U.S. Department of Health and Human Services 
O  ffice of Inspector General 
 
Data Brief 
 
Au gust 2021, OEI-02-20-00401 
 
 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access 
to Treatment and Overdose-Reversal Drugs 
Why OIG Did This Review 
Key Takeaways 
The coronavirus disease 2019 (COVID-19) pandemic and its effects on the 
o More than 43,000 Medicare  provision of health care have heightened concerns about opioid use and 
Part D beneficiaries suffered an 
access to treatment.  The pandemic has put people with opioid use 
opioid overdose in 2020. 
disorder at particular risk, as they are at higher risk of developing COVID-
o Nearly 1 in 4 Part D beneficiaries  19 and are more likely to experience hospitalizations or death from the 
received opioids during the year.   illness.1 These increased risks posed by COVID-19 make urgent the need 
o Growth slowed in the number of  to monitor opioid use as well as access to treatment and to the opioid 
beneficiaries receiving drugs  overdose-reversal drug naloxone. 
through Part D to treat opioid 
The Office of Inspector General (OIG) has been tracking opioid use and 
use disorder. 
access to treatment and naloxone in Part D for the past several years.2  
o Growth stopped in the number  Before 2020 and the COVID-19 pandemic, there were consistent 
of beneficiaries receiving 
decreases in opioid use in Part D.  There was also growth in the use of 
prescriptions for overdose-
medications to treat opioid use disorderreferred to as medication-
reversal drugs through Part D. 
assisted treatment (MAT) drugsand naloxone.  This data brief provides 
o Ensuring access to treatment  important information on opioid use, MAT drugs, and naloxone in 
and to overdose-reversal drugs  Medicare Part D in 2020.  It builds on a previously released OIG data 
in 2021 and beyond is  snapshot about opioid use during the onset of the pandemic.3   
particularly important as we do 
not yet know the full extent to  What OIG Found 
which the stressors of the  More than 43,000 Part D beneficiaries suffered an opioid overdosefrom 
COVID-19 pandemic may have  prescription opioids, illicit opioids, or bothduring 2020.  This number 
increased the need for these  may be higher, as additional beneficiaries could have overdosed but not 
drugs.  received medical care that was billed to Medicare.  Overall, nearly 1 in 4 
Medicare Part D beneficiaries received opioids in 2020.  The number of 
beneficiaries receiving short-term opioid prescriptions dropped sharply in the early months of the pandemic, likely 
the result of a decrease in elective surgeries at that time.  The number of beneficiaries who received MAT drugs 
through Part D increased, but at a slower rate in 2020 than in prior years.  And, unlike in other recent years, there 
was no growth in 2020 in the number of beneficiaries receiving prescriptions for naloxone through Part D.  These 
changes are likely related to COVID-19, as patients may have avoided seeing their health care providers during the 
pandemic, reducing the opportunity for providers to offer treatment.  These slower growth rates add to ongoing 
concerns about access to MAT drugs and naloxone. 
What OIG Concludes 
Monitoring opioid use and access to MAT drugs and naloxone has always been critical to fighting the opioid crisis 
in this country.  The COVID-19 pandemic has made these efforts even more pressing.  A May 2020 OIG data brief 
recommended that the Centers for Medicare & Medicaid Services (CMS) educate Part D beneficiaries and 
providers about access to MAT drugs and naloxone.  We continue to encourage CMS to take these steps.  It is also 
critical for CMS to closely monitor the number of beneficiaries receiving MAT drugs and naloxone and take action, 
if needed.  OIG is also committed to continuing our work on opioid use and access to treatment.    
RESULTS 
 
 
More than 43,000 Part D beneficiaries suffered an opioid 
overdose during 2020 
In 2020, at least 43,762 Part D beneficiaries suffered 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.4  The overdoses were 
linked to prescription opioids, illicit opioids, or both.   
The total number of beneficiaries who suffered an opioid overdose may be higher, as 
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 at 
home during the year would not be counted if there was no medical care billed to 
Medicare.  
In every month in 2020, the average number of beneficiaries who received medical 
care for an opioid overdose topped 4,000 per month. The number peaked in the 
summer of 2020 and then fell later in the year.  As Exhibit 1 shows, in June and July, 
more than 5,500 beneficiaries received care for an overdose; while around 4,300 
beneficiaries did so in November and December.  
Exhibit 1: The number of beneficiaries receiving medical care for an  
opioid overdose peaked in the summer of 2020.  
5,555 5,565
5,263 5,306
5,048 5,013
4,770 4,797
4,622
4,193 4,274 4,285
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
 
