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PRESCRIPTION PAIN 

MEDICATIONS: 

Frequently Asked Questions and Answers for Health Care 

Professionals, and Law Enforcement Personnel 

Supported by 

Drug Enforcement Administration 

Last Acts Partnership 

Pain & Policy Studies Group, University of Wisconsin 

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Principal Working Group

Patricia M. Good, Chief, Liaison and Policy Section,Office of Diversion Control,Drug 

Enforcement Administration 

David E. Joranson, MSSW, Senior Scientist, Director, Pain & Policy Studies Group, 

University of Wisconsin-Madison Medical School 

Karen Orloff Kaplan, MPH, ScD., President and Chief Executive Officer, Last Acts 

Partnership 

Steven D. Passik, Ph.D., Director, Symptom Management and Palliative Care Program 

Markey Cancer Center,University of Kentucky

Russell Portenoy, M.D., Chairman, Department of Pain Medicine and Palliative Care, 

Beth Israel Medical Center 

Robert C. Williamson, Deputy Chief, Liaison and Policy Section, Office of Diversion 

Control, Drug Enforcement Administration 

Review Committee

Ian Buttfield, M.D., Senior Specialist Physician, Drug and Alcohol Services Council of 

South Australia 

Michael P. Cinque, R.Ph, Pharm D.(c), FAPhA, President, Academy of Pharmacy 

Management and Practice, American Pharmaceutical Association 

Margaret (Peggy) Compton, RN, Ph.D., Associate Professor, School of Nursing, 

University of California, Los Angeles 

June L. Dahl, Ph.D., Professor, Pharmacology, University of Wisconsin Medical School 

Dennis Doherty, DO, Southeastern Pain Specialists, Atlanta 

Kathleen M. Foley, M.D., Chief of the Pain Service at Memorial Sloan-Kettering Cancer 

Center, and Professor of Neurology, Neuroscience and Clinical Pharmacology at Cornell 

University Medical College 

Douglas Gourlay, M.D., MSc, FRCPC, Medical Consultant, Pain and Chemical 

Dependency, Center for Addiction and Mental Health, Toronto, Ontario 

Howard Heit, M.D, Assistant Clinical Professor, Georgetown University

Nathaniel Katz, M.D., MS, Assistant Professor of Anesthesia, Harvard Medical School 

Walter Ling, M.D., Professor of Psychiatry and Director of the Integrated Substance 

Abuse Programs, University of California, Los Angeles 

Arthur G. Lipman, PharmD, Professor of Pharmacotherapy, College of Pharmacy; 

Adjunct Professor of Anesthesiology, School of Medicine; Director of Clinical 

Pharmacology, Pain Management Center, University of Utah 

Will Rowe, MA, Executive Director, American Pain Foundation 

Burness Communications (www.burnesscommunications.com) assisted the Principal 

Working Group in developing, editing and disseminating the document. 

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Preface 

The Drug Enforcement Administration, Last Acts Partnership, and the Pain & 

Policy Studies Group at the University of Wisconsin joined forces in 2001 to develop a 

consensus statement, “Promoting Pain Relief and Preventing Abuse of Pain Medications: 

A Critical Balancing Act” (the statement can be found on www.lastacts.org). This 

consensus statement, which was joined by numerous other health care organizations, 

called for a balanced policy addressing both the necessity of medical access to 

prescription pain medications and active approaches to stem abuse, addiction and 

diversion. After the statement was released, the group met to discuss the need for 

education of both the health care community, and the law enforcement and regulatory 

community. Although educational programs that promoted the philosophy, science and 

practical issues surrounding the policy of balance had begun to appear, there was a 

compelling need for a clear and concise educational product, which would be targeted to 

both health care professionals and professionals in the law enforcement and regulatory 

communities. The group met several times during the last year to review existing 

educational material and ultimately decided to produce a highly readable “Frequently 

Asked Questions” that would cover the clinical and regulatory issues surrounding the 

prescribing of controlled drugs. 

These Frequently Asked Questions (FAQs) were produced by a Principal 

Working Group, which included the experts who developed the consensus statement, and 

a Review Committee, which included experts from the fields of nursing, neurology, 

psychiatry, pharmacology, pharmacy and addiction medicine. The material represents a 

consensus, supported by the available literature and by the laws and regulations that 

govern the use of controlled prescription drugs. 

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Contents 

Section I: Introduction 

Section II: Terms 

 1. What are the key addiction-related terms used in discussing pain 

medications and risk management? 

Section III: Pain and Its Treatment 

 2. Why is pain management important? 

 3. What are the goals of pain management? 

 4. How can a clinician assess a patient’s pain?

 5. When should a primary care physician turn to a pain medicine specialist 

to manage a patient’s pain? 

Section IV: Medical Use of Opioid Analgesics 

 6. How are opioids used to manage chronic pain? 

 7. What outcomes should be assessed when judging whether opioid therapy 

is successful? 

 8. Where can clinicians find educational material on prescribing opioid 

analgesics? 

 9. What are the common side effects associated with opioid therapy, and 

how can they be managed? 

10. What information do patients need about using opioids for chronic pain? 

11. What kinds of problems might patients encounter when obtaining opioid 

prescriptions, in having them filled, or in taking the medications properly? 

12. Can more than one opioid at a time be prescribed to a patient? 

13. What is “opioid rotation,” and when is it appropriate? 

14. What are “tapering” and “drug holidays”? 

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15. Is a written agreement between the clinician and the patient required 

before instituting treatment with an opioid? 

16. What should be documented when prescribing opioids? 

Section V: Risks in the Medical Use of Opioid Analgesics 

17. What is the extent of prescription opioid abuse? 

18. What are the common ways opioids are diverted to illicit uses? 

19. How can clinicians assess for risks of abuse, addiction, and diversion and 

manage their patients accordingly? 

20. What behaviors are potential indicators of problems for patients on longterm opioid therapy? 

21. If a patient receiving opioid therapy engages in an episode of drug abuse, 

is the physician required by law to discontinue therapy or report the patient 

to law enforcement authorities? 

22. Is it legal and acceptable medical practice to prescribe long-term opioid 

therapy for pain to a patient with a history of drug abuse or addiction, 

including heroin addiction? 

23. What strategies can be used to treat pain successfully in patients who are 

currently abusing drugs? 

Section VI: Other Legal and Regulatory Considerations 

24. What requirements must physicians and pharmacists meet to comply 

with federal and state laws regulating opioids? 

25. What regulations do physicians need to know and observe when 

prescribing opioid analgesics for pain? 

26. Can methadone be used for pain control and, if so, is a clinician required 

to have a special license to prescribe it? 

27. Under what circumstances will the federal Drug Enforcement 

Administration (DEA) investigate and prosecute a doctor or pharmacist or 

refer cases to other agencies? 

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28. Should efforts to address diversion avoid interfering with medical 

practice and patient care? 

29. When should a law enforcement officer turn to a pain medicine specialist 

for advice? 

30. Does the number of patients in a practice who receive opioids, the 

number of tablets prescribed for each patient, or the duration of therapy 

with these drugs by themselves indicate abuse or diversion? 

Appendix A: Key Addiction-Related Terms 

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SECTION I 

INTRODUCTION 

The purpose of this document is to provide information to health care professionals and 

professionals in the law enforcement and regulatory communities about the medical 

treatment of pain. The goal is to achieve a better balance in addressing the treatment of 

pain while preventing abuse and diversion of pain medications. The authors of this 

document stand committed to the core principle of balance that was expressed in the 2001 

joint consensus statement by the U.S. Drug Enforcement Administration and numerous 

health care organizations: 

Both healthcare professionals, and law enforcement and regulatory personnel, 

share a responsibility for ensuring that prescription pain medications are available 

to the patients who need them and for preventing these drugs from becoming a 

source of harm or abuse. We all must ensure that accurate information about both 

the legitimate use and the abuse of prescription pain medications is made 

available. The roles of both health professionals and law enforcement personnel 

in maintaining this essential balance between patient care and diversion 

prevention are critical (DEA et al., 2001).

Controlled substances that are prescription drugs, such as opioids, are essential for the 

care of patients but carry a risk that goes beyond the usual clinical concern about toxicity. 

These drugs can become the object of abuse and addiction or be a target for diversion to 

an illicit market. This potential for abuse, addiction, and diversion raises concern among 

all clinicians, including physicians and pharmacists, and those in law enforcement, drug 

regulation, and policy makers. 

When potentially abusable drugs are also necessary medicines, assessment and 

management of drug-related problems can be complex. The parameters of acceptable 

medical practice include patterns of drug prescription—such as long-term administration 

of an opioid drug at escalating doses and administration of more than one controlled 

prescription drug—that may raise a “red flag” for both clinicians and regulators. 

Problematic drug-related behavior takes many forms and has many causes in the clinical 

setting. Even relatively severe drug-seeking behaviors in the context of a legitimate 

medical need, such as uncontrolled pain, cannot immediately be ascribed to addiction. 

The desperate search for pain relief, and the complex psychosocial disturbances 

accompanying chronic pain, may influence the phenomenology of drug use and greatly 

complicates the assessment of drug-related problems. 

 

At the same time, however, even patients with severe pain can develop patterns of abuse 

or addiction, or engage in criminal activity. Physicians who encounter such patients must 

control the behaviors, diagnose the comorbidities, and react in a way that is both 

medically appropriate and consistent with the laws and regulations that apply to the 

medical use of controlled drugs. Although physicians have expressed concern about 

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criminal prosecution when treating such patients, the arrest and indictment of a physician 

cannot occur unless he or she can be shown to have knowingly and intentionally 

distributed or prescribed controlled substances to a person outside the scope of legitimate 

practice. 

Drug abuse exacts a huge social cost, and some have been tempted to address 

prescription drug abuse by greatly limiting access. When drugs are needed for legitimate 

medical purposes, such as pain management, this action may have unintended 

consequences that could be just as harmful to the public. Surveys have found that 

chronic pain is highly prevalent and exacts a huge toll in terms of lost productivity, health 

care costs, and human suffering. As the U.S. population ages, people will live longer 

with chronic, often painful, diseases. Even if opioids are appropriate for only a small 

proportion of these patients, nothing should be done to limit access to the drugs when 

they are needed, or to increase the reluctance of prescribers to recommend them. 

Society has a compelling interest in ensuring both the ready access to controlled 

prescription drugs when medically needed and ongoing efforts to minimize their abuse 

and diversion. These two goals are not in conflict; they coexist and must be balanced. 

Those who are licensed to prescribe, dispense and administer these drugs, and those in 

the law enforcement or regulatory communities need continual education to improve their 

ability to balance these goals. There should be an ongoing dialogue between practitioners 

and those in law enforcement and regulation. 

The FAQs in this document support the need for dialogue and reflect an effort to answer 

basic questions about the appropriate use of opioids given their unquestioned medical 

value, as well as their potential for abuse, addiction, and diversion. The goal is to provide 

medically and legally sound and balanced education to practitioners, law enforcement, 

and regulators. Clinical items have been drafted by experts in pain management, and the 

items addressing regulatory issues have been drafted by members of law enforcement and 

experts in the regulation of controlled substances. All responses derive from the 

fundamental view that practitioners must try to relieve pain, but also must obey laws and 

regulations, and avoid contributing to diversion, while law enforcement personnel and 

regulators must address the sources of diversion, but do so in a manner that never 

interferes in clinical pain management. 

Important Disclaimer

Although the FAQs reflect a consensus view of an expert panel, lack of strict adherence 

to these suggestions does not imply that a particular practice is outside the scope of 

legitimate medical practice. The FAQ is not intended to be used as medical practice 

guidelines or standards or as legal advice with regard to specific practices or cases for 

which clarification should be obtained by consulting relevant practice guidelines, laws, 

and regulations; the agencies that administer them; and experts in law and in pain and 

addiction medicine. Practitioners, law enforcement, and regulators should always keep 

abreast of changes in federal and state statutes, in regulations, and in other policies 

relevant to pain management. 

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Relevant Resources:

Drug Enforcement Administration, Last Acts, Pain & Policy Studies Group, et al. (2000). 

Promoting Pain Relief and Preventing Abuse of Pain Medications: A Critical 

Balancing Act. Washington, DC: Last Acts. (Available at 

http://www.medsch.wisc.edu/painpolicy/dea01.htm.) 

Research America. (2003). Chronic Pain Pervasive in All Age Groups, New Study 

Shows. Alexandria, VA, September 4. (Available at 

http://www.researchamerica.org/opinions/pain.html.)

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SECTION II 

TERMS 

1. What are the key addiction-related terms used in discussing pain 

medications and risk management? 

It is imperative to use clear terminology when discussing medical matters. Terms such as 

abuse, addiction, physical dependence, pseudoaddiction, and tolerance are often used 

incorrectly by researchers, clinicians, regulators, the media, and patients. This contributes 

to misunderstandings about the risk of addiction when opioids are used to manage pain. 

