  24%  New Jersey  18% 
 
Colorado  24%  New Hampshire  17% 
 
Washington  24%  Rhode Island  17% 
 
Nebraska  24%  Vermont  16% 
 
Nation  23%  Hawaii  15% 
Florida  23%     New York  15% 
Source: OIG analysis of Medicare Part D data, 2022.   
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Appendix A | 16   
APPENDIX B 
 
Beneficiaries Receiving Opioids Through Part D 
Exhibit B-1: About 200,000 beneficiaries received high amounts of opioids through 
Part D in 2021. 
Number of Beneficiaries Who Received  Percentage Change from 
   High Amounts of Opioids  Previous Year 
2016  501,008  - 
2017  458,935  -8% 
2018  353,751  -23% 
2019  266,728  -25% 
2020  225,463  -15% 
2021  199,169  -12% 
Source: OIG analysis of Medicare Part D data, 2022. 
 
Exhibit B-2: About 23,000 beneficiaries were at serious risk in 2021. 
Number of  
Beneficiaries  
Who   Percentage   Number of   Percentage   Total   Percentage  
Received   Change   Beneficiaries   Change   Number of   Change 
Extreme   from   Who   from   Beneficiaries   from  
Amounts of   Previous   Appear To Be   Previous   at   Previous  
   Opioids  Year  Doctor Shopping  Year  Serious Risk*  Year 
2016  69,563  -  22,308  -  89,843  - 
2017  57,611  -17%  14,814  -34%  71,260  -21% 
2018  40,374  -30%  8,796  -41%  48,558  -32% 
2019  29,734  -26%  4,346  -51%  33,809  -30% 
2020  27,352  -8%  2,131  -51%  29,306  -13% 
2021  21,493  -21%  1,805  -15%  23,186  -21% 
 
* Numbers in the total column do not equal the sums of the numbers in the corresponding extreme amount and doctor shopping 
columns because beneficiaries can be in both groups. 
Source: OIG analysis of Medicare Part D data, 2022.  
 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Appendix B | 17   
APPENDIX C 
 
Prescribers With Questionable Opioid Prescribing for 
Beneficiaries at Serious Risk 
Exhibit C: About 100 prescribers ordered opioids for a high number of beneficiaries at 
serious risk in 2021. 
Number of Prescribers With   Percentage 
Questionable Opioid Prescribing for   Change from 
   Beneficiaries at Serious Risk  Previous Year 
2016  401  - 
2017  282  -30% 
2018  198  -30% 
2019  142  -28% 
2020  98  -31% 
2021  98  0% 
 
For more information, see these previous OIG data briefs: Opioids in Medicare Part D: 
Concerns About Extreme Use and Questionable Prescribing (OEI-02-17-00250), July 2017; 
Opioid Use in Medicare Part D Remains Concerning (OEI-02-18-00220), June 2018; Opioid Use 
Decreased in Medicare Part D, While Medication-Assisted Treatment Increased  
(OEI-02-19-00390), July 2019; Opioid Use in Medicare Part D Continued To Decline in 2019, 
but Vigilance Is Needed as COVID-19 Raises New Concerns (OEI-02-20-00320), August 2020; 
and Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment 
and Overdose-Reversal Drugs (OEI-02-20-00401), August 2021. 
Source: OIG analysis of Medicare Part D data, 2017-2022. 
 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Appendix C | 18   
ACKNOWLEDGMENTS AND CONTACT 
 
Acknowledgments 
Jason Kwong and Margaret Himmelright served as the team leaders for this study.  
Others in the Office of Evaluation and Inspections who conducted the study include 
Miriam Anderson.  Office of Evaluation and Inspections staff who provided support 
include Althea Hosein and Michael Novello.  
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 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Acknowledgments and Contact | 19   
EE  NNDDNNOOTTEESS  
 
 
 
