ILLICIT OPIOIDS

Office of National Drug 

Control Policy and Other 

Agencies Need to Better 

Assess Strategic Efforts

Gretta L. Goodwin, Director, 

Homeland Security and Justice

Testimony 

Before the Committee on Oversight 

and Government Reform, 

House of Representatives

For Release on Delivery 

Expected at 11:00 AM ET

Thursday, May 17, 2018

GAO-18-569T

United States Government Accountability Office
Page 1 GAO-18-569T Illicit Opioids

Chairman Gowdy, Ranking Member Cummings, and Members of the 

Committee:

I am pleased to be here today to discuss GAO’s recent work related to 

combating the opioid problem and the role of the Office of National Drug 

Control Policy (ONDCP). Though drug abuse in our nation is not a new 

phenomenon, the scale and impact of illicit drug use in this country has 

reached new levels. Deaths from drug overdoses have risen steadily over 

the past two decades and are the leading cause of death due to injuries in 

the United States. In fact, according to the Centers for Disease Control 

and Prevention (CDC), drug overdose deaths surpass the annual number 

of traffic crash fatalities, as well as deaths due to firearms, suicide, and 

homicide, respectively. In 2016, the most recent year for which national 

data are available, nearly 64,000 Americans died from drug overdoses, or 

approximately 175 people every day.

Recently, there has been a rise in opioid use in the United States 

involving the abuse of prescription drugs and more traditional illicit 

opioids, such as heroin. Coinciding with this increase, there also has 

been a significant increase in the use of man-made (synthetic) opioids, 

such as fentanyl and fentanyl analogues, which is a main contributor to 

the spikes in overdose deaths. For example, according to CDC, of the 

nearly 64,000 drug overdose deaths in 2016, nearly two thirds of the 

deaths involved opioids. Of those opioid-related overdose deaths, more 

than 15,000 involved heroin and more than 19,000 involved synthetic 

opioids such as fentanyl. Public health and law enforcement experts 

expect this number to continue to increase.

The Administration has taken certain actions to address the crisis. In 

March 2017, the President issued Executive Order 13784 establishing a 

commission to study the scope and effectiveness of the federal response 

to drug addiction and the opioid crisis.1 The President’s Commission on 

Combating Addiction and the Opioid Crisis issued a final report in 

November 2017, making a number of recommendations to the President 

to enhance the federal government’s response to the opioid problem. 

Further on October 26, 2017, the President directed the Acting Secretary 

of Health and Human Services (HHS) to declare the drug demand and 

opioid crisis to be a public health emergency.2 That same day, the Acting 

 1

Exec. Order No. 13,784, 82 Fed. Reg. 16,283 (Mar. 29, 2017).

2

See 42 U.S.C. § 247d. HHS has since renewed the October 26, 2017 determination 

twice — on January 19, 2018, and April 20, 2018 —for additional 90-day periods.
Page 2 GAO-18-569T Illicit Opioids

HHS Secretary declared the public health emergency under section 319 

of the Public Health Service Act.3

While multiple agencies have a role in drug prevention, treatment, and 

supply reduction, ONDCP is responsible for, among other things, 

overseeing and coordinating the implementation of national drug control 

policy across the federal government to address illicit drug use (see 

appendix I).4 In this role, the Director of ONDCP is required annually to 

develop a National Drug Control Strategy to reduce illicit drug use through 

programs intended to prevent or treat drug use or reduce the availability 

of illegal drugs.5 ONDCP is also responsible for developing a National 

Drug Control Program Budget proposal for implementing the Strategy.6

When we last testified to this committee on this issue in July 2017, 

ONDCP officials had told us that work was underway to develop a new 

Strategy.7 As of today ONDCP has not issued a new strategy, and based 

on publicly available health data, our analysis shows that the majority of 

the former strategy’s goals have yet to be fully achieved.

My testimony today is based on our March 2018 report examining illicit 

opioids and federal agencies’ efforts to combat them.8 In particular, I will

highlight our findings pertaining to (1) federal agencies’ specific opioidrelated strategies and the extent to which each agency is measuring its 

performance; and (2) federal agencies’ efforts to enhance collaboration 

and information sharing to limit the availability of illicit opioids, ongoing 

challenges to doing this, and ONDCP’s role in enhancing such 

collaboration.

 3

GAO has recently begun work focused on the public health emergency declaration for 

opioids, including the actions that the declaration enables the government to take, and the 

actions that it has taken to date.

