Risk scores are statistical indicators based on prescribing patterns compared to specialty peers. They are NOT allegations of fraud, misconduct, or improper care. Many legitimate medical reasons can explain outlier prescribing.
Read our methodology →Anatomy of a Pill Mill: What Medicare Data Reveals
Analysis · February 2026
"Pill mill" is colloquial, but the data signature is specific. When a provider's opioid prescribing rate vastly exceeds their specialty peers, they prescribe a narrow range of drugs (mostly controlled substances), and they combine opioids with benzodiazepines at high rates — the statistical fingerprint starts to look very different from legitimate pain management.
What Is a Pill Mill?
A pill mill is a doctor, clinic, or pharmacy that prescribes or dispenses controlled substances — primarily opioids — inappropriately, often without legitimate medical purpose. The term gained national recognition during Florida's catastrophic pain clinic boom between 2007 and 2012, when the state became the epicenter of America's prescription opioid crisis.
During that era, Florida had no prescription drug monitoring program (PDMP), making it nearly impossible to track patients visiting multiple clinics. Pain management clinics proliferated — at the peak in 2010, Florida had 856 registered pain clinics, many concentrated along the I-95 and I-75 corridors. Patients drove from as far as Kentucky, West Virginia, and Ohio to obtain prescriptions, a phenomenon law enforcement dubbed the "Oxy Express." By 2010, Florida physicians purchased 89% of all oxycodone sold directly to practitioners in the United States.
The consequences were staggering. Between 2003 and 2009, opioid-related deaths in Florida tripled. The state consistently led the nation in oxycodone distribution, and seven of the top ten oxycodone-purchasing physicians in the country practiced in Florida. It took a combination of state legislation (HB 7095 in 2010, which regulated pain clinics), the implementation of a PDMP in 2011, and aggressive federal prosecution to begin reversing the trend. By 2014, Florida had dropped from first to sixth in per-capita opioid prescribing — proof that regulatory intervention works, but also a reminder of how much damage accrues before intervention occurs.
The modern definition has expanded beyond a single rogue doctor in a strip mall. Today's pill mills may operate through telehealth platforms, multi-location clinic chains, or corporate structures designed to insulate prescribers from oversight. But the underlying data pattern remains remarkably consistent: extreme opioid concentration, narrow drug selection, high patient volume, and dangerous drug combinations.
The Statistical Fingerprint
Across 1,380,665 Medicare Part D prescribers, we identified 1808 providers with prescribing patterns that match multiple pill mill indicators simultaneously:
- Opioid rate >50% — More than half of all prescriptions are opioids (vs. national average ~12%)
- Risk score ≥40/100 — Multiple independent risk factors flagged
- Specialty-adjusted outlier — Opioid rate significantly above their own specialty's mean
What makes a pill mill look different in data is the convergence of multiple signals. Any single metric — high opioid rate, low drug diversity, high patient count — can have a legitimate explanation. A hospice provider will have a high opioid rate. A specialist may see many patients. But when all of these factors co-occur in the same provider, particularly a provider whose specialty does not typically involve chronic pain management, the statistical probability of a benign explanation drops sharply.
The most distinctive feature is prescription diversity, or rather the lack of it. A typical primary care physician prescribes 80 to 150 distinct medications across their Medicare patient panel. A provider prescribing fewer than 15 unique drugs — and those drugs are predominantly oxycodone, hydrocodone, alprazolam, and carisoprodol — is exhibiting a pattern that forensic pharmacologists call the "Holy Trinity" of pill mill prescribing: an opioid, a benzodiazepine, and a muscle relaxant.
Patient volume is another distinguishing factor. Pill mills historically operated on a high-throughput model — seeing 40 to 80 patients per day with brief examinations. In Medicare data, this manifests as an unusually high number of unique beneficiaries per provider. While large group practices may legitimately see high patient volumes, a solo practitioner claiming 2,000 or more unique Medicare beneficiaries in a single year — particularly when most of those patients receive opioid prescriptions — is generating a volume signal that is difficult to reconcile with individualized medical care.