   Source: OIG analysis of Medicare Part D data, 2021. 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401    Results | 1  Nearly 1 in 4 Medicare Part D beneficiaries received opioids in 
2020 
In 2020, nearly 1 in 4 beneficiaries received at least one prescription opioid through 
Medicare Part D.  Twenty-four percent of beneficiariesalmost 12 million of the total 
of 50 million beneficiaries enrolled in Medicare Part Dreceived opioids.  This is an 
overall decrease from 2019, when 26 percent of beneficiaries received opioids 
through Part D.  It is also a decrease from previous years.  From 2016 to 2018, the 
proportion of beneficiaries receiving opioids declined from 33 percent to 29 percent.5 
(See Appendix A for information about opioid use in each State.) 
Some of the decline in 2020 can be attributed to the sharp decline in the number of 
beneficiaries receiving short-term opioid prescriptionsi.e., prescriptions for 7 days 
or lessin the early months of the pandemic, particularly in April of 2020.  Short-term 
prescriptions are commonly prescribed for acute pain caused by injury or surgery.  
Declines in these prescriptions were likely due to elective surgeries being postponed 
during the early months of the pandemic. 6  (See Appendix A for more information 
about monthly opioid use in 2020.) 
Part D paid for 63.4 million opioid prescriptions, an average of 5.4 prescriptions per 
beneficiary receiving opioids in 2020.7  This total number is a decrease from 2019, 
when Medicare paid for 66.5 million prescriptions.  It is also a decline from previous 
years.  From 2016 to 2018, the number of opioid prescriptions exceeded 70 million 
annually.8 
Similarly, overall Part D spending for opioids also went down.  Part D paid $2.7 billion 
for opioids in 2020, compared to $2.8 billion in 2019. 
Growth in the number of beneficiaries receiving drugs for 
medication-assisted treatment has slowed 
Beneficiaries use of drugs for medication-assisted treatment (MAT) in Part D 
increased in 2020, but at a slower rate than in recent years. These drugs help treat 
opioid use disorder, a problematic pattern of opioid use that leads to clinically 
significant impairment or distress.9  Opioid use disorder is linked to the misuse of 
prescription opioids, illicit opioids, or both. 
Ensuring access to MAT drugs is essential to fighting the opioid crisis, as they treat 
the patients underlying disorder and have been shown to decrease illicit opioid use 
and opioid-related overdose deaths.10  Part D covers two drugs indicated for the 
treatment of opioid use disorder: buprenorphine and naltrexone.11  
In 2020, the number of Medicare beneficiaries receiving MAT drugs through Part D 
reached 225,546, an increase of 8 percent from 2019. As Exhibit 2 shows, the growth 
in the number of beneficiaries receiving MAT drugs slowed in 2020, compared to 
2018 and 2019, when the growth rate topped 20 percent each year. 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Results | 2  Exhibit 2: Although the number of beneficiaries receiving MAT drugs 
through Part D increased in 2020, the rate of increase has slowed. 
30%
25%
25%
20% 20%
19%
20%
15%
16%
13%
10%
The number of beneficiaries receiving MAT drugs  8%
5%
grew 8% in 2020, down from 20% growth in 2019. 
0%
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
 
  Source: OIG analysis of Medicare Part D data, 2021. 
Growth in the number of Part D prescriptions for MAT drugs also slowed.  From 2019 
to 2020, this number rose from 1.9 million to 2.1 million, an increase of 11 percenta 
lower percentage increase than in recent years.  From 2018 to 2019, it grew 
21 percent and from 2017 to 2018 it grew 24 percent.   
The slower growth in the number of beneficiaries receiving MAT drugs may have been 
related to the COVID-19 pandemic.  For example, patients may have delayed or 
avoided seeing their health care providers during the pandemic, reducing the 
opportunity for providers to offer treatment.  The Centers for Disease Control and 
Prevention (CDC) estimates that 4 in 10 adults in the United States delayed or avoided 
medical care because of concerns related to COVID-19.12 
Nevertheless, this slower growth rate adds to OIGs ongoing concerns about access to 
MAT drugs.  A previous OIG report found that a limited number of beneficiaries with 
opioid use disorder receive MAT drugs through Part D.  Specifically, in 2019, about 
960,000 Medicare Part D beneficiaries had a diagnosis of opioid use disorder, yet just 
13 percent of these beneficiaries received MAT drugs through Part D.13  This may have 
resulted in part from beneficiaries having challenges in accessing providers who can 
prescribe buprenorphineonly certain health care practitioners who have waivers 
from the Substance Abuse and Mental Health Services Administration (SAMHSA) may 
prescribe buprenorphine for MAT.14  A second recent OIG report found that 
40 percent of U.S. counties did not have providers with a waiver.15  See Appendix C 
for more information on the use of MAT drugs in Part D. 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401    Results | 3  The number of beneficiaries receiving prescriptions for 
overdose-reversal drugs through Part D did not grow 
The number of beneficiaries receiving naloxone prescriptions through Part D did not 
grow in 2020, in contrast with trends in recent years.16  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.   
A total of 377,457 beneficiaries received a naloxone prescription in 2020 paid for by 
Part D, very close to the number378,829who received a prescription in 2019.17  As 
Exhibit 3 shows, 2020 marks the first time in recent years that the number of 
beneficiaries receiving prescriptions for naloxone did not grow.  For comparison, this 
number grew 70 percent from 2018 to 2019.18   
Exhibit 3: The number of beneficiaries receiving prescriptions for naloxone
a drug that can reverse an opioid overdosedid not grow in 2020. 
378,829  377,457
222,809 
89,876
37,039
7,201  9,401  6,870  5,346  5,889  11,548 
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
 
