For agencies
Measurement and evaluation
The outcomes we think an agency should hold this program to — including the ones that would show it failing.
The measure this program is not built to move
It is worth starting with the one that everybody reaches for. Reduction in opioid prescribing volume is not an outcome measure for this program. It is the measure that twenty years of policy optimized, and step four is what happened: prescribing fell while opioid-involved mortality rose 95% to its 2022 peak. A program evaluated on prescribing volume will be steered into producing exactly the harms described in step seven, and will look successful while doing it.
If an agency requires prescribing reduction as the headline measure, that is a legitimate choice and this is probably the wrong program.
What we think should be measured
Harm
- Fatal and non-fatal overdose in the enrolled population, and in the jurisdiction.
- Emergency department presentations related to pain, withdrawal or overdose.
- Mental health crisis events — the tapering literature makes this a required measure, not an optional one.
- Deaths from any cause in the enrolled population.
Continuity of care — the measure that is almost never collected
- Proportion of patients who lose their prescribing clinician during the program.
- Therapy gaps: episodes where a patient went without prescribed medication, and their duration.
- Proportion of patients who leave care entirely. A cohort study found tapering associated with subsequent termination of care at an adjusted odds ratio of 4.3.
- Time to a new clinician for patients who lose one.
Whether the program is actually happening
- Proportion of enrolled patients receiving each component.
- Behavioral health screening completion, and what proportion of critical findings received a clinical response, and how quickly.
- Naloxone in the home, and safe storage in place.
- Delivery reliability — deliveries made on schedule as a proportion of those due.
Population-level
- Time from a change in the local drug supply to a warning being issued.
- Overdose clusters detected, and whether response was reallocated.
The measures that would show this failing
These should be agreed before the program starts, because a program that only reports favorable measures is a marketing exercise.
- An increase in patients leaving care, or in patients unable to find a prescriber.
- An increase in therapy gaps.
- Any evidence that screening results are being used to restrict treatment rather than to direct support.
- Any evidence that identity or toxicology components are producing dismissals from care — which CDC’s 2022 guideline says should not happen on the basis of toxicology or monitoring information.
- Differential outcomes by race, insurance status or geography within the enrolled population. Given the social determinants evidence, this has to be looked for deliberately; it will not announce itself.
- Enrollment skewed toward patients who were easy to serve.
How it should be analyzed
By the agency’s own epidemiologists, or by an independent evaluator, with access to the underlying data. Not by us, and not only reported by us. A pilot evaluated solely by its vendor tells nobody anything, and every agency in this field has a shelf of those already.
Measures should be pre-registered where the agency has a mechanism for it, and the analysis plan agreed before the data exists.
Questions this raises
Why not measure reduction in opioid prescribing?
Because that is the metric the last two decades optimized, with the results set out in step four. A program steered by prescribing volume will produce the access harms described in step seven and will report success while doing it. See what a prescribing limit actually does.
Who should analyze the results?
The agency’s own epidemiologists or an independent evaluator, with access to the underlying data. We will supply data and analysis; we should not be the only party producing the findings. See evaluating a pilot honestly.
Sources
Every figure on this page is traceable to the source listed here.
- National Center for Health Statistics. VSRR Provisional Drug Overdose Death Counts (dataset xkb8-kh2a), 12-month-ending counts for the United States. Data accessed 20 August 2026. View source.
- Perez HR, Buonora M, Cunningham CO, Heo M, Starrels JL. Opioid taper is associated with subsequent termination of care: a retrospective cohort study. J Gen Intern Med. 2020;35(1):36–42. PMID 31428983. View source.
- Agnoli A, Xing G, Tancredi DJ, Magnan E, Jerant A, Fenton JJ. Association of dose tapering with overdose or mental health crisis among patients prescribed long-term opioids. JAMA. 2021;326(5):411–419. PMID 34342618. View source.
- Dowell D, Ragan KR, Jones CM, Baldwin GT, Chou R. CDC clinical practice guideline for prescribing opioids for pain — United States, 2022. MMWR Recomm Rep. 2022;71(3):1–95. PMID 36327391. View source.