The geographic distribution of a provider's patients also carries information. Most physicians draw the majority of their patients from within a 30-mile radius. Providers whose patient panels include significant numbers of beneficiaries from distant ZIP codes — particularly from states known as opioid "source" states — exhibit a pattern historically associated with pill mill operations. We compute a patient geographic dispersion index for each provider to capture this signal.
Historical Examples
The modern pill mill crisis cannot be understood without acknowledging Purdue Pharma's role in reshaping American pain treatment. Beginning in the mid-1990s, Purdue's aggressive marketing of OxyContin — including the now-discredited claim that fewer than 1% of patients would become addicted — created the conditions for pill mills to thrive. When physicians were encouraged to treat pain as "the fifth vital sign" and prescribe opioids liberally, the distinction between legitimate pain management and inappropriate prescribing became dangerously blurred.
Purdue's sales representatives targeted high-volume prescribers with bonuses, speaker fees, and all-expenses-paid conferences. Internal documents revealed during litigation showed that the company tracked individual physicians by prescribing volume and directed marketing resources toward those writing the most opioid prescriptions. This created a feedback loop: the doctors most willing to prescribe aggressively received the most encouragement and financial reward for doing so.
Florida's I-75 corridor became ground zero. Clinics like American Pain in Palm Beach County, operated by convicted felons Chris and Jeff George, dispensed millions of oxycodone pills between 2008 and 2010. At its peak, American Pain was the largest purchaser of oxycodone from distributors in the entire United States — more than some entire hospital systems. The clinic employed doctors who conducted cursory examinations lasting two to three minutes before writing prescriptions for hundreds of pills. Patients lined up before dawn, and the parking lot was filled with out-of-state license plates.
In New Jersey, the Twin Boro case illustrated how pill mills operated in the Northeast. Twin Boro Medical Associates and its associated pharmacy dispensed massive quantities of oxycodone, often to patients who traveled long distances and paid cash — two classic pill mill indicators. The operation resulted in multiple overdose deaths before federal authorities intervened.
Other notable cases include the Houston clinics of Dr. Hector Castro, who prescribed more hydrocodone than any provider in Texas before his arrest in 2017; the Tri-County Healthcare ring in Michigan, where nine defendants were convicted of running a network that distributed over 6.6 million doses of opioids; and the Appalachian clinics documented in Beth Macy's Dopesick, where entire communities were destabilized by a handful of high-volume prescribers.
These historical cases established the behavioral template that we now look for in Medicare Part D data: extreme volume, geographic patient clustering from distant locations, cash payments (which we cannot see in Medicare data but which correlate with other visible patterns), and prescribing concentrated in a handful of controlled substances.
How We Detect Them
Our risk scoring methodology assigns points across multiple independent dimensions, and it is the simultaneous triggering of multiple flags that generates high risk scores. No single factor alone produces a score above 25 out of 100. The design is intentional: we want to minimize false positives by requiring convergent evidence from independent signals.
The scoring system operates in two stages. First, we compute specialty-adjusted z-scores for each provider across eight prescribing dimensions: opioid claim rate, benzodiazepine claim rate, drug diversity index, cost per beneficiary, claims per beneficiary, opioid-benzo overlap rate, Schedule II concentration, and brand-name preference ratio. Each z-score is calculated relative to the provider's own specialty cohort, ensuring that a pain management specialist is compared to other pain management specialists, not to dermatologists.
Second, we convert these z-scores into risk points using nonlinear thresholds. A z-score of 2.0 (roughly the 97.7th percentile within specialty) triggers a small number of points. A z-score above 3.0 triggers substantially more. And a z-score above 4.0 — representing extreme statistical rarity — triggers the maximum contribution for that dimension. The total across all dimensions produces the composite risk score displayed on each provider profile.
The methodology is deliberately conservative. We would rather miss a true pill mill than falsely flag a legitimate provider. The providers who reach the top of our risk rankings have typically triggered four or more independent flags at extreme levels — a combination that occurs in fewer than 0.1% of all Medicare prescribers. Even among these extreme outliers, we present the data as statistical patterns warranting review, never as definitive findings of wrongdoing.