Definitions of these and other terms are provided in Appendix A to: 

• encourage accurate and consistent use of addiction-related terms, 

• promote communication and better care of patients with pain and other conditions 

when the use of controlled prescription drugs is appropriate, and 

• encourage controlled substances regulatory policies and enforcement strategies that 

do not confuse the necessary treatment of pain with abuse or addiction. 

SECTION III 

PAIN AND ITS TREATMENT 

2. Why is pain management important? 

Uncontrolled pain is an enormous public health problem in the United States. Already 

accounting for many tens of billions of dollars of needed health care and lost 

productivity, it is expected that the costs will grow dramatically as the population ages 

and people live longer with chronic diseases. Equally important, unrelieved pain has a 

devastating impact on the physical, emotional, social, and economic well-being of 

patients and their families. Diagnosing and treating pain is, therefore, fundamental to the 

public health. Many medical and regulatory organizations have recognized the imperative 

to relieve pain in official statements and guidelines. 

Relevant Resources: 

American Geriatrics Society Panel on Persistent Pain in Older Persons. (2002). The 

management of persistent pain in older persons. Journal of the American 

Geriatric Society 50 (6 suppl): S205-S224. (Available at 

http://www.americangeriatrics.org/education/manage_pers_pain.shtml.) 

American Pain Society. (1999). Guideline for the Management of Acute and Chronic 

Pain in Sickle Cell Disease. Clinical Practice Guideline Number 1. Glenview, IL: 

American Pain Society. 

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American Pain Society. (2002). Guideline for the Management of Pain in Osteoarthritis, 

Rheumatoid Arthritis, and Juvenile Chronic Arthritis. Clinical Practice Guideline 

Number 2. Glenview, IL: American Pain Society. 

Arnold R, Berger A, Billings JA, et al. (2004) Clinical Practice Guidelines for Quality 

Palliative Care. Brooklyn, NY: National Consensus Project for Quality Palliative 

Care. (Available at <http://www.nationalconsensusproject.org/guideline.pdf> 

http://www.nationalconsensusproject.org/guideline.pdf).

Cancer Pain Management Policy Review Group.(2001). American Cancer Society Policy 

Statement on Cancer Pain Management. National Government Relations Department, 

American Cancer Society. 

Federation of State Medical Boards of the United States Inc. (2004). Model Policy for the 

Use of Controlled Substances for the Treatment of Pain. Dallas, TX: Federation of 

State Medical Boards of the United States Inc. (Available at http://www.fsmb.org.) 

Foley, K. M., and H. Gelband (eds). (2001). Improving Palliative Care for Cancer. 

Washington, DC: National Academy Press. (Available at 

http://www.nap.edu/catalog/10149.html.) 

Institute of Medicine Committee on Care at the End of Life. (1997). Approaching Death: 

Improving Care at the End of Life. Washington, DC: National Academy Press. 

(Available at http://books.nap.edu/catalog/5801.html.) 

National Institutes of Health Consensus Development Program. (2002). Symptom 

Management in Cancer: Pain, Depression and Fatigue. Statement prepared 

following a National Institutes of Health State-of-the-Science Conference on 

Symptom Management in Cancer; Bethesda, MD, July 15–17. (Available at 

http://consensus.nih.gov/ta/022/022_intro.htm.) 

Research America. (2003). Chronic Pain Pervasive in All Age Groups, New Study 

Shows. Alexandria, VA, September 4. (Available at 

http://www.researchamerica.org/opinions/pain.html.) 

Rich, B. A. (2001). Physicians’ legal duty to relieve suffering. Western Journal of 

Medicine 175:151–152. 

Tucker, K. L. (2001). A new risk emerges: Provider accountability for inadequate 

treatment of pain. Annals of Long-Term Care 9 (4): 52–56. 

Tucker, K. L. (2002). Anatomy of a claim for failure to treat pain adequately: $1.5M jury 

verdict in first case to be tried. Progress in Palliative Care 10 (1): 14-15. 

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3. What are the goals of pain management? 

The goals of pain treatment are to reduce pain and suffering, enhance quality of life, and 

increase the ability to function—all while minimizing the risk of adverse effects. These 

goals are the same for all pain patients regardless of addiction history. To accomplish 

these goals, pain management may involve any of a broad array of interventions, one of 

which is drug therapy. There are numerous options for analgesic drug therapy, including 

opioids. When drug therapy is one of the strategies used to address pain, the primary goal 

is to reduce pain without causing distressing side effects or other drug-related problems. 

Functional restoration may be another important goal and clinical decisions about the 

ongoing use of analgesic drugs typically require a careful assessment of all outcomes. 

4. How can a clinician assess a patient’s pain? 

Pain assessment is a critically important component of pain treatment because it can yield 

a pain diagnosis (usually described in terms of etiology, pathophysiology and/or 

syndrome) that may clarify the need for further evaluation, guide the selection of 

treatments, suggest prognosis, and indicate the status of coexisting diseases. A 

documented pain assessment provides a clinical basis for prescribing controlled 

substances and a recorded baseline against which to measure progress during treatment. 

The measurement of pain intensity is an important aspect of the pain assessment. Selfreport is the “gold standard” for pain measurement. This should be done with a tool 

appropriate for the patient’s cognitive development, language, culture, and preferences; 

the same tool should be used in subsequent assessments to allow for reliable evaluation of 

change. Pain measurement tools include numeric scales, visual analog scales, and verbal 

rating scales. In addition to pain measurement, the assessment should describe the pain in 

terms of location, temporal characteristics (onset, duration, course, and fluctuation), 

quality, and factors that increase and decrease pain. The assessment also should evaluate 

the impact of the pain on physical and psychosocial functioning. Other tools, such as 

body maps, daily diary records, and multidimensional pain scales, may be used to capture 

some of this additional information. 

A comprehensive pain assessment also includes a physical examination, which can help 

define the etiology and pathophysiology of the pain. The need for a physical examination 

is most compelling when a patient with pain is initially evaluated. The extent of this 

examination is considered to be a matter of clinical judgment and is determined by the 

nature of the clinical problem; the physician’s discipline; and the availability of 

previously documented examinations, imaging, and laboratory findings relevant to the 

pain problem. At the end of an examination, the physician should have sufficient 

information about the physical status of the patient to support a reasonable diagnostic 

formulation and decide on next steps. Whether further physical examination is required 

on subsequent visits also is a matter of clinical judgment, based on the need to confirm or 

monitor specific findings, track specific treatment effects, or assess comorbidities. 

Relevant Resource: 

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Miaskowski C, Cleary J, Burney R, Coyne,P.; Finley,R.; Foster,R.; Grossman,S.; 

Janjan,N.; Ray,J.; Syrjala,K.; Weissman,S.; Zahrbock,C. (2004) Guideline for the 

Management of Cancer Pain in Adults and Children. Glenview, IL: American Pain 

Society. 

Simon, L.S., AG Liman, and A Jacox et al. (2002). Guideline for the Management of 

Pain in Osteoarthritis, Rheumatoid Arthritis, and Juvenile Chronic Arthritis. Clinical 

Practice Guideline Number 2. Glenview, IL: American Pain Society. 

5. When should a primary care physician turn to a pain medicine 

specialist to manage a patient’s pain? 

Treatment of pain is an expected part of good medical practice, and all physicians should 

address the problem to the best of their abilities. Physicians have an obligation to 1) 

know about the range of therapies used to manage acute and chronic pain; 2) recognize 

their own level of expertise in pain assessment, treatment selection, and management; 3) 

understand the nature of the consultative resources in the community; and 4) refer 

appropriately. Consultation may be needed to obtain a more comprehensive evaluation, 

to clarify the optimal therapeutic strategy, to implement a therapy that is outside of the 

referring physician’s expertise, or to respond to the patient’s desire for another opinion. 

If the use of a controlled prescription drug, such as an opioid, is considered to be a 

potentially useful element in the therapeutic strategy, the physician may consider 

consultation for any of a variety of specific reasons. Consultation is considered part of 

good medical practice and is encouraged by the Federation of State Medical Boards’ 

“Model Policy for the Use of Controlled Substances for the Treatment of Pain” (available 

at http://www.fsmb.org/). Specialist input may be helpful to clarify the appropriateness 

of therapy; define the optimal regimen or monitoring approach; assist in the evaluation of 

problematic behavior, or evaluate specific recommendations, such as a switch from

“PRN” to fixed scheduled dosing, or from a short-acting to a long-acting drug. 

In all cases, the decision to request a consultation should be based on both a critical selfevaluation on the part of the physician and an assessment of the clinical challenges posed 

by the patient. The physician’s self-evaluation should define which types of patients or 

therapies can be implemented without additional help, which can be implemented with 

guidance through consultation, and which are better left to a specialist. Where these lines 

are drawn depends on existing knowledge and skills, and the availability of support 

systems for monitoring. Ideally, most patients who undergo evaluation by the specialist 

will then return to the primary physician for ongoing treatment. 

In some situations, consultation prior to, or during, opioid therapy may be requested 

solely to address the concern that specialist review would be reassuring to a regulator 

should the therapy ever be questioned. Although this is not a medical justification per se, 

it may be appropriate given the evolving nature of opioid therapy in medical care. 

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Consultation is not required under federal law, but some states do require consultation 

when treating patients with pain (see 

http://www.medsch.wisc.edu/painpolicy/2003_balance/ for examples). Some states have 

done away with this requirement. 

If the patient is referred to a specialist or pain treatment center to receive treatment, the 

referring physician should understand whether the expertise needed is in fact available. 

Not all pain specialists are knowledgeable or experienced in opioid therapy, for example, 

and not all provide access to psychological or rehabilitative treatments. The referring 

physician should understand the nature of the consultative services in the community 

before sending a patient for evaluation or care. A searchable list of credentialed pain 

specialists can be found at the American Academy of Pain Medicine’s website: 

http://www.painmed.org/membership/; a searchable list of pain clinics can be found at 

http://www.pain.com/frameindex.cfm. 

SECTION IV 

MEDICAL USE OF OPIOID ANALGESICS

6. How are opioids used to manage chronic pain?

There are many approaches to treating chronic pain that should be considered based on a 

comprehensive assessment of the pain syndrome and its impact, the level of disability, 

and the existence of medical and psychiatric comorbidities. In some cases, specific 

treatment targeting the cause of the pain is available and appropriate. For example, good 

glycemic control is central to the treatment of painful diabetic neuropathy and joint 

replacement can eliminate pain due to severe osteoarthropathy. When pain becomes 

chronic, there are numerous specific therapies that may be appropriate to lessen 

discomfort or address the need for functional restoration. On the basis of the assessment, 

pain treatment may emphasize or de-emphasize pharmacotherapy and incorporate any of 

a variety of non-drug treatments. These may include physical therapy or other 

rehabilitative approaches; cognitive and behavioral strategies; interventional treatments 

such as injections or implantation of spinal cord stimulators and pumps; or numerous 

complementary approaches such as acupuncture and massage. 

Drug treatments include nonopioid medications, such as acetaminophen, aspirin and the 

nonsteroidal anti-inflammatory drugs (NSAIDs); numerous drugs known collectively as 

the adjuvant medications (including antidepressants, antiseizure medications, and 

others); and opioid analgesics. Like the decision to use any other treatment, the decision 

to try an opioid, or to continue opioid therapy on a long-term basis, should be based on a 

careful evaluation of the issues specific to this approach. 

 

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Opioid therapy is accepted around the world as the most important approach to managing 

severe, acute pain (such as pain after surgery), moderate to severe chronic cancer pain, 

and moderate to severe chronic pain caused by other life-threatening diseases (such as 

AIDS). The use of opioid therapy to treat chronic nonmalignant pain has been more 

controversial and is still being actively discussed by medical experts. The consensus now 

is that some patients with chronic pain should be considered as candidates for long-term

opioid therapy, and some will gain great benefit from this approach. 

The controversy over the use of opioid drugs to treat chronic pain is multifaceted. To 

some extent, it is related to limited scientific literature that does not yet clearly define the 

most appropriate patient subpopulations, best treatments, and range of outcomes. More 

research is seriously needed to address these questions. 

The controversy also stems from a lack of education about these drugs on the part of 

clinicians, regulators, law enforcement, policy makers, patients and the public at large. 

The scientific literature that does exist is often poorly recognized. This literature is 

generally viewed by pain specialists as having established the effectiveness of opioid 

therapy in selected patients. It also has helped define the risks and range of benefits that 

are associated with the approach. 

There also is substantial confusion about the meaning of, and the true risks associated 

with, drug-related phenomena such as physical dependence, tolerance, and addiction (see 

Appendix A for definitions). This confusion can lead to the withholding of opioid 

medication because of a mistaken belief a patient is addicted when he or she is merely 

physically dependent. It can lead to inappropriate targeting of practitioners and patients 

for investigation and prosecution, and to excessive and unfounded fear of opioid use 

among patients and the public. This confusion must be resolved to settle the important 

medical questions relating to patient selection, treatment goals, dosing, and monitoring. 