4

21 U.S.C. § 1702(a)(2).

5

21 U.S.C. §§ 1703(b), 1705(a).

6

21 U.S.C. § 1703(c).

7

GAO, Drug Control Policy: Information on Status of Federal Efforts and Key Issues for 

Preventing Illicit Drug Use, GAO-17-766T (Washington, D.C.: July 26, 2017).

8

GAO, Illicit Opioids: While Greater Attention Given to Combating Synthetic Opioids, 

Agencies Need to Better Assess their Efforts, GAO-18-205 (Washington, D.C.: March 29, 

2018).
Page 3 GAO-18-569T Illicit Opioids

Information on our scope and methodology can be found in the original 

March 2018 report. To assess more recent progress on attaining the 

goals contained in the National Drug Control Strategy, we used the same 

data sources that ONDCP uses to assess progress when it developed its 

original 2010 Strategy and did not independently assess the reliability of 

these data. We conducted the work on which this statement is based in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

In summary, we found that federal agencies have documented specific 

strategies to combat illicit opioids; however, many lack outcome 

measures, or those that are results-oriented. The five strategies we 

reviewed were:

(1) ONDCP’s Heroin Availability Reduction Plan (HARP), which was 

implemented in 2016. HARP aims to guide and synchronize 

interagency activities performed through ONDCP’s National 

Heroin Coordination Group to reduce the supply of heroin, 

fentanyl, and fentanyl analogues in the U.S. market.

(2) ONDCP’s High Intensity Drug Trafficking Areas (HIDTA) 

program’s Heroin Response Strategy (HRS) which began in 

August 2015. HRS establishes a cross-disciplinary initiative that 

brings public health and public safety partners together at the 

federal, state, and local level to reduce drug overdose fatalities 

and disrupt trafficking in illicit opioids.

(3) The Organized Crime Drug Enforcement Task Forces’ (OCDETF) 

National Heroin Initiative. OCDETF is a component of the 

Department of Justice (DOJ) and it began this initiative in 

December 2014 to support local and regional initiatives in 

disrupting the flow of heroin into communities in every OCDETF 

region across the country. The initiative aims to bring together 

otherwise disparate agencies, investigations, and information to 

develop a coordinated law enforcement action plan involving 

federal, state, tribal, and local authorities.
Page 4 GAO-18-569T Illicit Opioids

(4) The Attorney General’s Strategy to Combat the Opioid Epidemic, 

which began in September 2016 and rests on three pillars: 

prevention, enforcement, and treatment.

(5) The Drug Enforcement Administration’s (DEA) 360 Strategy, 

which began in November 2015. DEA is also a DOJ component 

and the goal of the 360 Strategy is to bring together three key 

DEA activities—enforcement operations, diversion control 

initiatives, and demand reduction efforts—under one strategy 

targeted toward opioids.

We have long reported on the importance of measuring program 

performance.9 Our prior reports and guidance have stated that 

performance measurement should evaluate both processes (outputs) and 

outcomes related to program activities. Specifically, we have noted that

output measures address the type or level of program activities 

conducted and the direct products or services delivered by a program, 

such as the number of presentations given, while outcome measures 

address the results of products and services, such as reductions in 

overdose deaths. Outcome measures can help in assessing the status of 

program operations, identifying areas that need improvement, and 

ensuring accountability for end results. However, of the five strategies we 

assessed, we found that only one—ONDCP’s HARP—included outcomeoriented performance measures. Two—HIDTA’s HRS; and DEA’s 360 

Strategy—included some type of performance measurement but these 

measurements were output instead of outcome-focused. Finally, two—the 

Attorney General’s Strategy to Combat the Opioid Epidemic and 

OCDETF’s National Heroin Initiative—did not include measures at all. For 

example, one of the stated goals in the HARP is to have “a significant 

reduction in the number of heroin-involved deaths in the United States 

due to a disruption in the heroin and fentanyl supply chains.” ONDCP 

measures their progress towards this goal, in part, using CDC’s cause of 

death data on heroin-involved overdose deaths. In contrast, DEA’s 360 

Strategy measures the number of participants in its activities (an output), 

for example, but it does not have goals or outcome-oriented measures in 

 9

GAO, Electronic Health Record Programs: Participation Has Increased, but Action 

Needed to Achieve Goals, Including Improved Quality of Care, GAO-14-207 (Washington, 