1. Extreme Opioid Concentration
A typical Family Practice provider prescribes opioids for about 3.9% of claims. A pain management specialist might legitimately hit 30-50%. But when a non-specialist is writing opioids for 70-90% of their Medicare patients, the data raises questions. Our scoring system compares each provider to their own specialty peers, so a pain specialist at 40% isn't flagged — but a family doctor at 40% generates a significant z-score.
2. Low Drug Diversity
Legitimate physicians prescribe dozens to hundreds of different medications. Providers prescribing fewer than 10 unique drugs — especially when most are Schedule II-IV controlled substances — exhibit a pattern inconsistent with genuine medical practice.
3. Opioid + Benzodiazepine Combinations
The FDA has issued a Black Box Warning about concurrent opioid and benzodiazepine use due to life-threatening respiratory depression. We identified 6,149 providers who prescribe both. While some have legitimate clinical reasons, the combination is a well-established red flag.
4. High Fills Per Patient
When a provider has an unusually high number of prescription fills per patient, it may indicate excessive prescribing or "frequent flyer" patients seeking repeat refills. The national median for opioid fills per patient is approximately 3.2 per year for providers who prescribe any opioids. Providers averaging 8 or more opioid fills per patient are in the top 1% of this distribution and generate significant risk points in our scoring system.
This metric also captures a pattern common in pill mill operations: a large number of patients each receiving a small number of prescriptions. Some providers see hundreds of patients exactly once, writing a single high-quantity opioid prescription at each visit. The combination of high patient volume and one-time visits is a strong indicator of a "revolving door" practice — patients come in, get a prescription, and never return for follow-up care.
5. Extreme Cost Per Beneficiary
Some opioid-heavy providers also show extremely high cost per patient — not because opioids themselves are expensive, but because they may be prescribing high-cost brand-name formulations when generics exist, or writing for expensive long-acting formulations unnecessarily. Brand-name oxycodone formulations can cost ten to twenty times their generic equivalents. A provider consistently choosing brand-name products when generics are available — particularly when combined with other risk factors — may be receiving inducements from pharmaceutical companies or generating higher dispensing fees for an affiliated pharmacy.
The Modern Pill Mill
The strip-mall pain clinic of 2010 has evolved. Modern pill mills are harder to identify precisely because they have adapted to the enforcement mechanisms that shut down their predecessors. Several structural changes define the current landscape.
Telehealth prescribing expanded dramatically during the COVID-19 pandemic, when the DEA relaxed requirements for in-person visits before prescribing controlled substances. While most telehealth providers practice responsibly, the modality creates opportunities for high-volume prescribing without physical examination. Some telehealth platforms have been linked to prescribing patterns that mirror traditional pill mills — short consultations, limited medical history review, and disproportionate controlled substance prescriptions. The DEA's proposed rules to reinstate in-person visit requirements for Schedule II prescriptions have faced pushback from legitimate telehealth advocates, illustrating the tension between access and oversight.
Multi-location clinic chains represent another evolution. Rather than a single high-volume clinic that attracts attention, operators may distribute prescribing across five or ten locations, each individually below typical surveillance thresholds. Corporate structures — often involving shell companies, nominee owners, and complex billing arrangements — further insulate the decision-makers from individual prescribers. Some operations use management service organizations (MSOs) to control clinical decisions while maintaining the appearance of independent medical practices. Our analysis looks at provider-level patterns, but future work will examine network-level clustering to detect these distributed operations.
The use of nurse practitioners and physician assistants as prescribers has also changed the landscape. In states with independent practice authority for NPs, pill mill operators can employ mid-level providers who may face less scrutiny from medical boards than physicians. This is not an indictment of nurse practitioners generally — but it represents a regulatory gap that bad actors exploit.
Another modern adaptation is the "legitimate front" model. Some operations maintain a genuine medical practice — treating real patients with real conditions — while simultaneously running a high-volume opioid prescribing operation through a subset of their patient panel. These hybrid practices are particularly difficult to detect because their aggregate statistics are diluted by the legitimate portion of their practice. Identifying them requires examining the distribution of prescribing within a practice, not just the averages.
