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Intelligence Gaps

The full extent of CPD diversion is unknown. Data collection methodologies with regard to CPD diversion and abuse in drug markets throughout the country are often inconsistent, incomplete, or nonexistent. For example, complete analysis of prescription drug-related deaths is constrained because of inconsistencies in state-level reporting by medical examiners or health departments. Moreover, theft and loss data collected by law enforcement agencies generally include the number of incidents in which CPDs are stolen as well as the quantities stolen; however, recovery of the stolen drugs is usually not reported, resulting in incomplete data with regard to the quantity of stolen drugs that could be diverted to the illicit market.

The extent to which prescription opioid abusers are switching to heroin is unknown. Anecdotal reporting by treatment providers indicates that some prescription opioid abusers around the country have begun seeking out heroin, particularly when it is less costly than prescription opioids. Empirical data are limited.

Survey estimates regarding the extent of CPD abuse may be conservative. CPD abuse is most likely underreported because many abusers may be reluctant to report inappropriate behavior such as the nonmedical use of CPDs. This reluctance on the part of nonmedical users of CPDs (particularly those who respond to surveys) may account for inconsistencies between law enforcement/treatment provider data and national survey data such as NSDUH, PATS, and MTF. For instance, survey data indicate that abuse of CPDs, particularly among teenagers, has been generally stable over the past 5 years; however, law enforcement and treatment provider reporting indicate increases in abuse.

Information regarding the number of Internet pharmacies that actually sell CPDs without a prescription and the number of individuals ordering CPDs online (intentionally or unwittingly) is limited. Individuals or organizations that conduct Internet pharmacy research do not actually purchase prescription drugs as part of their studies. Because they do not culminate a transaction, these researchers cannot accurately determine which web sites do in fact sell CPDs and which financial institutions will accept payment for the illicit purchase of such drugs. The number of individuals ordering CPDs online could be determined by mail and package delivery services; however, privacy laws restrict the random interception and inspection of packages by delivery services without a search warrant. Nevertheless, the sheer volume of packages sent daily through mail and package delivery services would largely prevent interception and inspection of suspected diverted CPDs.

 

Predictive Estimates

The number of unintentional opioid overdose deaths may level off or decrease. Scientific initiatives aimed at determining specific prescription opioid overdose abuse patterns in conjunction with law enforcement initiatives targeting the availability of diverted prescription opioids may affect the number of reported unintentional overdose deaths.

CPD abuse among teenagers will decrease. About 40 percent of teenagers believe that taking CPDs recreationally is safer than taking illicit drugs, and nearly one-third believe that there is nothing wrong with using a prescription drug not prescribed for them, according to PATS. Educational campaigns focusing on the dangers of CPD abuse are being instituted in most schools nationwide. Moreover, many communities have become proactive with educational campaigns aimed at parents. CPD abuse among teenagers has remained stable or decreased over the past 5 years, according to survey data. As more teenagers--and their parents--learn the dangers of taking CPDs nonmedically, particularly the high risk of death from abuse of prescription opioids, abuse rates among teenagers will go down.

Some heroin distributors will add diverted prescription opioids to their drug supplies. Law enforcement agencies in some areas of the country report that polydrug dealers have begun distributing CPDs. Street dealers have not regularly been the primary source of supply for CPD abusers; however, heroin distributors who add prescription opioids to their street supplies will ensure continuity in their customer base, particularly as prescription opioid abusers realize that heroin is less costly.

Large-scale diversion of CPDs will decrease as distributors become more diligent in monitoring the amount of CPDs that they sell to businesses. Distributors will seek to avoid license revocation and fines by becoming aware of their customers' purchasing habits, recognizing when those customers request quantities of CPDs that are unusually high, and reporting the activity to DEA. Decreases in large-scale diversion will ultimately have an effect on Internet availability of CPDs.

New federal legislation will reduce the number of U.S.-based rogue Internet pharmacies selling CPDs. The Ryan Haight Online Pharmacy Consumer Protection Act of 2008, enacted in October 2008, legally establishes online pharmacies and prohibits the delivery, distribution, or dispensing of CPDs over the Internet without a prescription written by a doctor who has conducted at least one in-person examination of the patient. Under the law, criminal penalties have been increased for illegal Internet prescribing of Schedule II, III, IV and V controlled substances. The law will deter some U.S.-based Internet pharmacy operators from engaging in "script mill" practices, which provide alleged "medical consultations" (for a fee), after which prescriptions are sent to local pharmacies or directly to customers who can have them filled at a local pharmacy.


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