1 CDC, Provisional Drug Overdose Death Counts, June 9, 2022.  Accessed at https://www.cdc.gov/nchs/nvss/vsrr/drug-
overdose-data.htm on July 13, 2022. 
2 This builds off of a recently released OIG report on Medicare beneficiaries who received medication to treat their opioid use 
disorder and other related services.  See OIG, Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid 
Use Disorder, OEI-02-20-00390, December 2021; OIG, Concerns Persist About Opioid Overdoses and Medicare Beneficiaries 
Access to Treatment and Overdose-Reversal Drugs, OEI-02-20-00401, August 2021; OIG, Opioid Use in Medicare Part D During 
the Onset of the COVID-19 Pandemic, OEI-02-20-00400, February 2021; OIG, Opioid Use in Medicare Part D Continued To 
Decline in 2019, but Vigilance Is Needed as COVID-19 Raises New Concerns, OEI-02-20-00320, August 2020; OIG, Opioid Use 
Decreased in Medicare Part D, While Medication-Assisted Treatment Increased, OEI-02-19-00390, July 2019; OIG, Opioid Use in 
Medicare Part D Remains Concerning, OEI-02-18-00220, June 2018; and OIG, Opioids in Medicare Part D: Concerns About 
Extreme Use and Questionable Prescribing, OEI-02-17-00250, July 2017. 
3 This represents the number of Medicare beneficiaries who received medication to treat their opioid use disorder in outpatient 
settings.  See OIG, Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder, OEI-02-20-
00390, December 2021. 
4 OIG, Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder, OEI-02-20-00390, 
December 2021. 
5 We considered a beneficiary to have had an overdose if the beneficiary had at least one claim from Medicare Part A, B, or C 
with a diagnosis of an opioid poisoning from prescription or illicit opioids. 
6 In 2019, 26 percent of beneficiaries received an opioid through Part D; a decrease from 2018, when 29 percent did; a decrease 
from 2017, when 31 percent did; and a decrease from 2016, when 33 percent did. 
7 This represents the total number of opioid prescriptions paid for under Part D, including those in the deductible stage of the 
benefit when some beneficiaries pay the full cost.  For the purposes of this study, we use the term prescription to mean one 
PDE record. 
8 In 2019, 2018, 2017, and 2016, Part D paid for 66.5 million, 71 million, 76 million, and 79 million opioid prescriptions, 
respectively. 
9 We excluded beneficiaries with cancer and those in hospice care to align with the criteria that CMS used in 2016 and 2017 for 
its Overutilization Monitoring System.  The criteria for the Overutilization Monitoring System changed in 2018.  See CMS, 
Announcement of Calendar Year (CY) 2018 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment 
Policies and Final Call Letter and Request for Information, April 3, 2017.  Accessed at https://www.cms.gov/Medicare/Health-
Plans/MedicareAdvtgSpecRateStats/Downloads/Announcement2018.pdf on June 16, 2022. 
10 In addition to the risk of dependence and overdose, opioids carry other health risks, including respiratory depression, 
constipation, drowsiness, and confusion.  Older adults may also be at an increased risk of injury, as research has shown that the 
risk of fracture may increase as drug dosage increases.  See Diane L. Chau, Vanessa Walker, Latha Pai, et al., Opiates and 
Elderly: Use and Side Effects, Clinical Interventions in Aging, Vol. 3, No. 2, June 6, 2008, p. 276.  CDC, CDC Guideline for 
Prescribing Opioids for Chronic PainUnited States, 2016, MMWR [Morbidity and Mortality Weekly Report] Recommendations 
and Reports, Vol. 65, No. 1, March 18, 2016, pp. 149.  Accessed at 
https://www.cdc.gov/mmwr/volumes/65/rr/pdfs/rr6501e1.pdf on June 9, 2022.  Kathleen W. Saunders, Kate M. Dunn, Joseph O. 
Merrill, et al., Relationship of Opioid Use and Dosage Levels to Fractures in Older Chronic Pain Patients, Journal of General 
Internal Medicine, Vol. 25, No. 4, January 19, 2010, pp. 310315. 
 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Endnotes | 20   
11 CDC, CDC Guideline for Prescribing Opioids for Chronic PainUnited States, 2016.  (See preceding endnote for full MMWR 
citation and link.)  CDC has recently sought public comment on a draft of an updated opioid prescribing guideline.  A notable 
change in the proposed guideline is that the CDC does not include specific opioid levels in its main recommendations for 
prescribing opioids to patients.  See CDC, CDC Clinical Practice Guideline for Prescribing OpioidsUnited States, 2022 [Draft].  
Accessed at https://www.regulations.gov/document/CDC-2022-0024-0002 on June 2, 2022. 