  Source:  OIG analysis of Medicare Part D data, 2021. 
The total number of Part D prescriptions for naloxone also stayed relatively constant.  
In 2020, Medicare Part D paid for 423,135 naloxone prescriptions, a 2-percent 
increase from 2019.  (See Appendix C for more information on the use of naloxone in 
Part D.)  Again, patients may have delayed or avoided seeing their health care 
providers during the pandemic, reducing the opportunity for providers to offer 
treatment.  Some beneficiaries may have received naloxone from sources other than 
Part D.19 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401    Results | 4  The lack of growth in the number of beneficiaries receiving naloxone raises concern, 
as opioid overdoses among Part D beneficiaries persist. 
About 225,000 Part D beneficiaries received high amounts of 
opioids in 2020 
In 2020, a total of 225,463 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. 
The number of beneficiaries receiving high amounts of opioids is a decrease from 
2019, when 266,728 beneficiaries received high amounts.  It is also a decline from 
previous years.  (See Appendix D 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.20  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.21  For 
patients who are already taking high dosages of opioids, prescribers should offer 
them the opportunity to re-evaluate their continued use of these dosages, and 
prescribers should offer to work with them to taper their opioids to safer dosages.22   
About 29,000 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. 
A total of 29,306 beneficiaries were in these subgroups.23  (This does not include 
beneficiaries who have cancer or were in hospice care.)  Specifically, 
27,325 beneficiaries received extreme amounts of opioids (i.e., had an average daily 
MED greater than 240 mg for 12 months) and 2,131 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 150 beneficiaries were in both groups. 
The number of beneficiaries at serious risk in 2020 (29,306 beneficiaries) declined 
13 percent from 2019, when OIG identified 33,809 beneficiaries.24  Of note, the larger 
drop occurred in the number of beneficiaries who appeared to be doctor shopping.  
In 2020, there were about half as many beneficiaries who appeared to be doctor 
shopping than in 2019. 25  (See Appendix D for more detailed information.)  Despite 
the decreases, tens of thousands of beneficiaries are still at serious risk. 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401    Results | 5  Receiving extreme amounts of opioids or high amounts of opioids from multiple 
prescribers and 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.26  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.27  Prescribers can check these databases before ordering opioids to 
determine whether a beneficiary is already receiving opioids ordered by other 
prescribers.28 
Raising particular concern, a total of 296 beneficiaries had an average daily MED of 
more than 1,000 mg a day for the entire year.  (See the text box for an example.) 
Example of a Beneficiary at Serious Risk of Misuse or Overdose 
One beneficiary had an average daily MED of 1,565 mg for the entire year.  
This beneficiary received 56 opioid prescriptions in 2020.  On 2 consecutive 
days in January, she received six opioid prescriptions, including two strengths 
of oxycodone; methadone; morphine; tapentadol; and fentanyl patches.  
Together, Part D paid $9,577 for these six prescriptionsall ordered by the 
same prescriber and dispensed by the same pharmacy. 
About 100 prescribers had questionable opioid prescribing for 
beneficiaries at serious risk  
About 30,000 prescribers ordered opioids for at least 1 beneficiary at serious risk of 
misuse or overdose (i.e., beneficiaries who received extreme amounts of opioids or 
appeared to be doctor shopping in 2020.)29  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, 
70 prescribers each ordered opioids for at least 32 beneficiaries who received extreme 
amounts of opioids in 2020.  Further, 32 prescribers each ordered opioids for at least 
7 beneficiaries who appeared to be doctor shopping.  Four prescribers ordered 
opioids for high numbers of beneficiaries in both groups at serious risk. 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401    Results | 6  The number of prescribers with questionable prescribing for beneficiaries at serious 
risk was a decrease of 31 percent from 2019, when there were 142 prescribers with 
questionable prescribing.  This decline is similar to declines in previous years.  Each 
year between 2016 and 2018, the number of prescribers with questionable opioid 
prescribing declined about 30 percent.  (See Appendix E 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 67,956 opioid prescriptionstotaling 
$18.8 million of Part D costsfor beneficiaries at serious risk in 2020. 
Example of a Prescriber Who Ordered Opioids for Large Numbers of 
Beneficiaries At Serious Risk 
A nurse practitioner ordered 511 opioid prescriptions for 105 beneficiaries 
who received extreme amounts of opioids and 11 who appeared to be doctor 
shopping.  Six of these beneficiaries had average daily MEDs that exceeded 
500 mg for the entire year. 
 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401    Results | 7   
CONCLUSION 
 