The answers to these questions should be informed by research.

Ideally, the clinician’s decision about how to treat a patient’s pain is based on a full 

understanding of the likelihood of both benefit and harm from reasonable treatment 

alternatives. However, there are few data on risks and benefits for many treatments, 

including the long-term use of opioids. Nevertheless, it is widely agreed that opioids are 

an option for long-term pain treatment and that a trial may be a reasonable step for 

patients who have moderate to severe chronic pain. To make this decision, the 

assessment should attempt to answer the following questions: 

• What is conventional medical practice in the treatment of this type of pain? If 

there is widespread acceptance of an approach, such as trials of nonsteroidal antiinflammatory drugs in painful osteoarthropathy, then the decision to use an opioid 

may require documentation that the accepted approach has been tried and failed, 

or carries an unacceptably high risk in the specific patient. 

• Are there other treatments that may be effective and feasible, and have a risk-tobenefit profile as good as, or better than, the opioids? This question is difficult to 

resolve, given the lack of comparative data from clinical trials. Nonetheless, the 

clinician who is considering the administration of an opioid, particularly long15 
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term administration, should carefully consider whether there are other treatment 

options that are likely to work as well in the specific case, at the level of risk 

associated with opioid therapy. 

• Is the patient particularly vulnerable to opioid side effects? The analysis of riskto-benefits shifts in those who are predisposed to severe opioid side effects. 

• Is the patient likely to take medications responsibly or, if problems seem likely, 

could a plan for structuring the therapy and monitoring it be successful? Risk 

assessment and management should be considered a fundamental aspect to longterm opioid therapy. An assessment that reveals characteristics, such as a history 

of substance abuse in the recent past, that suggests a relatively high risk of 

problematic drug-related behaviors may influence the decision to initiate 

treatment or lead to more intensive monitoring if opioid therapy is still indicated. 

Based on the answers to these questions, the clinician should be able to make an informed 

judgment about the potential value of an opioid trial in a particular patient. 

Opioid treatment options include short-acting opioids, such as codeine, hydrocodone, 

hydromorphone, morphine, or oxycodone. Some of these drugs are available in 

combination with aspirin, acetaminophen or ibuprofen; in this case, caution is needed to 

avoid toxicity from the nonopioid component. Long-acting opioids, such as one of the 

modified-release opioids (e.g. fentanyl, morphine, or oxycodone) or the long half-life 

drug methadone (see Question 26) are preferred for chronic pain because they are more 

convenient and may provide more consistent pain relief. Less frequent dosing with longacting or controlled-release opioids also can improve adherence to the therapy (fewer 

missed doses). In appropriate patients, a short-acting opioid may be prescribed on a 

“PRN” basis in combination with fixed scheduled administration of a long-acting drug to 

assist in the management of “breakthrough” pain. 

For more information on the use of opioids in the management of pain, see: 

• American Academy of Pain Management 

http://www.aapainmanage.org/education/Education.php

• American Academy of Pain Medicine 

http://www.painmed.org/cme

• American Academy of Physician Assistants 

http://www.mecgeducation.com/jaapa/pain_management/default.asp

• American Board of Pain Medicine 

http://www.abpm.org/index.htm

• American Headache Society 

http://www.ahsnet.org

• American Medical Association 

http://www.ama-assn.org/ama/pub/category/10171.html

• American Pain Society 

http://www.ampainsoc.org

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• Beth Israel Department of Pain Medicine and Palliative Care 

http://www.stoppain.org/

• California Academy of Family Physicians 

http://www.familydocs.org/

• National Pain Education Council 

http://www.npecweb.org

Relevant Resources: 

American Society of Addiction Medicine. (1997). Rights and Responsibilities of 

Physicians in the Use of Opioids for the Treatment of Pain. Chevy Chase, MD: 

American Society of Addiction Medicine. (Available at 

http://www.asam.org/ppol/opioids.htm.) 

Gourlay, G. K. (2002). Clinical pharmacology of opioids in the treatment of pain. In M. 

A. Giamberadino (ed.), Pain 2002—An Updated Review: Refresher Course 

Syllabus. Seattle: IASP Press, pp. 381–394. 

Graven, S., H. C. W. deVet, M. van Kleef, and W. E. J. Weber (2000). Opioids in chronic 

nonmalignant pain: a criteria-based review of the literature. In M. Devor, M. C. 

Rowbotham, and Z. Wiesenfeld-Hallin (eds.), Proceedings of the 9th World 

Congress in Pain Research and Management 16, Seattle: IASP Press. 

Kalso, E. (2000). Opioids for chronic noncancer pain. In J. O. Dostrovsky, D. B. Carr, 

and M. Koltzenburg (eds.), Proceedings of the 10th World Congress on Pain, 

Seattle: IASP Press, pp. 751–765. 

Passik, S. D., and H. J. Weinreb Managing chronic nonmalignant pain; 

Overcoming obstacles to the use of opioids. Advances in Therapy17: 70–80. 

Savage, S. R. (2003). Opioid medications in the management of pain. In A. W. Graham, 

T. K. Schultz, M. F. Mayo-Smith et al. (eds.). Principles of Addiction Medicine 

(3rd ed.). Chevy Chase, MD: American Society of Addiction Medicine, Inc., 

pp.1451–1463. 

Zacny, J., G. Bigelow, P. Compton et al. (2003). College on Problems of Drug 

Dependence taskforce on prescription opioid non-medical use and abuse: Position 

statement. Drug and Alcohol Dependence 69: 215–232. 

7. What outcomes should be assessed when judging whether opioid 

therapy is successful? 

Opioid analgesics have the ability to relieve pain. Improved comfort may be associated 

with better physical and psychosocial functioning, and enhanced quality of life. Opioids 

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also have the potential for side effects and adverse effects (including abuse or addiction). 

Given the variation in the responses associated with this therapy, the management of 

opioid therapy should include ongoing evaluation of a range of outcomes. The relevant 

categories include: 

• pain relief; 

• side effects; 

• functioning, both physical and psychosocial (and overall quality of life); and 

• problematic drug-related behaviors (which may suggest misuse, abuse, addiction, 

or even diversion). 

Pain intensity, or the extent of pain relief, should be measured over time and documented 

in the medical record. This may involve questions using a simple verbal rating scale 

(none, mild, moderate, severe), a numeric scale (“0 to 10”), or some other type of 

measure. Documentation in the medical record that pain is being followed over time is 

important evidence of the appropriateness of therapy. 

Although opioids can provide pain relief, complete pain relief is uncommon during the 

treatment of chronic pain. Pain measurements during the treatment of chronic pain are 

seldom “zero,” and in some cases, can fluctuate at relatively high levels. In the clinical 

setting, the overall benefit, or success, of opioid therapy often cannot be determined by 

pain scores alone. Although clinical studies have suggested that meaningful pain relief is 

associated with defined reductions in pain scores (e.g., two points on a 0 to 10 scale or 

30% on a visual analogue scale), these values are helpful in research but do not capture 

the complexity of the clinical situation. For some patients, pain relief may be 

“meaningful” when specific tasks can be performed, mood improves, sleep is better, or 

relationships with others can occur. The monitoring of pain intensity is important but the 

clinician should be prepared to assess all these outcomes in an effort to understand the 

overall effects of therapy. 

Side effects are common during opioid therapy. The potential for side effects should be 

explained to the patient and anticipated, assessed, and managed. With the exception of 

constipation, side effects are usually of short duration and can be expected to lessen with 

time as the body adapts to the opioid (see Question 9 for more information on side 

effects).

Although a large clinical experience suggests that most patients use opioid drugs 

responsibly—following instructions, communicating with the clinician, and avoiding 

actions that would be worrisome to the prescriber—some patients engage in problematic 

drug-related behaviors. These problematic behaviors are very diverse and may reflect any 

of a wide array of clinical disorders (including addiction); they could potentially reflect 

diversion as well. Practitioners who prescribe controlled prescription drugs, such as the 

opioids, should monitor drug-related behavior. This may be done through history-taking, 

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or if indicated, through more structured plan that includes behavioral assessments. Such 

a structured approach is most clearly indicated if the patient has a known history of 

addiction or significant substance abuse (see Question 23). 

In summary, pain treatment with opioids should be evaluated over time by assessing 

improvement in pain and the extent to which this outcome is associated with side effects, 

gains in function and quality of life, and the occurrence of any problematic behaviors. 

These outcomes are important to assess in all cases, regardless of their history. 

Relevant Resources: 

Gourlay, G. K. (2002).Clinical pharmacology of opioids in the treatment of pain. In M. 

Giamberadino (ed.), Pain 2002—An Updated Review: Refresher Course 

Syllabus.Seattle: IASP Press, pp. 381–394. 

McQuay, H. J. (1999). How should we measure the outcome? Opioid Sensitivity of 

Chronic Noncancer Pain. In E. Kalso, H. J. McQuay, and Z. Weisenfeld-Hallin

(eds.), Progress in Pain Research and Management 14. Seattle: IASP Press, pp. 

371–383. 

Rowbotham, M. C. (2001). Editorial: What is a “clinically meaningful” reduction in 

pain? Pain 94: 131–132. 

8. Where can clinicians find educational material on prescribing opioid 

analgesics? 

• American Academy of Pain Management 

http://www.aapainmanage.org/education/Education.php

• American Academy of Pain Medicine 

http://www.painmed.org/cme

• American Academy of Physician Assistants 

http://www.mecgeducation.com/jaapa/pain_management/default.asp

• American Geriatrics Society 

http://www.americangeriatrics.org/education/manage_pers_pain.shtml

• American Medical Association 

http://www.ama-assn.org/ama/pub/category/10171.html 

• Beth Israel Department of Pain Medicine and Palliative Care 

http://www.stoppain.org/

• California Academy of Family Physicians 

http://www.familydocs.org/

• National Pain Education Council 

http://www.npecweb.org

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9. What are the common side effects associated with opioid therapy, and 

how can they be managed? 

It is very important that physicians anticipate, recognize, and treat side effects when 

patients are receiving opioids for pain. Common side effects at the start of therapy or 

after dose escalation include somnolence or mental clouding, nausea, and constipation. 

Uncommon side effects include fatigue; itching; adverse mood change; dry mouth, loss 

of appetite, bloating, or heartburn; urinary hesitancy; sweating; sexual dysfunction; and 

headache. Although any side effect can persist, the most common long-term side effect is 

constipation. With overdose, opioids can cause serious respiratory depression, the risk of 

which is again highest in the setting of limited or no ongoing opioid therapy. 

Physicians should periodically inquire about side effects. If side effects are present and 

are not tolerated well, treatment should be adjusted. The drug or how it is administered 

can be changed, or a specific treatment can be given for the side effect. Typically, 

successful therapy depends on achieving and maintaining a favorable balance between 

analgesic effects and side effects. 

Constipation is very common during opioid therapy, particularly among those patients 

who are predisposed (the elderly, patients taking other constipating drugs, patients with 

diseases that affect the gastrointestinal track). Tolerance may not develop to opioidinduced constipation, and laxative therapy may be needed throughout the course of 

treatment. 

Somnolence and mental clouding are common when therapy is initiated or the dose is 

increased. Although these effects typically decline over time, some patients experience 

persistent impairment. The risk presumably is higher among those who are concurrently 

using other CNS depressants and those with diseases associated with encephalopathy. 

Selected patients with analgesia compromised by somnolence or mental clouding may be 

candidates for specific therapy with a psychostimulant drug. 

Nausea and vomiting may be treated with antiemetics such as phenothiazines, 

butyrophenones, or metoclopramide. When nausea is due to motion-related vestibular 

effects, a trial of an antihistamine, such as meclizine or scopolamine, should be 

considered. If opioid-induced gastroparesis is suspected (postprandial nausea, bloating, 

reflux symptoms), metoclopramide is a preferred drug because of its positive effects on 

gastrointestinal motility. To help manage nausea, it may be worthwhile to consider 

switching to a nonoral route of administration, at least for a time. 

Itching, which results at least in part from the release of histamines triggered by opioids, 

usually resolves within a few days. If itching persists, it may be treated with an 

antihistamine. Among the commonly used opioids, and fentanyl and oxymorphone have 

a relatively low propensity to release histamine. 

Respiratory depression is a rare adverse effect during chronic opioid treatment. 

Respiratory depression is possible if dose escalation occurs very quickly, beyond the 

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ability of compensatory mechanisms to adjust; if some intercurrent cardiopulmonary 

event occurs (for example, pulmonary embolism or pneumonia), or if something happens 

to eliminate the source of the pain (for example, a nerve block). Except in rare 

circumstances, respiratory depression is preceded by somnolence and slowed breathing. 