12 This group of beneficiaries is a subset of the 199,169 beneficiaries who received high amounts of opioids. 
13 Between 2016 and 2020, the number of beneficiaries OIG identified as at serious risk of opioid misuse or overdose decreased 
between 13 percent and 32 percent annually. 
14 A total of 4,503 of the beneficiaries identified as being at serious risk in 2021 were also identified as such in 2016, 2017, 
2018, 2019, and 2020.  Together, these beneficiaries represent 15 percent of the 23,186 beneficiaries identified as being at 
serious risk in 2021. 
15 CDC recommends that clinicians evaluate benefits and harms with patients within 1 to 4 weeks of starting opioid therapy for 
chronic pain or of dose escalation.  CDC also recommends that clinicians evaluate benefits and harms of continued therapy 
with patients every 3 months or more frequently.  If benefits do not outweigh harms of continued opioid therapy, clinicians 
should optimize other therapies and work with patients to taper opioids to lower dosages or to taper and discontinue opioids.  
CDC, CDC Guideline for Prescribing Opioids for Chronic PainUnited States, 2016.   
16 Missouris Governor signed into law legislation for a Statewide prescription drug monitoring program on June 8, 2021.  See 
Missouri Senate Bill 63 (2021).  Accessed at 
https://www.senate.mo.gov/21info/BTS_Web/Bill.aspx?SessionType=R&BillID=54228843 on July 18, 2022.  A statewide 
prescription drug monitoring program is still under development. 
17 State requirements for checking this information vary.  For more information about prescription drug monitoring programs, 
see the website of the Prescription Drug Monitoring Program Training and Technical Assistance Center, Brandeis University, at 
http://www.pdmpassist.org/. 
18 Each of these 1.1 million Medicare beneficiaries had a diagnosis of opioid use disorder on at least 1 Medicare claim in 2021 
or received at least 1 service from an opioid treatment program in 2021.  We refer to these beneficiaries as beneficiaries with 
opioid use disorder throughout the report. 
19 Diagnostic and Statistical Manual of Mental Disorders: DSM-5.  Arlington, VA: American Psychiatric Publishing, 2013.   
20 42 C.F.R.  8.2. 
21 For more information about assessing a patient for opioid use disorder, see CDC training document Module 5: Assessing and 
Addressing Opioid Use Disorder.  Accessed at https://www.cdc.gov/drugoverdose/training/oud/ on June 7, 2022. 
22 Diagnostic and Statistical Manual of Mental Disorders: DSM-5, 2013. 
23 FDA, Information about Medication-Assisted Treatment (MAT), February 14, 2019.  Accessed at 
https://www.fda.gov/drugs/information-drug-class/information-about-medication-assisted-treatment-mat on May 26, 2022.  
24 21 U.S.C.  823(g).  Also see 42 C.F.R.  8.11 &  8.12(h). 
25 CMS, Medicare Prescription Drug Benefit Manual, Ch. 6, Sec. 10.8.  Accessed at https://www.cms.gov/Medicare/Prescription-
Drug-Coverage/PrescriptionDrugCovContra/Downloads/Part-D-Benefits-Manual-Chapter-6.pdf on August 9, 2022.  
Methadone is also indicated for pain.  When prescribed for pain, it can be prescribed in outpatient settings.  
26 These waivers allowed certain practitioners to treat up to 100 patients with buprenorphine in the first year, although most 
qualified practitioners were limited to treating up to 30 patients in the first year.  See 21 U.S.C.  823(g)(2)(b)(III)(i). In 
subsequent years, a practitioner can treat up to 275 patients.  See 42 CFR  8.610.  However, since April 2021, providers who 
plan to treat up to 30 patients have been exempt from some of the waiver requirements related to training, counseling, and 
 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Endnotes | 21   
other services.  See 86 F.R. 22439.  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. 
27 OIG, Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder, OEI-02-20-00390, 
December 2021. 
28 A total of 2,089 beneficiaries who received medication to treat their opioid use disorder in office-based settings had 
medications covered both by Medicare Part D and by Medicare Part B or C. 
29 A total of 1,466 beneficiaries received both buprenorphine and naltrexone in office-based settings in 2021. 
30 A total of 3,949 beneficiaries received medication to treat their opioid use disorder from both office-based settings and 
opioid treatment programs in 2021. 
31 Beneficiaries enrolled in Medicare Advantage plans may have had opioid treatment program services covered prior to 2020 