 
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.  The 
COVID-19 pandemic has made these efforts even more pressing.  The pandemic has 
heightened the risk for people with opioid use disorder, as they are at higher risk of 
developing COVID-19 and are more likely to experience hospitalization or death from 
the illness.  
At least 43,000 Part D beneficiaries suffered an opioid overdose during 2020.  In 
addition, nearly 1 in 4 beneficiaries received opioids through Part D in 2020.  This is 
an overall decrease from previous years.  It is important to note that the number of 
beneficiaries receiving short-term opioid prescriptions dropped sharply in the early 
months of the COVID-19 pandemic, likely due to elective surgeries being postponed.   
Growth in beneficiaries use of MAT drugs has slowed in 2020, and growth has 
stopped in the number of beneficiaries receiving prescriptions for the overdose-
reversal drug naloxone through Part D.  These changes add to ongoing concerns 
about access to MAT drugs and naloxone.  MAT drugs treat the patients underlying 
disorder and have been shown to decrease illicit opioid use and opioid-related 
overdose deaths.  Naloxonea drug that can reverse the effects of an opioid 
overdosecan save lives if it is on hand. 
A recent OIG data brief recommended that CMS educate Part D beneficiaries and 
providers about access to MAT drugs and naloxone.30  We continue to encourage 
CMS to take these steps.  It is also critical for CMS to closely monitor access to both 
MAT drugs and naloxone and to take appropriate action if the numbers of 
beneficiaries receiving these drugs begin to fall off.  Ensuring access to MAT drugs 
and naloxone in 2021 and beyond is particularly important as we do not yet know the 
full extent to which the stressors of the COVID-19 pandemic may have increased the 
need for these drugs.31  
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.32   
 
 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Conclusion | 8   
METHODOLOGY 
 
 
We based this data brief on an analysis of prescription drug event (PDE) records for 
Part D drugs.  These 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, CDCs Morphine Milligram Equivalent (MME) conversion 
file, and the National Plan and Provider Enumeration System (NPPES).  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.  Part C Encounter 
Data contain medical claims data, including diagnosis codes, for beneficiaries enrolled 
in Medicare Advantage plans.  CDCs MME conversion file contains information about 
each opioid drugs morphine milligram equivalence.33  The NPPES contains 
information about prescribers, such as their name, address, and taxonomy (i.e., 
specialty).  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 2020, 
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 Parts 
A, B, or C with a diagnosis of an opioid poisoning from prescription or illicit opioids 
between January 1, 2020, and December 31, 2020. 
Analysis of Part D Utilization of Opioids, MAT Drugs, and 
Naloxone 
We identified all PDE records for opioids that beneficiaries received in 2020.34  We 
calculated the total number of Part D beneficiaries who received opioids in 2020.  We 
then calculated the total number of opioid prescriptions paid for by Part D in 2020 
and the average number of opioid prescriptions per beneficiary.  We compared the 
2020 data to the data from 2016, 2017, 2018 and 2019 in our previous data briefs, 
which used the same methodology.  Next, we calculated total Part D spending for 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Methodology | 9  opioids from 2010 to 2020.  To do this, we summed four fields on the PDE records 
that represent the total gross drug costs:  ingredient cost, dispensing fee, vaccine 
administration fee, and sales tax. 
Next, we calculated the proportion of beneficiaries who received opioids in the Nation 
and in each State in 2020.  We based this analysis on the PDE records and Medicare 
enrollment data.   
We then identified all PDE records for (1) MAT drugs indicated for the treatment of 
opioid use disorder and (2) naloxone (the opioid overdose-reversal drug).  We first 
calculated the total number of beneficiaries who received MAT drugs and the number 
of prescriptions for these drugs from 2010 through 2020.35  Next, we calculated the 
total number of beneficiaries who received naloxone and the number of prescriptions 
for naloxone from 2010 through 2020.36 
Beneficiary Analysis  
We determined the amount of opioids that each beneficiary received in 2020.  To do 
this, we calculated each beneficiarys average daily morphine equivalent dose (MED).37  
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).38  To do this, we used the following 
equation: 
 