Respiratory depression that occurs from some intercurrent cardiopulmonary event may 

be partially reversed by naloxone. Accordingly, a response to naloxone does not mean 

that the opioid was the primary problem. When patients develop respiratory depression 

in the setting of stable dosing, a prompt search for another cause usually is indicated, 

even if the patient improves with naloxone. 

Because the administration of naloxone carries substantial risks in the physically 

dependent patient (severe withdrawal), it should not be used unless clinically significant 

respiratory depression is feared. Naloxone should not be given for somnolence in the 

absence of existing or impending respiratory effects. If the time of peak effect of the drug 

has passed, and the patient has adequate respirations, it is safer to observe for a period of 

hours than to treat with naloxone. If naloxone must be given, it is safer to give small 

doses repeatedly and monitor effects. 

Relevant Resources: 

American Pain Society. (2003). Principles of Analgesic Use in the Treatment of Acute 

Pain and Cancer Pain (5th ed.). Glenview, IL: American Pain Society.

Fohr, S. A. (1998). The double effect of pain medication: Separating myth from reality. 

Journal of Palliative Medicine 1 (4): 315–328. 

10. What information do patients need about using opioids for chronic 

pain? 

Informing patients about issues surrounding pain management and the use of opioid 

analgesics is good medical practice. Sometimes, this is accomplished as part of informed 

consent, which is recommended and, in fact, required in some states (to see if your state 

requires informed consent, refer to http://www.medsch.wisc.edu/painpolicy/matrix.htm). 

Physicians can provide information through discussions with the patient or by 

distributing a handout, booklet, or medication agreement. Patients and their caregivers 

also can gain access to valuable information by using the Internet to reach a number of 

organizations (see links provided below). 

Although not a complete list, patients should understand this information: 

• Patients’ rights

- Patients have the right to have their pain assessed and treated. 

- Accredited medical facilities should recognize this right. 

• Diagnosis and treatment plan

Patients should:

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- know the diagnosis and as much as possible about reasons for the pain. 

- know the goals of treatment and how the physician will measure progress to 

achieve the goals. 

- know why opioid analgesics are part of the treatment plan and how and when to 

take them. 

- know the realistic expectations for sustained pain relief and improved 

functioning, and that it may not be possible to relieve all their pain. 

- realize that opioids are only one part of a treatment plan that may include other 

treatments such as physical therapy or psychological techniques. 

- recognize that decisions about starting, changing, or stopping opioid treatment 

should be made with patient input. 

- know that they can ask for changes in treatment or a consultation with a 

specialist if pain relief is not adequate. 

• Side effects 

Patients should: 

- know what side effects to expect and how to manage them. 

- understand that most side effects are transitory, but any effect can persist and 

potentially compromise the long-term value of the treatment. 

- recognize that concurrent therapies for side effects may be recommended. 

- know that the occurrence of intolerable and untreatable side effects means that 

the treatment is not appropriate and must be changed. 

- know that opioids may impair thinking and alertness at first and, if this occurs, 

the patient should avoid driving or other similar activities until these effects 

dissipate. 

• Abuse, addiction, physical dependence, and tolerance

Patients should: 

- know the definitions of physical dependence, tolerance, and addiction. 

- understand that the use of an opioid in a manner different from what is 

instructed is a form of drug abuse, and that the clinician must continually 

assess whether this is occurring and take steps to prevent it or, should it be 

identified, stop it. 

- know that the use of alcohol and any other prescribed drugs during opioid 

therapy must be assessed by the clinician, and should the use of these 

substances be perceived to be problematic, the clinician must assess the 

situation and take appropriate actions. 

- recognize that the use of illicit drugs can be a significant problem, and that the 

clinician must monitor the patient for this occurrence and act appropriately if

it is discovered. 

- know that addiction is a serious illness, and that the clinician must monitor 

drug-related behaviors in part to make sure that this problem is not 

developing; if there is a possibility that problematic behaviors surrounding 

medicines are due to an addiction, the physician must treat this. 

 know that true addiction is believed to be a rare occurrence in patients 

who receive opioids for a medical reason and have no history of drug 

abuse or addiction; clinicians must monitor drug-related behaviors in all 

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patients, however, have accurate and balanced information about 

addiction and how it is assessed. 

- know that physical dependence, which is the capacity for withdrawal, is 

normal during opioid therapy, does not prevent discontinuation of the therapy 

if the pain stops, and, most important, is not addiction. 

- know that analgesic tolerance occurs when a stable dose of pain medication 

has a decreasing effect over time and does not indicate addiction. 

• Some “Dos” and One “Don’t” for Patients

- Do talk to the doctor and other health care professionals involved in your pain 

care about the pain; keep notes and write down questions to ask about the pain. 

- Do talk to the doctor if the medication is not working. 

- Do talk to the doctor if there are problems with side effects. 

- Do talk to the pharmacist openly about this therapy if he or she could potentially 

help with information about the pain or the management of side effects. 

- Do keep the medications in a safe place and out of children’s reach. 

- Do look for another physician, or request referral to a specialist, if the pain is not 

taken seriously. 

- Do use the medication only as it is prescribed and handle the therapy with a high 

level of responsibility. 

- Do notify the physician if you are planning to become pregnant or are already 

pregnant. 

- Don’t allow others to use the prescription medication; the patient is the only 

person who is legally permitted to have the prescribed opioids.

For more information about pain, patients’ rights, communicating with the physician, 

and support: 

American Alliance of Cancer Pain Initiatives 

http://www.aacpi.org

American Cancer Society 

http://www.cancer.org/docroot/home/index.asp

American Chronic Pain Association 

http://www.theacpa.org

American Pain Foundation (homepage) 

http://www.painfoundation.org/

American Pain Foundation (brochure “Finding Help for your Pain”) 

http://www.painfoundation.org/downloads/FindingCare.pdf

Cancer Information Service 

http://cis.nci.nih.gov/

National Chronic Pain Outreach Association 

http://www.chronicpain.org/

National Pain Foundation 

http://www.painconnection.org

 

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11. What kinds of problems might patients encounter when obtaining 

opioid prescriptions, in having them filled, or in taking the medications 

properly? 

• Some physicians may be reluctant to prescribe pain medications due to 

uncertainty about the medical appropriateness, inadequate or inaccurate 

knowledge about pain management, limited information about opioid 

pharmacology, concern about the development of problematic drug-related 

behavior or addiction, and fear of scrutiny by regulatory and law enforcement 

agencies and the insurance industry. Physician communication with regulatory 

agencies, as well as information disseminated by organizations such as medical 

boards, can help to overcome these problems. 

• Pharmacists sometimes react with suspicion to patients who are prescribed opioid 

drugs because of concern about drug abuse or lack of information about the 

proper role of opioid therapy in pain management. Some pharmacists even refuse 

to dispense controlled substances, and some do not understand what the law 

allows. Communication between the physician and pharmacist, as well as 

consultation with and information disseminated by pharmacy boards, can reduce 

these problems. 

• Some pharmacies do not stock pain medications due to high cost, poor 

reimbursement, low prescription demand, and concerns about theft or robbery; 

clinicians may recommend certain pharmacies or may call ahead to be sure that 

the prescribed medication is in stock. 

• Pharmacies sometimes provide drug information, including computer printouts, 

that provide an inaccurate perspective of the benefits and risks of opioid drugs, 

reinforcing patient concerns about the medicine. 

• Family and friends, or health care providers who are not directly involved in the 

therapy, may express concerns about the use of opioids. These concerns may 

result from a poor understanding of the role of this therapy in pain management or 

from an unfounded fear of addiction; they may be exacerbated by widespread, 

sometimes inaccurate, media coverage about abuse of opioid pain medications. 

Relevant Resources: 

Joranson, D. E., and A. M. Gilson (2001). Pharmacists’ knowledge of and attitudes 

toward opioid pain medications in relation to federal and state policies. Journal of 

the American Pharmaceutical Association 41 (2): 213–220. (Available at 

http://www.medsch.wisc.edu/painpolicy/publicat/01japhak/index.htm.) 

Morrison, R. S., S. Wallenstein, D. K. Natale et al. (2000). “We don’t carry that”—

Failure of pharmacies in predominantly nonwhite neighborhoods to stock opioid 

analgesics. New England Journal of Medicine 342 (14): 1023–1026. 

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12. Can more than one opioid at a time be prescribed to a patient? 

The physician may determine that it is beneficial for the patient to use more than one 

opioid at a time. In the treatment of cancer pain, the typical approach involves the 

prescription of a long-acting opioid to relieve baseline pain plus a short-acting opioid 

(known as the “rescue” dose) to be taken as needed for episodes of breakthrough pain. 

Many pain specialists now apply this approach to the management of chronic noncancer 

pain. The use of this rescue medication should be considered on a case-by-case basis. 

Some patients appear to be good candidates because their pain fluctuates, opioids help, 

and there is a reasonable expectation of responsible drug use; others may benefit more 

from administration of a single drug according to a fixed schedule. Other nonopioid 

controlled substances also may be coadministered during opioid therapy (see Question 9). 

A separate prescription form should be used for each opioid or other controlled substance 

prescribed. 

13. What is “opioid rotation,” and when is it appropriate? 

Opioid rotation refers to a switch from one opioid to another. It is a common strategy to 

address the occurrence of intolerable side effects during opioid therapy. When a switch 

is made, the starting dose of the new drug is selected based on the information in an 

“equianalgesic dose table.” Versions of this table are widely available, and the values it 

contains should be considered a broad guide to selecting the dose. In most cases, the 

dose of the new opioid is reduced from the calculated equianalgesic dose because crosstolerance between opioids is incomplete and there is substantial variation in the doseresponse across individuals. This reduction reduces the risk of side effects from a 

calculated dose that may be, in effect, too high for the patient. The extent of the dose 

reduction varies with the specific drug and the clinical situation of the patient. The usual 

30-50% reduction in the calculated equinalgesic dose is increased (usually to 75-90%) 

when the switch is to methadone, and is decreased (sometimes to no reduction at all) 

when the switch is to transdermal fentanyl; the reduction is increased if the patient has 

significant opioid side effects or is medically frail, and it is decreased if the patient has a 

high level of pain. After treatment with the new drug is initiated, the dose usually must be 

adjusted, often repeatedly, to optimize the balance between pain relief and side effects. 

Relevant Resources: 

Anderson, R., et al. (2001). Accuracy in equianalgesic dosing. Conversion dilemmas. 

Journal of Pain and Symptom Management 21 (5): 672–687. 

Arnold, R., and D. E. Weissman (2003). Calculating opioid dose conversions #36. 

Journal of Palliative Medicine 6 (4): 619–620. 

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Pereira, J., et al. (2001). Equianalgesic dose ratios for opioids. A critical review and 

proposals for long-term dosing. Journal of Pain and Symptom Management 22 

(2): 672–687. 

Southern California Cancer Pain Initiative. Pocket Card. (Available at 

http://sccpi.coh.org/.) 

14. What do the terms “tapering” and “drug holiday” mean? 

Tapering (or “weaning”) is when the physician discontinues a pain patient’s opioid 

therapy by progressively reducing the dose to prevent withdrawal symptoms. If opioid 

therapy must be stopped, the dose should be tapered rather than being discontinued 

abruptly. The observation that opioid therapy can be discontinued without uncomfortable 

abstinence by carefully tapering the dose supports the view that opioid therapy can be 

initiated as a trial. If the patient benefits, treatment can be continued; if the patient does 

not benefit, or benefits for a time but then develops problems, the treatment can be 

stopped without risk of the significant physiologic perturbations associated with 

withdrawal. 

Tapering of a patient being treated for pain is legally distinct from “detoxification” of a 

patient being treated for addiction. Physicians who are directing the taper of a therapy do 

not need a separate DEA registration as do those who are directing detoxification 

programs under Title 21 of the U.S. Code of Federal Regulations §1306.07. There are no 

federal or state regulations governing the tapering from opioids of a patient being treated 

for pain. 

A “drug holiday” usually means the cessation of opioid therapy for reasons other than 

inadequate pain relief, unacceptable adverse effects, or decreased quality of life. There is 

no medical justification for an enforced drug holiday of an opioid in the management of 

ongoing pain. 

15. Is a written agreement between the clinician and the patient required 

before instituting treatment with an opioid? 

Although not required by federal regulations, written agreements regarding opioid 

treatments can be an important part of treatment for some patients and may be required or 

considered the standard of practice in some states. Pain specialists have differing 

opinions about the contents and use of agreements, but some believe they should be used 

whenever long-term opioid therapy is instituted. Some clinicians use agreements as 

routine office policy for every patient receiving chronic opioid therapy. Written 

agreements should advance a positive therapeutic relationship, reflect a willingness to 

have an open dialogue about the responsibilities and risks associated with opioid therapy, 

and contain clear and accurate information and instructions for the patient. Such 

agreements—a copy of which is kept by both physician and patient—may be useful to: 

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• Describe the treatment goals and plan. 

