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Comptroller’s Office Discovers 62 Opioid Prescribers with Abnormal Prescribing Patterns

The Comptroller’s Office has released a new report that examines the opioid prescribing patterns of Tennessee’s doctors, nurses, dentists, and other licensed practitioners. Comptroller researchers worked to identify prescribers whose patterns were “significantly statistically abnormal,” and to investigate what disciplinary responses, if any, were taken by the licensing boards in response.

The Comptroller’s Office of Research and Education Accountability (OREA) identified 62 prescribers for further investigation based on their 2017 prescribing patterns. It is important to note that identification by OREA for further investigation alone did not indicate inappropriate prescribing. Prescribing data can be used as a tool to find potentially inappropriate prescribing, but a fuller range of information is necessary to determine if an identified prescribing pattern is inappropriate.

Forty-nine of the 62 prescribers identified by OREA (79 percent) have not been disciplined by their licensing board since the start of 2017 and are not currently under investigation by the department. Eight of the 62 prescribers identified by OREA received some level of discipline since the start of 2017, and the department is developing cases against the remaining five prescribers.

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The report’s key conclusions include:

  • For half (31 of the 62) of prescribers identified by OREA, no query had been opened by the Department of Health. This suggests that an area of potential improvement for the department is the monitoring of specific types of prescribing patterns, such as monitoring prescribers with a high number of patients on concurrent opioid and benzodiazepine prescriptions.
  • Consultants play a significant role in determining the ultimate course of the Department of Health’s investigations into prescribers. Consultants decide whether the department will begin an investigation and, after an investigation, whether discipline will be sought against a prescriber and the level of discipline that will be pursued. Of the 62 prescribers identified by OREA, queries opened by the department were closed for 16 prescribers based on a consultant’s opinion, while six prescribers reached a settlement with the department based on the disciplinary recommendations of a consultant.
  • From opening a query to receiving a ruling from a board, the disciplinary process can take years to complete. For example, four of the five prescribers whose cases are currently being developed by the department have been under investigation for at least two years and have not yet been brought before the relevant board.

The report includes three policy considerations that address the Department of Health’s use of data to identify potentially inappropriate prescribers and the role of consultants in determining whether to seek discipline against practitioners with potentially inappropriate prescribing patterns. 

To read the report, please visit the Comptroller’s OREA website at:

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