(SSSSSSSSSSSSSSh ppSSSS uuSSuuSS)(QQuuQQSSSSuuSSQQ dduuddppSSSSddSSdd)(MMMMMM ccccSSccSSSSdduuccSS ffQQccSSccSS)
MMMMMM = 
Next, we summed each beneficiarys ME(DMMQQ 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 2020.39 
We analyzed the MED data using the same criteria that we used in our previous 
analysis of the 2016, 2017, 2018 and 2019 data.40  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 2020.  We 
determined that a beneficiary received high amounts of opioids if he or she 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 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Methodology | 10  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 2020.  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 that we had previously identified in our analyses of the 2016, 2017, 2018 
and 2019 data.  
Prescriber Analysis 
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 National Provider Identifiers (NPIs) on the PDE records to identify 
prescribers.  We considered each NPI to be a unique prescriber.41 
In total, 22,910 prescribers ordered opioids for beneficiaries who received extreme 
amounts of opioids and 10,080 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.  Each of these prescribers is an extreme outlier in terms of 
the number of beneficiaries to whom he or she 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. 
Limitations 
This analysis is based on Part D PDE records; it is not based on a review of medical 
records.  The analysis does not include data on opioids, MAT drugs, or naloxone that 
beneficiaries may have received from sources other than 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. 
 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Methodology | 11   
APPENDIX A 
 
State Data 
Exhibit A-1: Alabama had the highest proportion of beneficiaries receiving opioids 
through Medicare Part D, while Hawaii and New York had the lowest proportion. 
Proportion of Beneficiaries in Each State Who Received Opioids 
Through Medicare Part D in 2020 
Alabama  36%  Arizona  23% 
Arkansas  34%  Virginia  23% 
Louisiana   32%  Nevada  23% 
Mississippi   32%  Iowa  23% 
Oklahoma  31%  Alaska  22% 
Georgia   30%  Illinois   22% 
Tennessee   30%  Wisconsin  22% 
Kentucky  30%  New Mexico  22% 
Missouri  29%  North Dakota  21% 
South Carolina  29%  South Dakota  21% 
Kansas  28%  Maryland  21% 
Indiana  28%  Delaware  20% 
North Carolina  28%  California  20% 
Utah  27%  Pennsylvania  20% 
Texas  27%  Minnesota  19% 
Idaho  27%  District of Columbia  18% 
West Virginia   26%  Maine  18% 
Oregon  25%  Connecticut  18% 
Wyoming  25%  Massachusetts  18% 
Montana  25%  New Jersey  17% 
Michigan   24%  Rhode Island  17% 
Washington  24%  New Hampshire   17% 
Colorado  24%  Vermont  16% 
Nebraska   24%  New York   15% 
Florida  23%  Hawaii  15% 
Ohio  23%     
  Source: OIG analysis of Medicare Part D data, 2021.  
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Appendix A | 12   
APPENDIX B 
Use of Opioids in Part D in 2020 
Exhibit B-1: The number of beneficiaries receiving short-term opioid prescriptions 
dropped sharply in the spring of 2020.* 
1.23
1.16
1.11 1.11 1.12 1.09 1.12
1.05 1.06
1.00
s
n 0.91
o
Milli 0.73
n 
I
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
 
    *Short-term opioid prescriptions are prescriptions for 7 days or less of opioids. 
  Source: OIG analysis of Medicare Part D data, 2021. 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Appendix B | 13   
APPENDIX C 
 
 
 
Use of Medication-Assisted Treatment Drugs and Naloxone in 
Part D 
Exhibit C-1: Both the number of beneficiaries and the number of prescriptions for 
medication-assisted treatment (MAT) drugs for opioid use disorder increased 
between 2016 and 2020, but growth was slower in 2020 than other years. 
  Number of 
 
  beneficiaries who  Percentage  Number of Part D  Percentage 
  received a MAT drug  change from  prescriptions for  change from 
through Part D  previous year  MAT drugs  previous year 
2016  113,967  --   1,030,757  -- 
2017  142,267  25%  1,278,553  24% 
2018  174,150  22%  1,591,706  24% 
2019  209,212  20%  1,927,075  21% 
2020  225,546  8%  2,134,987  11% 
Source: OIG analysis of Medicare Part D data, 2021. 
 