• Clarify the responsibilities and expectations of both physician and patient. 

• Serve as a reference point if there is any disagreement about expectations and 

responsibilities. 

• Serve as written informed consent regarding the possible side effects and risks of

opioid medications. 

• Establish parameters for opioid use and consequences for misuse. 

• Aid in the diagnosis of problematic drug-related behavior, should it occur. 

Examples of such agreements can be found at: 

• American Academy of Pain Management 

http://www.aapainmanage.org/literature/Articles/OpioidAgreements.pdf. 

• American Academy of Pain Medicine 

http://www.painmed.org/productpub/statements/ 

Relevant Resource: 

Gitlin, M. C. (1999). Contracts for opioid administration in the management of chronic 

pain: a reappraisal. Journal of Pain and Symptom Management18: 6–8. 

16. What should be documented when prescribing opioids? 

Requirements for documentation when prescribing opioids for the treatment of pain vary 

from state to state, but there are several features that endorsed commonly: 

• The medical record should have evidence that the treatment is taking 

place within the standards of medical practice. 

o For an initial evaluation, this includes a history and physical 

examination, a pain assessment, and a treatment plan. 

o For follow-up visits, this includes an appropriate interim history 

and focused examination when indicated, pain reassessment, and 

reevaluation of the treatment plan. 

• The medical record should reveal evidence that the physician has 

evaluated the nature of the pain complaint, earlier treatments, impact of

the pain, important comorbidities, and alcohol and drug history. 

• The medical record should show that a range of outcomes have been 

repeatedly assessed during the course of opioid therapy, including: 

o pain intensity; 

o physical and psychosocial functioning; 

o side effects of therapy; and 

o drug use behaviors (that is, whether any problematic behaviors 

occur). 

The Federation of State Medical Boards of the United States (FSMB) “Model Policy for 

the Use of Controlled Substances for the Treatment of Pain” provides more detailed 

direction on documentation at http://www.fsmb.org/. State requirements can be obtained 

from your state medical board (directory provided at http://www.fsmb.org) and from state 

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pain policies for each state and can be found at 

http://www.medsch.wisc.edu/painpolicy/matrix.htm. 

SECTION V 

RISKS IN THE MEDICAL USE OF OPIOID 

ANALGESICS 

17. What is the extent of prescription opioid abuse? 

 

It is difficult to measure with precision trends in the abuse of prescription controlled 

substances, including the opioid analgesics. Several information systems exist and are 

described in the references below. Some useful perspective can be obtained from one 

nationally representative information system, the Drug Abuse Warning Network 

(DAWN), although periodic changes in data collection methodology make its 

interpretation difficult over time. According to The DAWN Report (January 2003), 

published by the Substance Abuse and Mental Health Services Administration: 

Concern about the abuse of prescription painkillers has risen dramatically in the 

U.S. Of particular concern is the abuse of pain medications containing opiates 

(also known as narcotic analgesics), marketed under such brand names as 

Vicodin®, Oxycontin®, Percocet®, Demerol®, and Darvon®. According to the 

Drug Abuse Warning Network (DAWN), the incidence of emergency department 

(ED) visits related to narcotic analgesic abuse has been increasing in the U.S. 

since the mid-1990’s, and more than doubled between 1994 and 2001. 

The DAWN system collects data from EDs about the number of times drugs are 

mentioned1

 in drug overdoses. In 2002, the total number of DAWN ED mentions was 

1,209,938. These included: 

• 17% alcohol-in-combination with other drugs (24% increase from 1995); 

• 16% cocaine (47% increase from 1995); 

• 10% marijuana (164% increase from 1995); 

• 10% all narcotic analgesics combined (163% increase from 1995); and 

• 8% heroin (34% increase from 1995). 

Of the opioid analgesic category: 

• Codeine: 4,961 mentions; a decrease of 43% from 1995 

• Fentanyl: 1,506 mentions; an increase of 6745% over 1995 

• Hydrocodone: 25,197 mentions; an increase of 160% over 1995 

• Hydromorphone data not available 

1

 A drug mention refers to the number of times a drug is mentioned as being involved in a drug-related 

emergency room visit.

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• Meperidine: 722 mentions; a decrease of 31% from 1995 

• Methadone: 11,709 mentions; an increase of 176% over 1995 

• Morphine: 2,775 mentions; an increase of 116% over 1995 

• Oxycodone: 22,397 mentions; an increase of 560% over 1995 

• Propoxyphene: 4,676 mentions; a decrease of 25% from 1995 

Given the well accepted limitations of DAWN data, this report should not be considered 

a detailed or comprehensive accounting of the epidemiology of drug abuse. Nonetheless, 

the DAWN system has been used for many years as an indicator of drug abuse patterns. 

From this indicator and other data, there is a high likelihood that prescription drug abuse 

has increased substantially during the past decade. 

Relevant Resources: 

Brookoff, D. (1993). Abuse potential of various opioid medications. Journal of General 

Internal Medicine 8: 688–690. 

Gilson, A. M., K. M. Ryan, D. E. Joranson, and J. L. Dahl (in press). A reassessment of 

trends in the medical use and abuse of opioid analgesics. Journal of Pain and 

Symptom Management. 

Ling, W, D. R. Wesson, and D. E. Smith (2003). Abuse of prescription opioids. In A. W.

Graham, T. K. Schultz, M. F. Mayo-Smith, R. K. Ries, and B. B. Wilford (eds.), 

Principles of Addiction Medicine (3rd ed). Chevy Chase, MD: American Society 

of Addiction Medicine, Inc., pp. 1483–1492. 

Zacny, J., G. Bigelow, P. Compton et al. (2003). College on Problems of Drug 

Dependence taskforce on prescription opioid non-medical use and abuse: Position 

statement. Drug and Alcohol Dependence 69: 215–232. 

18. What are the common ways opioids are diverted to illicit uses? 

“Diversion” refers to the unlawful transfer of prescription drugs from legitimate to illicit 

channels of distribution, often resulting in episodes of abuse. Opioids are diverted in 

many ways, all of which are illegal. At the top of the distribution chain, there are thefts 

from drug manufacturers and wholesalers. The most common type of diversion at this 

level is from in-transit losses. Depending on the size of the “heist,” this source could 

account periodically for a large number of opioids reaching the illicit market. 

At the retail level, there are thefts from pharmacies, also a potentially large source of 

diversion. The most common pharmacy theft is the “night break-in.” There are also 

numerous reports of armed robbery of pharmacies. The individuals who commit these 

crimes can be dangerous and may be motivated by their own addiction or to sell the drugs 

on the illicit market. Diversion from pharmacies also includes employee pilferage and 

customer theft. There is also “Internet” diversion, where drugs are illegally purchased 

online from foreign and domestic websites. 

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Some physicians knowingly and intentionally prescribe opioid medications for profit or 

other personal gain and others may become involved in “prescription fraud,” which 

occurs whenever prescriptions for controlled substances are obtained under false 

pretenses, including when prescriptions are forged or altered to authorize additional 

quantities or refills, or when prescriptions are called in to pharmacies by individuals 

posing as patients or claiming to represent a physician. Patients sometimes sell their 

prescription forms or medications to others, and nonpatients may steal a patient’s 

prescriptions or medications. Some physicians unwittingly contribute to diversion by 

careless prescribing or failure to maintain control over their prescription pads. To reduce 

these occurrences, practitioners should write prescriptions in a way that precludes 

alteration, keep prescription forms in a secure location, and contact local law enforcement 

if prescription forms are ever stolen. 

Drug abusers may visit multiple physicians and present themselves convincingly so that 

physicians who are unfamiliar with drug abuse may inadvertently contribute to drug 

diversion. This method of diversion is called “doctor shopping.” Skilled “professional 

patients” seek out physicians and use them, willingly or unwillingly, as suppliers of drugs 

that are then diverted to the illicit market. Any physician can be duped, and physicians 

are encouraged to familiarize themselves with how to spot a drug abuser (see answer to 

Question 19) or go to DEA website for “Don’t be scammed by a drug abuser,” 

http://www.deadiversion.usdoj.gov/pubs/brochures/index.html), while at the same time 

ensuring that their pain patients receive the pain relief they need. 

There are few data about the extent to which these various sources contribute to overall 

diversion and abuse. The source of diversion for which there is the most consistent and 

reliable data comes from DEA registrants, including pharmacies, who are required to 

report all significant losses and thefts to the DEA. (An example of pharmacy theft data 

can be found on the DEA website, 

http://www.deadiversion.usdoj.gov/drugs_concern/oxycodone/oxycodone.htm). 

Relevant Resource: 

Gilson, A. M., K. M. Ryan, D. E. Joranson, and J. L. Dahl (in press). A reassessment of 

trends in the medical use and abuse of opioid analgesics. Journal of Pain and 

Symptom Management. 

19. How can clinicians assess for risks of abuse, addiction, and diversion 

and manage their patients accordingly? 

Some patients engage in aberrant drug-related behavior during treatment with an opioid 

or another controlled substance prescription drug. In some cases, this abuse is relatively 

minor and transitory, but in others, it is serious and persistent. Clinicians should 

recognize that these behaviors may have any number of causes, including addiction. It is 

recommended that clinicians adopt a “universal precautions” approach to the use of 

potentially abusable drugs, including opioids, as discussed below. This approach 

monitors behaviors over time and structures prescribing consistent with the degree of risk 

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31

of abuse, addiction, and diversion. By establishing treatment expectations for each 

patient, and structuring therapy appropriately, physicians can identify those patients who 

are at risk for abuse, addiction, or diversion; help those who may need controls to manage 

the therapy responsibly; and provide the monitoring that is needed for safe and effective 

prescribing. 

Clinicians should consider the following approaches in developing a “universal 

precautions” approach: 

1. In assessing patients for opioid therapy, take a detailed history and perform an 

appropriate physical examination (see Question 4). The medical history should 

include a history of controlled prescribed drug use and alcohol, cannabis and 

nicotine use. Screen for addictive behaviors of other family members. Take into 

consideration any social, psychological, or work-related factors that may indicate 

a potential for abuse, addiction, or diversion. Identify concurrent psychiatric 

illness, especially where poor impulse control is a feature. 

2. Establish diagnoses for the pain problem and for relevant comorbidities, and 

record these in the chart. Base the diagnosis on appropriate evaluations and 

review of patient records, if available. A patient’s unwillingness to allow contact 

with previous providers should be evaluated and documented. 

3. Consider multiple approaches to the treatment of chronic pain. 

Nonpharmacological and nonopioid analgesic approaches may be preferred. 

Some states have special requirements for treatments that should be tried before 

opioids. 

4. Consider opioid therapy for all patients with chronic moderate to severe pain, but 

evaluate the answers to the following questions first and make case-by-case 

decisions about the appropriateness of an opioid trial (see Question 6): 

• What is conventional medical practice in the treatment of this type of pain? 

• Are there other treatments that are effective and feasible and have a risk-tobenefit profile as good as, or better than, the opioids? 

• Is the patient particularly vulnerable to opioid side effects? 

• Is the patient likely to take medications responsibly or, if problems seem 

likely, could a plan for structuring the therapy and monitoring it be 

successful? 

5. Recognize that opioid therapy is as much a “therapeutic trial” as any other 

treatment. If the benefits are not clear, or the risks of adverse effects are not 

easily managed, the therapy can be modified or stopped. 

 

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6. One practitioner should have primary responsibility for management of chronic 

pain in patients with a known or suspected history of abuse, addiction, or 

diversion. 

7. When a patient has a known history of abuse, addiction, or diversion, it is 

particularly important that the clinician be clear from the beginning about 

expectations in the treatment plan. The treatment plan may include a written 

agreement with the patient describing the requirements (see Question 15 

regarding agreements), such as limited quantities of medication, routine urine 

screens, consultation with a specialist, and the consequences of not adhering to 

the agreement. 

If the clinician decides to initiate opioid therapy, it is appropriate to begin by titrating the 

amount of opioid to ensure that maximum therapeutic effect can be reached. 

Continuation of therapy is justified if the benefit is demonstrably greater than the adverse 

outcomes; this should be clearly documented. Once adequate pain relief has been 

achieved, a successfully treated patient is one who remains responsible over time, follows 

the agreement for use of the opioids and exhibits neither drug abuse behaviors nor 

indications of addiction, and experiences enhanced comfort and an improved quality of 

life. At the other extreme, patients who manifest the disease of addiction exhibit a range 

of maladaptive behaviors and experience a decreased quality of life. They do not follow 

the agreement for use of opioids, do not conform to the agreed-upon dosing schedule; and 

may lose prescriptions, repeatedly seek early refills, or obtain additional supply from

other sources. They continue or escalate medication use despite adverse consequences; 

appear unaware of, or in denial about, abuse of the medication; and may always have a 

“story.” In some cases, such a patient will “doctor shop” or alter prescriptions to increase 

his or her supply of the medication. (See answers to Question 22 and Question 23 for 

more information). 