as a supplemental benefit.  CMS, Announcement of Calendar Year (CY) 2017 Medicare Advantage Capitation Rates and Medicare 
Advantage and Part D Payment Policies and Final Call Letter, April 4, 2016.  Accessed at https://www.cms.gov/medicare/health-
plans/medicareadvtgspecratestats/downloads/announcement2017.pdf on August 24, 2022.  Beginning in 2020, opioid 
treatment programs became a recognized Medicare provider type.  They are paid through weekly bundled payments under 
Part B.  See 42 CFR  410.67.  
32 42 C.F.R.  8.12(f). 
33 National Institute on Drug Abuse, Naloxone for Opioid Overdose: Life-Saving Science, June 2021.  Accessed at 
https://nida.nih.gov/publications/naloxone-opioid-overdose-life-saving-science on August 10, 2022. 
34 Notably, most States allow for third-party prescriptions, which means that family members or friends of an at-risk patient can 
get a prescription for naloxone in their own name.  In addition, a number of recent initiatives have increased community-based 
distribution of naloxone.  Also, beneficiaries who did not receive naloxone through Part D in 2021 may still have naloxone that 
they received through Part D from a prior year. 
35 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 May 25, 2022.  
36 OIG also recommended that CMS take steps to increase the utilization of behavioral therapy among beneficiaries receiving 
medication to treat opioid use disorder and collect data on the use of telehealth in opioid treatment programs.  See OIG, Many 
Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder, OEI-02-20-00390, December 2021. 
37 CMS, CMS Behavioral Health Strategy.  Accessed at https://www.cms.gov/cms-behavioral-health-strategy on July 1, 2022.  
38 CMS, Value in Opioid Use Disorder Treatment Demonstration Program.  Accessed at https://innovation.cms.gov/innovation-
models/value-in-treatment-demonstration on July 12, 2022.  
39 An example of a recent step CMS has taken to increase access to naloxone is that, beginning in 2022, opioid treatment 
programs can receive reimbursement under Part B for take-home supplies of nasal naloxone distributed to beneficiaries whom 
they are treating.  See CMS, Opioid Treatment Programs (OTPs) Medicare Billing & Payment, November 2021.  Accessed at 
https://www.cms.gov/files/document/otp-billing-and-payment-fact-sheet.pdf on August 10, 2022.  
40 OIG, Many Medicare Beneficiaries Are Not Receiving Medication to Treat Their Opioid Use Disorder, OEI-02-20-00390, 
December 2021; and OIG, SAMHSA Is Missing Opportunities To Better Monitor Access to Medication Assisted Treatment Through 
the Buprenorphine Waiver Program, OEI-BL-20-00260, June 2021. 
41 MED and MME are interchangeable terms. 
42 For more information on calculating opioid dosage, see CDC, Calculating Total Daily Dose of Opioids for Safer Dosage.  
Accessed at https://www.cdc.gov/drugoverdose/pdf/calculating_total_daily_dose-a.pdf on June 16, 2022. 
 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Endnotes | 22   
43 We included opioids dispensed in 2020 with days of use in 2021.  This analysis excludes PDE records for injection, 
intravenous, and intrathecal opioids, as well as opioids indicated for medication-assisted treatment. 
44 We identified beneficiaries with a cancer diagnosis or hospice stay by using CMSs National Claims History File and Part C 
Encounter data.  In total, we identified 2,898,737 beneficiaries with cancer or in hospice care who received at least 1 opioid. 
45 We selected these criteria because they closely align with the criteria that CMS used in 2016 and 2017 for its Overutilization 
Monitoring System.  Through 2017, CMSs Overutilization Monitoring System identified beneficiaries who had a daily MED of 
120 mg for 90 days plus four or more prescribers and four or more pharmacies.  Note that the guidance uses the term more 
than 3 prescribers and more than 3 pharmacies, which is the equivalent of 4 or more prescribers and 4 or more pharmacies.  
The criteria for the Overutilization Monitoring System changed in 2018.  See CMS, Announcement of Calendar Year (CY) 2018 
Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies and Final Call Letter and Request for 
Information, April 3, 2017.  Accessed at https://www.cms.gov/Medicare/Health-
Plans/MedicareAdvtgSpecRateStats/Downloads/Announcement2018.pdf on June 16, 2022. 
46 For our analysis, we counted prescribers in group practices separately. 
Opioid Overdoses and the Limited Treatment of Opioid Use Disorder Continue To Be Concerns for Medicare Beneficiaries 
OEI-02-22-00390  Endnotes | 23