Exhibit C-2: The number of beneficiaries and the number of prescriptions for 
naloxone changed slightly in 2020. 
   
Number of 
  beneficiaries who  Percentage  Number of Part D  Percentage 
received naloxone  change from  prescriptions for  change from 
 
through Part D  previous year  naloxone  previous year 
 
2016  37,039  --  39,902  -- 
 
  2017  89,876  143%  96,300  141% 
 
2018  222,809  148%  239,366  149% 
 
2019  378,829  70%  414,185  73% 
 
  2020  377,457  0%  423,135  2% 
Source: OIG analysis of Medicare Part D data, 2021.
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Appendix C | 14   
 
 
APPENDIX D 
 
Beneficiaries Receiving Opioids Through Part D 
Exhibit D-1: About 225,000 beneficiaries received high amounts of opioids through 
Part D in 2020. 
   
Number of beneficiaries  Percentage 
who received high  change from 
amounts of opioids  previous year   
2016  501,008  --   
2017  458,935  -8%   
2018  353,751  -23%   
2019  266,728  -25% 
 
2020  225,463  -15% 
 
Source: OIG analysis of Medicare Part D data, 2021. 
 
Exhibit D-2: About 29,000 beneficiaries were at serious risk in 2020. 
    Number of  Percentage  Number of  Percentage  Total number of  Percentage 
 
beneficiaries who  change from  beneficiaries who  change from  beneficiaries at  change from 
 
received an extreme  previous  appear to be  previous  serious risk*  previous 
 
  amount of opioids  year  doctor shopping  year  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  27,325  -8%  2,131  -51%  29,306  -13% 
 
 
  *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, 2021. 
 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Appendix D | 15   
 
Appendix E 
 
Prescribers With Questionable Opioid Prescribing for 
Beneficiaries at Serious Risk 
Exhibit E-1: Almost 100 prescribers ordered opioids for a high number of beneficiaries 
at serious risk in 2020. 
  Number of prescribers with questionable   Percentage change  
opioid prescribing for beneficiaries at  from previous year   
serious risk* 
2016  401  -- 
2017  282  -30% 
2018  198  -30% 
2019  142  -28% 
2020  98  -31% 
* 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; and 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. 
Source: OIG analysis of Medicare Part D data, 2017-2021. 
 
 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Appendix E | 16   
 
 
ACKNOWLEDGMENTS AND CONTACT 
 
 
Acknowledgments 
Miriam Anderson served as the team leader for this study.  Other Office of Evaluation 
and Inspections staff from the New York regional office who conducted the study 
include Margaret Himmelright and Jason Kwong.  Office of Evaluation and Inspections 
headquarters staff who provided support include Christine Moritz and 
Kelsey Ridenour.  We would also like to acknowledge the contributions of other Office 
of Inspector General staff, including Lauren McNulty. 
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 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Acknowledgments and Contact | 17  ENDNOTES 
 