A “universal precautions” approach to the prescribing of controlled prescription drugs 

does not mean that all patients who have the capacity to engage in abuse or diversion will 

be identified, or prevented from these behaviors over time. Nonetheless, the approach 

emphasizes the value of ongoing assessment and close monitoring, which are essential 

aspects to the appropriate, safe and effective use of these over time. 

Relevant Resources: 

Compton, P., J. Darakjian, and K. Miotto(1998). Screening for addiction in patients with 

chronic pain and “problematic” substance use: Evaluation of a pilot assessment 

tool. Journal of Pain and Symptom Management 16 (6): 355–363. 

Covington, E. (2001). Lawful Opioid Prescribing and Prevention of Diversion. 

Dannemiller Education Foundation CD ROM, October. 

Drug Enforcement Administration. (1999) “Recognizing the Drug Abuser.” (Available at 

http://www.deadiversion.usdoj.gov/pubs/brochures/drugabuser.htm.)

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33

Gourlay, D., and H.A. Heit: Universal Precautions in Pain Medicine: A rational approach 

to the treatment of chronic non-cancer pain. Submitted for publication. 

Savage, S. R. (2002). Assessment for addiction in pain-treatment settings. Clinical 

Journal of Pain 18: S28–S38. 

Savage, S. R. (2003). Principles of pain management in the addicted patient. In A. W.

Graham, T. K. Schultz, M. F. Mayo-Smith et al. (eds.), Principles of Addiction 

Medicine (3rd ed.). Chevy Chase, MD: American Society of Addiction Medicine, 

Inc., pp. 1405–1419. 

Schnoll, S. H., and J. Finch (1994). Medical education for pain and addiction: Making 

progress toward answering a need. Journal of Law, Medicine & Ethics 22: 252–

256. 

20. What behaviors are potential indicators of problems for patients on 

long-term opioid therapy? 

Patients who received opioids or other controlled prescription drugs for legitimate 

medical purposes may engage in problematic drug-related behaviors. The range of 

behaviors is broad and their meaning may be difficult to clarify. Some behaviors that are 

clear-cut indicators of abuse or addiction when they occur in those with no legitimate 

medical problem become more challenging to interpret when there are unrelieved 

symptoms that are the target of therapy. In all cases, problematic drug-related behaviors 

must be carefully assessed, even as efforts are undertaken to eliminate or limit them. The 

differential diagnosis of problematic behavior includes addiction and diversion, but also 

pseudoaddiction (see Appendix A), confusion related to organic brain disease, and 

numerous psychiatric disorders associated with impulsive or self-destructive drug use. 

Some of the problematic drug-related behaviors that occur in populations with chronic 

pain should be noted, and managed, by clinicians, but are generally recognized as 

relatively less egregious, and therefore, probably less likely to be predictive of addiction. 

These include: 

• complaints about need for more medication;

• drug hoarding;

• requesting specific pain medications (others “don’t work”);

• openly acquiring similar medications from other providers; 

• occasional unsanctioned dose escalation; and 

• nonadherence to other recommendations for pain therapy. 

These behaviors are not acceptable and could lead to any of a number of responses on the 

part of the clinician, including the decision to taper and discontinue treatment. Clinicians 

also should be aware that some of these types of behaviors, such as the effort to acquire 

medications from other providers, may be violating the laws of some states. It is 

important to recognize, however, that these behaviors cannot be perceived to be an 

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34

immediate reflection of addiction. Rather, the assessment may reveal other potential 

explanations, including the possible effects of unrelieved pain. 

The following behaviors are more egregious, and as such, are more probable indicators of 

abuse, addiction, or diversion (see DEA website, 

http://www.deadiversion.usdoj.gov/pubs/brochures/index.html): 

• Deterioration in functioning at work, in the family, or socially 

• Illegal activities, such as selling medications, forging prescriptions, stealing drugs 

from other patients, buying prescription drugs from nonmedical sources 

• Injection or snorting of medication 

• Multiple episodes of “lost” or “stolen” prescriptions 

• Resistance to changes in therapy, regardless of adverse effects 

• Refusal to comply with random urine drug screens or referral to specialist 

• Concurrent abuse of alcohol or illicit drugs 

• Use of multiple physicians and pharmacies 

These behaviors also cannot be assumed to be diagnostic of addiction, but they do 

indicate a relatively greater degree of pathology and presumably signal a higher 

likelihood of this disorder. Even if the criteria for addiction are not met, the severity of 

these problems emphasizes the need for a competent assessment and appropriate 

management, possibly including referral to a specialist in addiction medicine. 

Several recent surveys suggest that the occurrence of problematic drug-related behaviors 

of one sort or another is very common in populations treated with long-term opioid 

therapy. As a result, monitoring for problematic behaviors must be considered to be an 

essential aspect of the long-term management of opioid therapy. These behaviors should 

not be taken to mean that a patient does not have pain, or that opioid therapy is 

contraindicated. Rather, they indicate the need for assessment, informed diagnosis and 

appropriate management. Management may or may not include continuation of therapy, 

depending on the circumstances (see Question 21). If the decision is made to terminate 

the physician-patient relationship, there must always be a good faith effort to avoid 

patient abandonment by providing referrals. 

Pharmacists, whose principal professional obligation is to provide medications to the 

patient, and to counsel the patient on safe and effective use of the medications, must 

evaluate whether the prescription presented to them is for a legitimate medical purpose 

and issued by a properly registered practitioner in the course of professional practice. 

The main indicator that pharmacists should watch for is whether the prescription appears 

to be forged or altered. Pharmacists also should check patient profiles for seemingly 

duplicative or excessive controlled substance use and communicate with the prescribers 

in such cases. In addition, DEA says that the following signs should also be considered: 

• Unsettling patient presentation 

• A pattern of early requests for prescription refills (that is, more than a few days 

before the patient should be running out) 

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35

• Unreasonable quantities 

• Time of prescription presentation, that is, weekends or after hours 

• Patient unknown to pharmacist 

• Prescriber unknown to pharmacist 

 

These “red flags” do not mean that drug abuse or diversion is occurring. Patients are the 

focus of the practice of pharmacy, so professional judgment must serve the patient’s 

needs first and foremost. Stereotypes of what an abuser “looks like” can harm legitimate 

patients because people who abuse prescription medicine can exhibit some of the same

behaviors as patients who have unrelieved pain (see Appendix A for definition of 

pseudoaddiction). 

Physicians and pharmacists should expect some degree of interaction with law 

enforcement authorities if their patients are involved in illegal activities, especially when 

patients sell the drugs that have been prescribed for them or when there is a need to 

substantiate prescription forgeries. 

Relevant Resources: 

Brushwood, D. B. (2003). Drug control policy out of balance. Pain & The Law. 

(Available at http://www.painandthelaw.org/mayday/brushwood_090403.php.) 

Compton, P., J. Darakjian, and K. Miotto (1998). Screening for addiction in patients with 

chronic pain and “problematic” substance use: evaluation of a pilot assessment 

tool. Journal of Pain and Symptom Management 16 (6): 355–363. 

Drug Enforcement Administration. (2003). Pharmacist’s Manual: An Informational 

Outline of the Controlled Substances Act of 1970 (8th ed.). Washington, DC: U.S. 

Department of Justice. (Available at 

http://www.deadiversion.usdoj.gov/pubs/manuals/index.html.)

Passik, S. D., K. L. Kirsh, M. V. McDonald et al. (2000). A pilot survey of aberrant drugtaking attitudes and behaviors in samples of cancer and AIDS patients. Journal of 

Pain and Symptom Management 19 (4): 274–286. 

Portenoy, R. K. (1996). Opioid therapy for chronic nonmalignant pain: Clinicians’ 

perspective. Journal of Law Medicine & Ethics 24 (4): 296–309. (Available at 

http://www.painandthelaw.org/aslme_content/24-4c/portenoy.pdf.) 

 

21. If a patient receiving opioid therapy engages in an episode of drug 

abuse, is the physician required by law to discontinue therapy or to report 

the patient to law enforcement authorities? 

Federal drug laws do not require physicians to report to law enforcement authorities 

patients who have engaged in drug abuse. The controlling federal legal standard is that 

the physician must issue prescriptions for controlled substances only for legitimate 

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36

medical purposes and in the usual course of professional practice. However, some state 

policies state that a physician should not prescribe, administer, or dispense opioid 

analgesics to a person the physician knows or should know is using controlled substances 

for nontherapeutic purposes. State laws and regulations should be consulted on whether a 

report of patient drug abuse is necessary or use of opioids must cease under such 

circumstances.

In states with no specific legal requirements on this subject, if continued opioid therapy 

makes medical sense, then the therapy may be continued, even if drug abuse has 

occurred. Additional monitoring and oversight of patients who have experienced such an 

episode is recommended (see the answer to Question 23). 

Incontrovertible evidence of criminal activity, such as diversion, is grounds for 

termination of the doctor-patient relationship. 

22. Is it legal and acceptable medical practice to prescribe long-term 

opioid therapy for pain to a patient with a history of drug abuse or 

addiction, including heroin addiction? 

It is within the scope of current federal law to prescribe opioids for pain to patients with a 

history of substance abuse or addiction. However, some state policies may be more 

restrictive than federal law (see the answer to Question 21 as well as 

http://www.medsch.wisc.edu/painpolicy/2003_balance/). 

In general, pain patients fall into three groups. The first includes patients whose pain is 

not complicated by current addiction or a history of substance abuse. This group includes 

the majority of patients. 

The second group comprises those patients who have histories of substance abuse or 

addiction but are in established recoveries. Some of these patients are receiving 

substitution therapy (methadone or buprenorphine), and some are in drug-free recovery. 

It is prudent to consult with a specialist in addiction medicine when considering longterm opioid therapy for patients who fall into this group. Therapy for patients in this 

group typically includes more controls than does therapy for those with no such history. 

The third group, which includes those who are actively abusing substances, poses the 

greatest challenge. These patients require care of an advanced nature, which may not 

available in the primary care setting (see Question 23 for guidance about treating pain in 

patients who are currently abusing drugs, and Question 26 regarding the need to 

distinguish between the use of methadone for analgesia or substitution treatment). 

Referral of such patients to an addiction medicine specialist is appropriate (see state lists 

of addiction medicine specialists at www.asam.org).

Relevant Resources: 

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37

Compton, P., J. Darakjian, and K. Miotto (1998). Screening for addiction in patients with 

chronic pain and “problematic” substance use: evaluation of a pilot assessment 

tool. Journal of Pain and Symptom Management 16 (6): 355–363. 

Dunbar, S. A., and N. P. Katz (2001) Chronic opioid therapy for nonmalignant pain in 

patients with a history of substance abuse: report of 20 cases. Journal of Pain and 

Symptom Management 11 (3): 163–171. 

Gilson, A. M., and D. E. Joranson (2002) U.S. policies relevant to the prescribing of 

opioid analgesics for the treatment of pain in patients with addictive disease. 

Clinical Journal of Pain 18 (4 suppl): S91–S98. (Available at 

http://www.medsch.wisc.edu/painpolicy/publicat/02cjpn/index.htm.) 

23. What strategies can be used to treat pain successfully in patients who 

are actively abusing drugs? 

Federal law and regulations do not prohibit the use of opioids to treat pain if a patient is 

abusing controlled substances. However, state policies vary with respect to this therapy. 

Some states’ policies discourage, if not prohibit, physicians from prescribing opioid 

analgesics to patients whom they know or should know are using controlled substances 

for nontherapeutic purposes (see answer to Question 21). 

Using opioids to treat pain in such patients is very challenging. Physicians who proceed 

with this treatment should consider the following suggestions: 

• Refer the patient to an addiction medicine specialist for concurrent treatment. 

• Work closely with the addiction medicine specialist to coordinate the patient’s 

care. 

• Use a written agreement to outline treatment plan, including expectations and 

consequences. 

• Structure the treatment in a manner that maintains the safety of the patient, and 

increases both the patient’s ability to maintain control and the clinician’s ability to 

identify medication misuse. Depending on the specifics of the case, this structure 

may include the prescribing of small quantities, frequent visits, the use a single 

drug (typically a long-acting opioid), pill counts, the use of a single pharmacy, 

defined contacts with historians other than the patient (e.g., family members or 

employers), required attendance at a drug-treatment program, and regular 

screening of urine toxicology (to provide evidence of therapeutic adherence and 

non-use of other drugs). The structure of the treatment plan should be tailored to 

reflect the clinician’s assessment of the severity of drug abuse risk. Clear and 

regular communication between the clinician and the patient is an extremely 

valuable part of the treatment plan. 

Continued drug abuse despite repeated interventions may, in some cases, indicate the 

need to discontinue prescribing of potentially abusable drugs, and in other cases, provide 

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38

the impetus for termination of the physician-patient relationship. The clinician should be 

prepared to respond in these ways, and should understand both the options for nondrug 

therapies and the approach to termination without abandonment. 