D.C.: March 6, 2014); GAO, Designing Evaluations: 2012 Revision, GAO-12-208G 

(Washington, D.C.: January 2012); GAO, Performance Measurement and Evaluation: 

Definitions and Relationships, GAO-11-646SP, (Washington, D.C.: May 2011); and GAO, 

Executive Guide: Effectively Implementing the Government Performance and Results Act,

GAO/GGD-96-118 (Washington, D.C.: June 1, 1996).
Page 5 GAO-18-569T Illicit Opioids

place to help officials understand what they are trying to achieve and 

whether the activities they have included in their strategy are yielding the 

desired results. Likewise, absent any measures at all, the Attorney 

General’s and OCDETF’s strategies make it difficult to set a course for its 

efforts and understand whether related efforts are having the intended 

impact.

During our review, federal agencies told us that it was difficult to set 

outcome-oriented performance measures for their respective strategies 

for a number of reasons, such as:

• the programs are being implemented in different locations that have 

unique needs and challenges;

• the federal government still does not have a complete understanding 

of the opioid problem; and

• the programs are time limited and outcomes are difficult to measure 

and achieve over a short time period.

However, as we stated in our report, without specific goals and outcomeoriented performance measures, federal agencies will not be able to truly 

assess whether their respective investments and efforts are helping them 

achieve the goals set out in their strategies. Further, while we 

acknowledged in our report that it may be difficult to single out individual 

agencies’ contributions to these activities, the stated goals of these 

strategies revolve around the collaboration among multiple agencies. 

Therefore, establishing outcome-oriented performance measures would 

enhance these agencies’ ability to assess whether these collaborative 

efforts are producing intended results. We recommended that DOJ, 

OCDETF, ONDCP, and DEA develop outcome-oriented performance 

measures for their respective strategies. ONDCP raised concerns about 

the recommendation, and DOJ did not concur with the recommendations 

for some of the reasons stated above. However, we continue to believe 

that our recommendations are valid and that finding meaningful ways to 

measure the effectiveness of these approaches will help ensure that the

invested resources are yielding intended results.

We also found that federal law enforcement agencies have expanded 

their collaboration with one another, as well as with state and local law 

enforcement officials and with public health officials. However, ongoing 

data related challenges have hampered their efforts. For example, each 

HIDTA that participates in HRS has a drug intelligence officer located in 

each state where the HIDTA operates to help share information across 
Page 6 GAO-18-569T Illicit Opioids

jurisdictions. Some HIDTAs have leveraged this increased coordination to 

better understand and respond to the opioid problem in their area. For 

example, our report discusses the RxStat Initiative in in the New 

York/New Jersey region, which consists of regular monthly meetings 

among 44 federal, state, and local government agencies to bridge the gap 

between public health agencies’ population-level view of the opioid 

problem and public safety agencies’ case-level view. HIDTA officials in 

the region reported that the initiative has been beneficial because it 

helped them understand the scope of the opioid abuse problem and 

target approaches in order to address it more effectively.

Despite these initiatives, officials from each of the six HIDTAs with whom 

we spoke during our review indicated that accessing and analyzing data 

on fatal and nonfatal overdoses continue to pose challenges to 

coordination, a view also shared by nearly all of the law enforcement and 

public health officials we interviewed. In particular, officials cited 

timeliness, accuracy, and the accessibility of overdose-related data as 

their primary concerns.

• With respect to timeliness, overdose data traditionally comes from the 

official cause of death listed on the death certificate that is prepared 

by medical examiners or coroners. However, toxicology test results 

can take months to obtain. Therefore, it is very difficult for law 

enforcement and public health officials to have timely data on 

overdose deaths so they can anticipate and respond to emerging 

trends.

• With respect to accuracy, law enforcement and public health officials 

we spoke with reported that some of the data on overdose deaths 

may be incomplete because medical examiners and coroners may not 

always test for synthetic opioids like fentanyl in their toxicology tests. 

This may be due to factors such as the lack of resources to conduct 

the test, the level of training of the person performing the autopsy, or 

there was no indication at the time of an autopsy that a fentanyl test 

was needed. An undercount of the number of overdose deaths may 

affect the scope of law enforcement and public health officials’

response.