 
1 Wang, Q.Q., Kaelber, D.C., Xu, R. et al.  COVID-19 risk and outcomes in patients with substance use disorders: analyses from 
electronic health records in the United States.  Molecular Psychiatry 26, 3039 (2021).  Accessed at 
https://doi.org/10.1038/s41380-020-00880-7 on July 13, 2021.    
2 OIG first began tracking opioid use in Part D in 2014.  In 2016 OIG began to conduct more in-depth reviews that determined 
the number of beneficiaries who were receiving high amounts of opioids, as well as the number of beneficiaries who were at 
serious risk for opioid misuse or overdose and the number of prescribers with questionable opioid prescribing for these 
beneficiaries.  OIG has subsequently released additional data briefs in 2017, 2018, and 2019.  See OIG, Questionable Billing and 
Geographic Hotspots Point to Potential Fraud and Abuse in Medicare Part D, OEI-02-15-00190, June 2015; OIG, High Part D 
Spending on Opioids and Substantial Growth in Compounded Drugs Raise Concerns, OEI-02-16-00290, June 2016; OIG, Opioids 
in Medicare Part D: Concerns About Extreme Use and Questionable Prescribing, OEI-02-17-00250, July 2017; OIG, Opioid Use in 
Medicare Part D Remains Concerning, OEI-02-18-00220, June 2018; OIG, Opioid Use Decreased in Medicare Part D, While 
Medication-Assisted Treatment Increased, OEI-02-19-00390, July 2019; and OIG, Opioid Use in Medicare Part D Continued 
To Decline in 2019, but Vigilance Is Needed as COVID-19 Raises New Concerns, OEI-02-20-00230, August 2020. 
3 OIG, Opioid Use in Medicare Part D During the Onset of the COVID-19 Pandemic, OEI-02-20-00400, February 2021. 
4 We considered a beneficiary to have had an overdose if the beneficiary had at least one claim from Medicare Parts A, B, or C 
with a diagnosis of an opioid poisoning from prescription or illicit opioids. 
5 In 2018, 29 percent of beneficiaries received an opioid through Part D; a decrease from 2017, when 31 percent did; and a 
decrease from 2016, when 33 percent did. 
6 In 2020, 8.3 million beneficiaries received a short-term opioid prescriptioni.e., prescription for 7 days or lesswhich was a 
decline from 2019, when 9.2 million beneficiaries did so.  The number of beneficiaries receiving longer-term prescriptions
prescriptions for more than a week of opioidsalso declined from 6.5 million in 2019 to 6.1 million in 2020. 
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 2018, 2017, and 2016, Part D paid for 71 million, 76 million, and 79 million opioid prescriptions, respectively.   
9 Diagnostic and Statistical Manual of Mental Disorders:  DSM-5.  Arlington, VA: American Psychiatric Publishing, 2013. 
10 SAMHSA, Treatment Improvement Protocol 63: Medications for Opioid Use Disorder (2020).  Accessed at 
https://store.samhsa.gov/sites/default/files/SAMHSA_Digital_Download/PEP20-02-01-006_508.pdf on March 31, 2021.  CMS 
has taken steps to ensure that Part D sponsors provide access to MAT drugs on their formularies.  Formularies are lists of 
covered drugs, which are often divided into tiers with different cost-sharing.  CMS expects that Part D plans place MAT drugs 
on tiers with lower cost-sharing (i.e., generic or preferred brand-name tiers).  For more information, see CMS, Announcement of 
Calendar Year (CY) 2020 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies and Final 
Call Letter, April 1, 2019, p. 204.  
11 Naltrexone is also approved to treat alcohol use disorder.  A third drug, methadone, is covered by Medicare Part B, but not 
by Part D.  In 2020, Medicare Part B began covering drugs for medication-assisted treatment, including methadone, that are 
dispensed by opioid treatment programs.  Drugs covered by Part B are not included in this review. 
 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Endnotes | 18   
12 Czeisler ME, Marynak K, Clarke KE, et al.  Delay or Avoidance of Medical Care Because of COVID-19Related Concerns
United States, June 2020.  MMWR [Morbidity and Mortality Weekly Report] 2020;69:12501257.  Accessed at 
https://www.cdc.gov/mmwr/volumes/69/wr/mm6936a4.htm#suggestedcitation on April 21, 2021.  
13 See OIG, Opioid Use in Medicare Part D Continued To Decline in 2019, but Vigilance Is Needed as COVID-19 Raises New 
Concerns, OEI-02-20-00230, August 2020.  We identified beneficiaries with a diagnosis of opioid use disorder in 2019 using 
CMSs National Claims History File and Part C Encounter data.  A diagnosis of opioid use disorder indicates that an individual 
has a problematic pattern of opioid use that leads to clinically significant impairment or distress.    
14 21 U.S.C.  823(g).  Also see 86 Fed. Reg. 22439 for changes that went into effect in April 2021.  
15 OIG, Geographic Disparities Affect Access to Buprenorphine Services for Opioid Use Disorder, OEI-12-17-00240 (January 2020).  
See also OIG, Medicare Part D Beneficiaries at Serious Risk of Opioid Misuse or Overdose: A Closer Look, OEI-02-19-00130 
(May 2020). 
16 CMS encourages Part D sponsors to include at least one naloxone product on a formulary tier with low or no cost-sharing.  
CMS, Announcement of Calendar Year (CY) 2020 Medicare Advantage Capitation Rates and Medicare Advantage and Part D 
Payment Policies and Final Call Letter, April 1, 2019, p. 203.  
17 The total number of beneficiaries who received naloxone may be underestimated.  This number includes only naloxone 
prescriptions that were paid for by Part D.  Beneficiaries may receive naloxone from sources other than Part D.   
18 See OIG, Opioid Use in Medicare Part D Continued To Decline in 2019, but Vigilance Is Needed as COVID-19 Raises New 
Concerns, OEI-02-20-00230, August 2020. 