Relevant Resources: 

Dunbar, S. A., and N. P. Katz (2001). Chronic opioid therapy for nonmalignant pain in 

patients with a history of substance abuse: report of 20 cases. Journal of Pain and 

Symptom Management 11 (3): 163–171. 

Gilson, A. M., and D. E. Joranson (2002). U.S. policies relevant to the prescribing of 

opioid analgesics for the treatment of pain in patients with addictive disease. Clinical 

Journal of Pain 18 (4 suppl): S91–S98. (Available at 

http://www.medsch.wisc.edu/painpolicy/publicat/02cjpn/index.htm.) 

Gourlay, D., H.A. Heit, and Y. Caplan (2002). Urine drug testing in primary care, 

dispelling the myths & designing strategies. California Academy of Family 

Physicians (CAFP). PharmaCom Group, Inc. Stamford, CT. (Available at 

http://www.familydocs.org/UDT.pdf ) 

Heit, H.A., and D. Gourlay (2004). Urine drug testing in pain medicine. Journal of Pain 

and Symptom Management 27 (3): 260-67. 

Savage, S. R. (2002). Assessment for addiction in pain-treatment settings. Clinical 

Journal of Pain 18: S28–S38. 

Savage, S. R. (2003). Principles of pain management in the addicted patient. In A. W. 

Graham, T. K. Schultz, M. F. Mayo-Smith et al. (eds.), Principles of Addiction 

Medicine (3rd ed.). Chevy Chase, MD: American Society of Addiction Medicine, 

Inc., pp. 1405–1419. 

Wesson, D., W. Ling, and D. E. Smith (1993). Prescription of opioids for treatment of 

pain in patients with addictive disease. Journal of Pain and Symptom 

Management 8: 289–296. 

 

SECTION VI 

OTHER LEGAL AND REGULATORY CONSIDERATIONS 

24. What requirements must physicians and pharmacists meet to comply 

with federal and state laws regulating opioids? 

For a physician to apply for a federal controlled substances registration to administer, 

prescribe, and/or dispense controlled substances, the physician must be licensed to 

practice medicine. In addition, some states require a state controlled substance 

registration. 

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39

If a physician loses or has restrictions placed upon his or her state-granted authority to 

use controlled substances, or is convicted of a drug-related felony or has lost his or her 

authority to participate in federal health care programs, there may be a legal impact on 

the physician’s DEA registration status. 

Physicians are legally authorized to administer, dispense, and/or prescribe controlled 

substances only for legitimate medical purposes, and the prescription must be issued in 

the usual course of a professional practice in the context of a doctor/patient relationship. 

DEA regulations (http://www.access.gpo.gov/nara/cfr/) affecting prescriptions include 

the following: 

• Schedule II prescriptions must be signed by the physician or nurse practitioner 

unless there is an emergency. 

• In the case of a bona fide emergency, the physician may telephone a pharmacy 

and authorize a prescription; however, a signed prescription must be forwarded to 

the pharmacy within seven days to account for the emergency prescription. 

• Schedule II prescriptions may not be refilled; however, a physician may prepare 

multiple prescriptions on the same day with instructions to fill on different dates. 

• Prescriptions written for controlled substances in schedules III, IV, and V may be 

refilled up to five times within six months. They may be telephoned or 

transmitted via facsimile to the pharmacy. Office staff may communicate the 

information to the pharmacy when acting as an agent of the registered physician. 

• The amount of a controlled substance prescription is not limited by federal 

regulations to a maximum quantity or a specific period, although some states do 

have such limitations. 

• Federal regulations do not require physicians to maintain prescribing records for 

controlled substances, although many states do. 

Federal regulations are being developed that will provide a legal basis for the secure 

transmission of prescription information electronically, including via the Internet, 

between physicians and pharmacies. Practitioners should also be aware that an individual 

state’s requirements for controlled substance prescriptions might be more restrictive than 

federal provisions. 

Dispensing physicians are also subject to the following DEA regulations: 

• Physicians who purchase controlled substances or who receive controlled 

substances as complimentary samples must maintain records to account for the 

receipt and use of the controlled substances.

• Physicians must physically inventory the drugs once every two years and have a 

copy of the inventory available for inspection by DEA diversion investigators. 

• An official DEA order form must be used to obtain or transfer Schedule II drugs. 

The records of receipt and distribution (dispensing) must clearly identify the 

source of the drugs and the recipient (patient). 

These are the basic requirements. Physicians should consult with DEA field offices if 

they have questions about the separate registration needed for the use of opioids to treat 

39 
40

opioid-dependent patients, or if they have multiple offices or special situations that 

require clarification. A list of the DEA’s field offices with staff contacts can be found at 

the DEA diversion website, http://www.deadiversion.usdoj.gov/. 

Pharmacists filling a prescription for controlled substances have a corresponding 

responsibility under the law to ensure that the prescription was written by a properly 

authorized prescriber and that it was written for a valid medical purpose. Pharmacists 

must be familiar with both state and federal requirements and are encouraged to 

document their efforts to ensure they have fulfilled their responsibilities under the law. 

They are also encouraged to develop a working relationship with their state pharmacy 

board (contact information can be found at http://www.nabp.net/) and DEA 

representatives to achieve open channels for communication. Finally, pharmacists are 

encouraged to read the DEA’s Pharmacist Manual for guidance about the Controlled 

Substances Act and its implementing regulations, at 

http://www.deadiversion.usdoj.gov/pubs/manuals/index.html.

Relevant Resources: 

Good, P. M. (2003). DEA Policy Concerning the Legality of a Practitioner Issuing 

Several Schedule II Prescriptions on the Same Date for the Same Medication for 

a Stable Patient. Letter from Chief of the Liaison and Policy Section, DEA 

Office of Diversion Control, to Dr. Howard Heit, January 31. (Available at 

http://www.asam.org/pain/federal_regulations_for_prescrib.htm.) 

Joranson, D. E. (1993). Guiding principles of international and federal laws pertaining to 

medical use and diversion of controlled substances. In J. R. Cooper, D. J. 

Czechowicz, S. P. Molinari, and R. C. Petersen (eds.). Impact of Prescription Drug 

Diversion Control Systems on Medical Practice and Patient Care: Monograph 131. 

Rockville, MD: U.S. Department of Health and Human Services, Public Health 

Service, National Institutes of Health, National Institute on Drug Abuse, pp. 18–34. 

(Available at http://www.medsch.wisc.edu/painpolicy/publicat/93nida.htm.) 

Public Policy Statement on the Rights and Responsibilities of Healthcare Professionals in 

the use of Opioids for the Treatment of Pain (2004) Adopted by the American Society 

of Addiction Medicine’s Public Policy Committee, the American Academy of Pain 

Medicine, and the American Pain Society. (http://asam.org/) Power Point slides of

Federal Regulations of Prescribing a Controlled Substance. 

25. What regulations do physicians need to know and observe when 

prescribing opioid analgesics for pain? 

State level: The privilege of prescribing drugs, including controlled substances, is based 

on having a license to practice medicine or osteopathy issued by a licensing and 

disciplinary board in each of the states where a practitioner wishes to practice. Some

states also require an additional registration for prescribing controlled substances. 

(information about how to contact state controlled substances authorities can be obtained 

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41

at http://www.nascsa.org/HOME.htm.) State statutes and regulations list prohibited 

controlled substances activities. Most states also have issued a regulation, guideline, or 

policy statement that provides guidance and, in some cases, a standard of care, for 

prescribing opioid analgesics for pain 

(http://www.medsch.wisc.edu/painpolicy/matrix.htm). 

Federal level: Once a practitioner has satisfied state requirements of licensure and 

registration, the DEA issues a federal controlled substances registration, enabling the 

prescribing of controlled substances for legitimate medical purposes. The specific 

requirements for prescribing controlled substances are listed in Title 21, Parts 1300–1999 

of the Code of Federal Regulations (http://www.access.gpo.gov/nara/cfr/cfr-tablesearch.html#page1) and are summarized in a presentation format 

(http://www.asam.org/pain/federal_regulations_for_prescrib.htm). Further information 

about controlled substances and prescribing requirements can be obtained at 

http://www.deadiversion.usdoj.gov/.

Prescribing opioids (referred to as narcotic drugs in federal regulations) for pain, 

including “intractable” pain, is lawful when there is a physician-patient relationship 

established by an examination, a treatment plan, and medical records.

26. Can methadone be used for pain control, and, if so, is a clinician 

required to have a special license to prescribe it? 

Methadone is approved by the Food and Drug Administration as safe and effective for 

medical use as an analgesic. Although its low cost and effectiveness in some settings is 

driving increasing use, it is important to emphasize that its unique pharmacology is 

associated with a relatively higher risk of unintentional toxicity. This relates to a long 

and variable half-life and the potential for a greater-than-expected potency when a switch 

is made from an alternative opioid. The safe use of methadone requires knowledge of 

these characteristics and an ability to monitor therapy closely after it is initiated or 

changed. 

State and federal regulations do not restrict the use of methadone to treat pain. It is 

recommended that the physician note in the chart that the methadone is for analgesia 

only. Any physician who has a DEA registration for controlled substances that includes 

Schedule II can prescribe methadone, just as any other Schedule II opioid medication, for 

pain. An additional separate DEA registration is needed only when dispensing 

methadone for outpatient maintenance or detoxification, not when prescribing it for pain, 

and the supply and records must be separate from its use for analgesia. 

Relevant Resources: 

Anderson, R., et al. (2001). Accuracy in equianalgesic dosing. Conversion dilemmas. 

Journal of Pain and Symptom Management 21 (5): 672–687. 

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42

Dole, V. P. (1988). Implications of methadone maintenance for theories of narcotic 

addiction. Journal of the American Medical Association 260: 3025–3029. 

Garrido, M. J., and I. F. Troconiz (1999). Methadone: A review of its pharmacokinetic/ 

pharmacodynamic properties. Journal of Pharmacological and Toxicological 

Methods 42 (2): 61–66. 

Gazelle, G., and P. G. Fine (2003). Methadone for the treatment of pain #75. Journal of 

Palliative Medicine 6 (4): 620–621. 

Pereira, J., et al. (2001). Equianalgesic dose rations for opioids. A critical review and 

proposals for long-term dosing. Journal of Pain and Symptom Management 22 

(2): 672–687. 

27. Under what circumstances will the federal Drug Enforcement 

Administration (DEA) investigate and prosecute a doctor or pharmacist or 

refer cases to other agencies? 

According to the DEA, the vast majority of DEA-registered practitioners are honest, 

ethical people who strive to satisfy their legal and regulatory responsibilities. The targets 

of DEA complaint investigations are the small number of practitioners who operate with 

criminal intent. For a physician to be convicted of illegal sale, the authorities must show 

that the physician knowingly and intentionally prescribed or dispensed controlled 

substances outside the scope of legitimate practice. 

The DEA focuses its limited manpower and resources on the most flagrant violators. To 

understand the DEA’s intent and practices, it is important to keep in mind that: 

 State and local agencies, including licensing boards, police departments, Medicaid 

fraud units, etc., also conduct investigations related to controlled substance 

diversion, fraud, or improper medical practice. 

 The DEA investigates only a small number of physicians2

 (for example, during 

fiscal year 2003, the DEA initiated a total of 732 investigations concerning 

doctors, 584 of which resulted in some form of sanction. In short, approximately 

0.075% of all physicians registered with the DEA were the subject of some type 

of DEA investigation during the year.) 

 A significant number of theses investigations were initiated because the physician 

in question was no longer licensed to practice medicine and was therefore no 

longer entitled to DEA registration. In 424 such cases, the physicians elected to 

 

2

 The term “physician” includes dentists, osteopaths, podiatrists, veterinarians, medical doctors and a small

number of mid-level practitioners. In May of 2004, there were 972,008 practitioners registered with the 

DEA. Medical doctors account for 71 percent of the total physicians registered with the DEA. Osteopaths 

account for another 4.6 percent. Dentists account for 13.3 percent. Veterinarians account for 5.1 percent. 

42 
43

surrender their DEA registrations. This represents 72.7% of the 584 “sanctions” 

imposed by the DEA. 

 In 34 cases, physicians’ DEA registration was revoked. 

 During fiscal year 2003, the DEA arrested 50 physicians whose activities were 

deemed to be knowingly and intentionally beyond the scope of medical practice, 

that is, criminal. This represents 0.005% of physician registrants. 

 Most frequently, the DEA responds to complaints, allegations of diversion, or 

some other impropriety. Depending on the content, most of these are referred to 

state medical boards or local police. 

 Joint investigations may occur when local police and state or federal agencies 

seek out the DEA for its expertise. 

 The DEA does use administrative sanctions (for example, Letters of Admonition, 

Memoranda of Understanding) rather than criminal investigations when the 

complaint or allegation relates to such activities as faulty record keeping. In fact, 

of the 584 actions mentioned above taken during fiscal year 2003, 67 were of this 

nature. 