• With respect to accessibility, much of the relevant data for law 

enforcement and public health officials has legal restrictions to protect 

patient privacy on how the data can be shared and analyzed. For 

example, access to data from state Prescription Drug Monitoring 

Programs, which monitor controlled substance prescriptions 

dispensed by pharmacies and doctors, may be restricted based on 
Page 7 GAO-18-569T Illicit Opioids

state law. Separately, law enforcement and public health officials we 

spoke with indicated a need for data on non-fatal overdoses to help 

them identify and investigate the sources of these drugs in their 

communities and to be able to direct people to available drug 

treatment programs. They particularly noted that data of this kind 

would provide an early warning system for law enforcement and 

public health officials to anticipate and respond to emerging drug 

overdose trends.

As we noted in our report, ONDCP is uniquely positioned to collaborate 

with its law enforcement and public health counterparts to identify 

solutions to these data challenges. As such, we recommended that 

ONDCP lead a specific review on ways to improve the timeliness, 

accuracy, and accessibility of fatal and non-fatal overdose data that 

provide critical information to understand and respond to the opioid 

epidemic. In response, ONDCP neither agreed nor disagreed with our 

recommendation but did say it would consider it. During our review, the 

lack of timely, accurate, and accessible information was one of the most 

pervasive concerns we heard from the public health and law enforcement 

officials with whom we spoke. Given ONDCP’s role in framing a national 

strategy and supporting the HIDTAs, we continue to believe the agency 

should bring together law enforcement and public health officials to 

improve national-level data and support the data improvement efforts 

occurring at the state and local levels.

Chairman Gowdy, Ranking Member Cummings, and Members of the 

Committee, this completes my prepared statement. I would be pleased to 

respond to any questions that you may have at this time.

If you or your staff have any questions about this testimony, please 

contact Gretta L. Goodwin at (202) 512-8777 or goodwing@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this statement. Individuals 

making key contributions to this testimony include Joy Booth (Assistant 

Director), Julia Vieweg (Analyst-in-Charge), Eric Warren, Kisha Clark, 

Kevin Reeves, Amanda Miller, Billy Commons, and Jan Montgomery. Key 

contributors to the prior work on which this testimony is based are listed in 

the product.

GAO Contact and 

Staff 

Acknowledgements
Appendix I: Examples of Federal Agencies 

Involved in Combating Drug Trafficking and 

Drug Use

Page 8 GAO-18-569T Illicit Opioids

Table 1: Examples of Federal Agencies Involved in Combating Drug Trafficking and Drug Use 

Agency Tasks

Department of Defense (DOD)

Joint Interagency Task Force West & Joint Interagency Task 

Force South

• Detects and monitors illicit drug trafficking, and facilitates 

international and interagency interdiction

National Guard • Supports the detection, interdiction, disruption, and curtailment of 

drug trafficking activities and use at all levels of government, 

through use of military skills and resources

Department of Health & Human Services (HHS)

Centers for Disease Control and Prevention (CDC) • Detects and responds to new and emerging health threats 

causing death and disability for Americans

• Uses science and technology to prevent disease

• Promotes healthy and safe behaviors, communities, and 

environment

Food and Drug Administration (FDA) • Protects public health by ensuring the safety, efficacy, and 

security of human and veterinary drugs, biological products, and 

medical devices

• Coordinates with DEA on scheduling drugs under the Controlled 

Substances Acta

• Collaborates with CBP to prevent the importation of unapproved 

drugs and investigates their distribution

• Inspects registered facilities that manufacture drugs approved for 

marketing in the United States

National Institutes of Health • Supports research to protect and improve public health, prevent 

disease, and expand medical knowledge

• Includes the National Institute on Drug Abuse (NIDA), which 

supports research on the causes and consequences of drug 

misuse

Substance Abuse and Mental Health Services Administration 

(SAMHSA)

• Develops best practices and expertise in preventing and treating 

mental and substance use disorders.