19 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. 
20 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 (2008), p. 276.  CDC, CDC Guideline for Prescribing 
Opioids for Chronic Pain: United 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 May 8, 
2020.  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 (2010), pp. 310315. 
21 The CDC Guideline provides recommendations for prescribing opioids for chronic pain outside of cancer treatment, palliative 
care, and end-of-life care.  It recommends that prescribers avoid increasing opioids to morphine equivalent dosages of greater 
than or equal to 90 mg a day or carefully justify the decision to increase to this level.  CDC, CDC Guideline for Prescribing 
Opioids for Chronic Pain: United States, 2016.  (See previous endnote for full MMWR citation and link.) 
22 In September 2019, HHS issued a guide for clinicians on how to appropriately reduce or discontinue long-term use of 
opioids.  The guide provides insights for clinicians on when and how to work with patients to taper opioids.  The guide 
emphasizes that prescribers should decide based on the patients individual circumstances whether tapering is appropriate.  It 
also reiterates that under most circumstances, HHS does not recommend abrupt opioid dose reduction or discontinuation.  
See HHS, HHS Guide for Clinicians on the Appropriate Dosage Reduction or Discontinuation of Long-Term Opioid Analgesics, 
September 2019.  Accessed at https://www.hhs.gov/opioids/sites/default/files/2019-10/8-
Page%20version__HHS%20Guidance%20for%20Dosage%20Reduction%20or%20Discontinuation%20of%20Opioids.pdf on 
March 30, 2021. 
23 This group of beneficiaries is a subset of the 225,463 beneficiaries who received high amounts of opioids. 
24 Between 2016 and 2019, the number of beneficiaries OIG identified as at serious risk of opioid misuse or overdose decreased 
between 21 percent and 32 percent annually.  
 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Endnotes | 19   
25 A total of 6,753 of the beneficiaries identified as being at serious risk in 2020 were also identified as such in 2016, 2017, 
2018, and 2019.  Together, these beneficiaries represents 23 percent of the 29,306 beneficiaries identified as being at serious 
risk in 2020. 
26 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 Pain: United States, 2016.  (See endnote 20 for full MMWR citation 
and link.) 
27 Missouri lacked a Statewide prescription drug monitoring program in 2020; instead, St. Louis County operated a program.  
Missouris Governor signed legislation in June 2021 that will create a Statewide program.  See Missouri Senate Bill 63 (2021).  
Accessed at SB63 - Modifies provisions relating to the monitoring of certain controlled substances on June 8, 2021.  
28 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/. 
29 A total of 30,142 prescribers ordered opioids for at least 1 beneficiary at serious risk of opioid misuse or overdose in 2020. 
30 OIG, Medicare Part D Beneficiaries at Serious Risk of Opioid Misuse or Overdose: A Closer Look, OEI-02-19-00130, May 2020.   
31 In April 2021, HHS issued Practice Guidelines for the Administration of Buprenorphine for Treating Opioid Use Disorder.  
Under these new Guidelines, practitioners planning to treat fewer than 30 patients are exempt from certain requirements 
related to training, counseling and other ancillary services.  See 86 Fed. Reg. 22439. 
32 See OIG, Utilization of Medication-Assisted Treatment in Medicare, OEI-02-20-00390, forthcoming, 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. 
33 These files contain MME conversion factors for each National Drug Code.  MED and MME are interchangeable terms. 
34 Using CMSs Integrated Data Repository, we reviewed 63,434,155 PDE records for opioids with dates of service in 2020.  
To identify PDE records for opioids, we matched the NDCs on the PDE records with two files: First DataBank and CDCs MME 
conversion file. 
35 Part D covers two MAT drugs indicated for opioid use disorder:  buprenorphine and naltrexone.  Some buprenorphine 
products indicated for opioid use disorder also contain naloxone, e.g., Suboxone.  To identify PDE records for MAT drugs 
containing buprenorphine or naltrexone, we matched the NDCs to First Databank.  We reviewed each drug and included all 
formulations indicated for the treatment of opioid use disorder.  Note that some of these formulations are also indicated for 
alcohol use disorder.  We based this on PDE records from CMSs Integrated Data Repository. 
36 To identify PDE records for naloxone, we matched the NDCs to First Databank.  We included formulations indicated for the 
emergency treatment of a known or suspected opioid overdose in this analysis.  We based this on PDE records from CMSs 
Integrated Data Repository. 
37 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 March 30, 2021. 
38 We included opioids dispensed in 2019 with days of use in 2020.  This analysis excludes PDE records for injection, 
intravenous, and intrathecal opioids, as well as opioids indicated for medication-assisted treatment. 
39 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 2,736,399 beneficiaries with cancer or in hospice care who received at least 1 opioid. 
 
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Endnotes | 20   
40 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 March 30, 2021. 
41 For our analysis, we counted prescribers in group practices separately.   
Concerns Persist About Opioid Overdoses and Medicare Beneficiaries Access to Treatment and Overdose-Reversal Drugs 
OEI-02-20-00401  Endnotes | 21