Following receipt of information concerning a physician or pharmacist, an investigator 

would make inquiries to ascertain the validity of the allegation. Practitioners should be 

aware that a preliminary inquiry does not necessarily mean that wrongdoing has 

occurred. The nature of the inquiry varies based on the type of information received. 

For example, if the allegation pertains to a doctor prescribing controlled substances 

without conducting medical examinations, the investigator would be required to obtain 

information about the doctor’s prescribing habits. In the absence of a prescriptionmonitoring program, investigators would be required to visit pharmacies to review 

prescription files. If the complaint pertained to a pharmacist, a review of the pharmacy’s 

prescriptions and possibly an audit would be conducted. 

An investigation that uncovers inappropriate activity may be resolved through a variety 

of administrative, civil, or criminal actions. Factors that are considered when law 

enforcement personnel are determining what action to take include the opinion of medical 

experts, the egregiousness of the violations, and whether the practitioner is thought to 

have engaged in the violation knowingly or intentionally. The legal system does not 

allow practitioners to consciously disregard indications that illegal drug-related activities 

might be occurring. 

A DEA criminal investigation may involve a search warrant, but only if the DEA has 

sufficient evidence to convince a federal judge or magistrate that it is warranted. 

Although a search is not a charge and may not result in an arrest, it is a very serious 

matter, and normal police protocol involves control of the premises and safety of the 

participants. 

Cases generally would be referred to other agencies if a practitioner’s activities are found 

to be outside the course of professional practice, but not significant enough to warrant 

federal prosecution.

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28. Should efforts to address diversion avoid interfering with medical 

practice and patient care? 

To avoid interfering with legitimate medical practice and patient care, there needs to be a 

balanced approach between physicians and regulators. The principle of balance, which 

should be fundamental to national and state drug control policy, asserts that efforts to 

prevent abuse of opioid analgesics, while necessary, should not interfere with medical 

practice and patient care. Health professionals should avoid contributing to diversion, 

and law enforcement and regulatory authorities should avoid interfering in pain 

management. 

A 2003 comprehensive evaluation of all relevant federal and state policies according to 

the principle of balance can be found at 

http://www.medsch.wisc.edu/painpolicy/2003_balance/. 

Key law enforcement and regulatory organizations endorse the principle of balance. For 

example: 

• In 1998, the Federation of State Medical Boards of the U.S. issued model 

guidelines that state regulatory boards can use to encourage better pain 

management, address physicians’ concerns about regulatory scrutiny, and 

maintain compliance with existing legal requirements for prescribing 

(http://www.fsmb.org). These guidelines have been endorsed by the National 

Association of Boards of Pharmacy, the National Association of State Controlled 

Substances Authorities, and the U.S. Drug Enforcement Administration. The 

guidelines have since been revised as a model policy in 2004. 

• In 2001, the DEA and many leading health care groups issued a joint statement, 

titled “Promoting Pain Relief and Preventing Abuse of Pain Medications: A 

Critical Balancing Act.” It has been endorsed by 43 organizations and can be 

accessed at http://www.lastacts.org/briefingoct01/endorse.html. 

• In its 2003 report, “Improving End-of-Life Care: The Role of Attorneys General,” 

the National Association of Attorneys General stated its support for the concept of 

balance, recognizing the need for a positive regulatory environment for pain 

management and emphasizing that law enforcement efforts should not affect 

provision of patient care. 

For law enforcement to stop diversion, it is necessary to accurately identify the sources of 

diversion. The sources are individuals who unlawfully divert prescription controlled 

substances to other than legitimate medical purposes. When an individual is suspected of

robbing a pharmacy, there is little chance that apprehension and prosecution will interfere 

with medical practice and patient care; indeed, solving such crimes protects good medical 

care. When the suspect is a physician, pharmacist, or patient, the need for law enforcers 

to distinguish the medical use of opioid analgesics to manage pain from unlawful 

activities is critically important. This FAQ presents information that can be valuable to 

enforcement personnel in such situations. In some cases, consultation with a pain 

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medicine specialist may be useful to law enforcement and regulatory officials (see answer 

to Question 29). 

Relevant Resources: 

Drug Enforcement Administration, Last Acts, Pain & Policy Studies Group et al. (2001). 

Promoting Pain Relief and Preventing Abuse of Pain Medications: A Critical 

Balancing Act. Washington, DC: Last Acts. (Available at 

http://www.medsch.wisc.edu/painpolicy/dea01.htm.) 

Federation of State Medical Boards of the United States Inc. (1998). Model Guidelines 

for the Use of Controlled Substances for the Treatment of Pain. Euless, TX: 

Federation of State Medical Boards of the United States Inc. (Available at 

http://www.fsmb.org.) 

Federation of State Medical Boards of the United States Inc. (2004). Model Policy for 

the Use of Controlled Substances for the Treatment of Pain. Dallas, TX: 

Federation of State Medical Boards of the United States Inc. (Available at 

http://www.fsmb.org.) 

Joranson, D. E. (1993). Guiding principles of international and federal laws pertaining to 

medical use and diversion of controlled substances. In J. R. Cooper, D. J. 

Czechowicz, S. P. Molinari, and R. C. Petersen (eds.), Impact of Prescription Drug 

Diversion Control Systems on Medical Practice and Patient Care: Monograph 131. 

Rockville, MD: U.S. Department of Health and Human Services, Public Health 

Service, National Institutes of Health, National Institute on Drug Abuse, pp. 18—34. 

(Available at http://www.medsch.wisc.edu/painpolicy/publicat/93nida.htm.) 

National Association of Attorneys General. (2003). Improving End-of-Life Care: The 

Role of Attorneys General. Washington, DC: National Association of Attorneys 

General. 

Pain & Policy Studies Group. (2003). Achieving Balance in Federal and State Pain 

Policy: A Guide to Evaluation (2nd ed.). Madison, WI: University of Wisconsin 

Comprehensive Cancer Center. (Available at 

http://www.medsch.wisc.edu/painpolicy/2003_balance/.) 

29. When should a law enforcement officer turn to a pain specialist for 

advice? 

The timing of a consultation with a pain specialist varies, according to the information 

needed by an investigator. The identified specialist should have current knowledge about 

pain management, including the use of opioids. In consulting with a pain specialist, an 

investigator may seek confirmation that prescriptions are being issued for legitimate 

medical purposes and that the care being provided is within the bounds of professional 

practice. There is great potential for misunderstanding at the interface of pain treatment, 

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addiction, and the therapeutic use of controlled substances. Consequently, investigators 

are encouraged to consult a pain specialist or addiction medicine specialist whenever 

there are questions about using controlled substances to treat pain. The following 

questions are examples: 

• How can you tell this patient has a chronic pain problem?

• Is there justification for the drugs that have been prescribed?

• Are the prescribed amounts appropriate?

• If a patient is displaying drug-seeking behaviors, is this a sign of 

undertreated pain, addiction, or involvement in diversion?

Relevant Resource: 

Andrew, L. B. (2003). The ethical medical expert witness. Federation Bulletin, Journal 

of Medical Licensure & Discipline 89 (3): 125—131. 

30. Do the number of patients in a practice who receive opioids, the 

number of tablets prescribed for each patient, or the duration of therapy 

with these drugs by themselves indicate abuse or diversion? 

The number of patients in a practice who receive opioids, the number of tablets 

prescribed for each patient, and the duration of therapy with these drugs do not, by 

themselves, indicate a problem, and they should not be used as the sole basis for an 

investigation by regulators or law enforcement. However, these factors, combined with 

others, may indicate that prescriptions are being issued or dispensed for other than 

legitimate medical purposes or not in the course of professional practice. Characteristics 

of a practitioner or pharmacy that warrant further inquiry that could lead to an 

investigation include: 

• A large proportion of prescriptions being paid for in cash. 

• Large distances between the doctor, patients, and pharmacy, particularly if a 

sizable proportion of a doctor’s prescriptions are being filled at a pharmacy not 

conveniently located to either the doctor or the patients. 

• Drugs and doses being prescribed are not individualized. 

• One physician writing multiple prescriptions for numerous patients that are filled 

consecutively in one pharmacy, indicating that either one person is presenting 

multiple prescriptions, or several people are filling similar prescriptions at the 

same time. 

• A high frequency of prescriptions to replace lost prescriptions or medications. 

• Frequent premature renewal or refilling of prescriptions. 

• Frequent prescribing of unusual combinations of drugs, such as stimulants and 

depressants. 

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APPENDIX A 

Abuse: A term used in the psychiatric (“Substance Abuse”) nomenclature to describe a 

maladaptive pattern of substance use, not related to a therapeutic purpose, resulting in 

recurrent and significant adverse consequences. Repeated nontherapeutic use of a 

substance causes harm that can manifest in physical or social impairment but does not 

meet the criteria of compulsive use despite harm. In common parlance, “abuse” may also 

refer to the use of a substance, including a controlled prescription drug, that is outside of 

social norms (including the norm of adherence to prescribed drug treatments). 

Addiction: A primary, chronic, neurobiological disease, with genetic, psychosocial, and 

environmental factors influencing its development and manifestations. It is characterized 

by behaviors that include one or more of the following: impaired control over drug use, 

compulsive use, continued use despite harm, and craving. Addiction is considered distinct 

from, though sometimes interrelated with, tolerance and physical dependence. Neither 

physical dependence nor tolerance to prescribed drugs is sufficient evidence of addiction. 

Unlike tolerance or physical dependence, addiction is not a predictable effect of drug 

exposure but represents an idiosyncratic adverse reaction in biologically and psychosocially 

vulnerable individuals, for which drug exposure is only one of the etiologic factors. Simple 

exposure to opioids does not produce addiction. 

Narcotic: A legal term that refers to all those substances covered by the Single 

Convention on Narcotic Drugs, 1961, and the 1972 Protocol amending that Convention, 

including opiates, opioids as well as cocaine and marijuana. 

Opiate: A substance that is produced from the poppy plant, such as codeine and 

morphine. 

Opioid: A scientific term that refers to both natural and synthetic drugs whose effects 

are mediated by specific receptors in the central and peripheral nervous systems, 

including codeine, morphone, oxycodone, and fentanyl. 

Physical Dependence: A state of adaptation that is manifested by a specific withdrawal 

syndrome that can be produced by abrupt cessation of dosing, rapid dose reduction, 

and/or administration of an antagonist. Most patients on long-term opioid therapy 

develop physical dependence, which is not predictive of addiction. 

Pseudoaddiction: A term used to describe an iatrogenic phenomenon in which a patient 

with undertreated pain is perceived by health care professionals to exhibit behaviors 

similar to those seen in addiction but is not true addiction. Patients may become focused 

on obtaining medications, may “clock watch,” and may otherwise seem inappropriately 

“drug seeking.” The term has been used to describe even such behaviors as illicit drug 

use and deception, if they appear to be primarily driven by the patient’s efforts to obtain 

relief. It is believed that pseudoaddiction can be distinguished from true addiction 

because the behaviors resolve and do not recur when pain is effectively treated. 

Clinicians should be aware that abuse or addiction, and pseudoaddiction can co-exist, and 

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a pattern of maladaptive drug-related behaviors could signal the presence of addiction, 

undertreated pain, or both. 

Tolerance: Tolerance is a state of adaptation in which exposure to a drug induces changes 

that result in a diminution of one or more of the drug's effects over time. Tolerance often 

occurs in the absence of addiction, as when drugs are used therapeutically over a period of 

time, and usually requires increased doses of the drug to produce the pharmacologic effects 

initially resulting from smaller doses. 

* The definitions of addiction, physical dependence, and tolerance are from American Academy of Pain Medicine, 

American Pain Society, and American Society of Addiction Medicine (2001). Definitions related to the use of opioids 

for the treatment of pain

Relevant Resources: 

American Academy of Pain Medicine, American Pain Society, American Society of 

Addiction Medicine (2001). Definitions Related to the Use of Opioids for the 

Treatment of Pain. Glenview, IL: AAPM, APS, ASAM. (Available at 

http://www.ampainsoc.org/advocacy/opioids2.htm.) 

Savage, S. R., D. E. Joranson, E. C. Covington et al. (2003). Definitions related to the 

medical use of opioids: Evolution towards universal agreement. Journal of Pain and 

Symptom Management 26 (1): 655–667. (Available at 

http://www.medsch.wisc.edu/painpolicy/biblio.htm.) 

Weissman, D. E., and J. D. Haddox (1989). Opioid pseudo-addiction—an iatrogenic 

syndrome. Pain 36: 363–366. 

Heit, H.A., (2003) Addiction, Physical Dependence, and Tolerance: Precise Definitions 

to Help Clinicians Evaluate and Treat the Patient with Chronic Pain. Journal of 

Pain and Palliative Care Pharmacotherapy.