• Evaluates and disseminates evidence-based behavioral health 

practices

• Supports behavioral health programs and services with grant 

funding

• Supports behavioral health with data from national surveys and 

surveillance

Department of Homeland Security (DHS)

Customs and Border Protection (CBP) • Manages and controls border, including the enforcement of 

customs, immigration, border security, and agricultural laws. This 

includes screening inbound cargo at ports of entry, including 

international mail and express consignment carrier items

• Collaborates with FDA to prevent the importation of unapproved 

drugs and investigates their distribution

U.S. Coast Guard • Conducts maritime drug interdiction

• Contributes vessels and aircraft deployed to disrupt illicit drug 

smuggling

Appendix I: Examples of Federal Agencies 

Involved in Combating Drug Trafficking and 

Drug Use
Appendix I: Examples of Federal Agencies 

Involved in Combating Drug Trafficking and 

Drug Use

Page 9 GAO-18-569T Illicit Opioids

Agency Tasks

Department of Homeland Security (DHS)

U.S. Immigration and Customs Enforcement (ICE) • Enforces federal laws governing border control, customs, trade, 

and immigration

• ICE’s Homeland Security Investigations (HSI) investigates the 

illegal movement of goods within and out of the U.S., including 

narcotics

Department of Justice (DOJ)

Criminal Division • Develops, enforces, and supervises application of federal criminal 

laws except those assigned to other divisions

• Advises the Attorney General, Congress, the Office of 

Management and Budget, and the White House on matters of 

criminal law and assists federal prosecutors

Drug Enforcement Administration (DEA) • Enforces laws and regulations related to the growing, 

manufacture, or distribution of controlled substances

• Conducts investigations in coordination with international, state, 

local and tribal law enforcement agencies

• Coordinates with FDA on scheduling drugs under the Controlled 

Substances Act

a

Federal Bureau of Investigation (FBI) • National security organization with intelligence and law 

enforcement responsibilities, including terrorism, cyber-attacks, 

and other major criminal threats

Office of Justice Programs • Disseminates information on strategies for crime control and 

prevention to federal, state, local, and tribal justice systems

• Administers grant programs to develop and implement these 

strategies

Organized Crime Drug Enforcement Task Forces (OCDETF) • Identifies, targets, disrupts, and dismantles major drug trafficking 

organizations, money laundering organizations, and related 

criminal enterprises

• Coordinates prosecutor-led, intelligence-driven multi-agency and 

multijurisdictional task forces, including DOJ, DHS, and USPS 

component agencies 

U.S. Attorney’s Office (USAO) • Enforces federal laws throughout the country, including drug 

trafficking and production offenses

Department of State

Bureau of International Narcotics and Law Enforcement 

Affairs

• Helps foreign governments implement programs to reduce the 

demand for and supply of illicit drugs

Office of National Drug Control Policy (ONDCP) • Advises the President on drug-control issues

• Coordinates drug-control activities and funding across the federal 

government

• Develops the annual National Drug Control Strategy

• Administers the High Intensity Drug Trafficking Areas (HIDTA) 

Program and the Drug-Free Communities grant programb

• Leads the interagency National Heroin Coordination Group, which 

developed the Heroin Availability Reduction Plan
Appendix I: Examples of Federal Agencies 

Involved in Combating Drug Trafficking and 

Drug Use

Page 10 GAO-18-569T Illicit Opioids

Agency Tasks

United States Postal Service (USPS)

U.S. Postal Inspection Service (USPIS) • Protects against and prevents criminal attacks to postal 

employees, customers, infrastructure, and the U.S. Mail

• Enforces laws that defend the nation’s mail system from illegal or 

dangerous use

• As the federal law enforcement arm of the USPS, investigates 

cases and prepares them for court along with U.S. Attorneys, 

other law enforcement, and local prosecutors

Source: GAO Analysis of Agency Documents | GAO-18-205

a

Enacted in 1970, the Controlled Substances Act and its implementing regulations establish a 

framework for the federal government to regulate the use of these substances for legitimate medical, 

scientific, research, and industrial purposes, while preventing them from being diverted for illegal 

purposes. This Act assigns controlled substances—including narcotics, stimulants, depressants, 

hallucinogens, and anabolic steroids—to one of five schedules based on the substance’s medical 

use, potential for abuse, and risk of dependence. FDA compiles and transmits to DEA a medical and 

scientific evaluation regarding a drug or other substance, recommending whether the drug should be 

controlled, and in what schedule it should be placed.

b

The Drug-Free Communities Support program provides grants to community coalitions to create and 

sustain reduction in local youth substance use. For more information, see GAO, Drug-Free 

Communities Support Program: Agencies Have Strengthened Collaboration but Could Enhance 

Grantee Compliance and Performance Monitoring, GAO-17-120 (Washington, D.C.: Feb. 7, 2017).

(102804)
ppendix I: Examples of Federal Agencies 

Involved in Combating Drug Trafficking and 

Drug Use

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