Pharmacy-level collusion adds another layer of complexity. Traditional pill mills often had an associated pharmacy that filled prescriptions without question. Modern equivalents may involve relationships with mail-order pharmacies or compounding operations that are harder to trace. When both the prescriber and the dispenser are cooperating, the internal controls that normally catch inappropriate prescriptions — pharmacist review, utilization management, prior authorization — are effectively neutralized.
Geographic Patterns
Pill mill signatures in Medicare data are not evenly distributed. Appalachian states — West Virginia, Kentucky, Tennessee, and southern Ohio — consistently show the highest rates of providers with extreme opioid prescribing patterns. This reflects both the legacy of the OxyContin marketing campaigns that targeted rural areas and the ongoing burden of chronic pain in communities with high rates of manual labor, mining, and industrial work.
The Southeast remains overrepresented, with Alabama, Mississippi, and Louisiana showing elevated rates even after adjusting for specialty mix. Parts of the rural Southwest, particularly New Mexico and Arizona, also appear in our geographic analysis. Urban areas are not immune — Houston, Detroit, and parts of New York City all have clusters of high-risk providers. Our state-level analysis breaks down these patterns in detail.
Border effects are visible in the data. Providers located near state lines often show patient panels with unusual geographic spread, drawing patients from neighboring states with stronger regulations. This cross-border prescribing pattern was a hallmark of the Florida pill mill era and persists in attenuated form along several state borders today.
Rural versus urban dynamics also matter. Rural providers face genuine challenges — fewer specialists, longer travel distances for patients, higher rates of occupational injuries — that can legitimately drive higher opioid prescribing. Our geographic analysis attempts to control for these factors by incorporating county-level variables including poverty rate, employment in high-injury industries, and distance to the nearest pain management specialist.
State-level regulatory environments matter enormously. States with strong PDMPs, mandatory checking requirements, and active medical board enforcement tend to show fewer pill mill patterns. States with weaker oversight frameworks — or those that only recently implemented PDMPs — show more. Florida's dramatic reduction in pill mill activity after implementing its PDMP in 2011 and passing clinic regulation in 2010 provides a natural experiment demonstrating the effectiveness of regulatory intervention.
The Specialty Question
Which provider specialties show the most pill mill signatures? The answer is more nuanced than "pain management." Pain management specialists do have higher opioid rates by definition, but our specialty-adjusted scoring accounts for this. The providers who generate the highest adjusted risk scores are often in specialties where high opioid prescribing is unexpected.
Family Practice and Internal Medicine providers appear most frequently in our highest-risk tier, simply because these are the largest specialties — more providers means more outliers. But on a per-capita basis, certain smaller specialties raise concerns. Physical Medicine and Rehabilitation, Interventional Pain Management, and Anesthesiology all have elevated rates of providers matching pill mill patterns, even after specialty adjustment.
Nurse Practitioners represent a growing share of high-risk prescribers in our data. This likely reflects both the expansion of NP prescribing authority across states and the deliberate recruitment of NPs by clinic operators seeking to maximize prescribing capacity. In states where NPs can prescribe Schedule II substances independently, the rate of NPs appearing in our highest-risk tier is approximately double that of states requiring physician oversight.
Podiatrists, dentists, and optometrists — providers with limited prescribing authority in most states — occasionally appear as statistical outliers in opioid prescribing. While post-surgical pain management is legitimate for podiatrists and dentists, the appearance of these specialties in our extreme outlier tier warrants examination. A dentist whose opioid prescribing rate exceeds that of most pain management specialists is generating a signal that is difficult to explain through legitimate clinical need.
The role of supervising physicians in collaborative practice arrangements also deserves scrutiny. In states requiring physician oversight of NP prescribing, the supervising physician may be nominal — signing off on charts without meaningful review. Some enforcement actions have revealed "supervision mills" where a single physician nominally supervises dozens of mid-level providers across multiple clinic locations, providing a veneer of oversight without substantive clinical involvement.
Law Enforcement Successes
Federal and state enforcement actions have dismantled hundreds of pill mill operations over the past fifteen years. The DEA's Tactical Diversion Squads, working with the Department of Justice and state attorneys general, have prosecuted thousands of providers for unlawful distribution of controlled substances.
Operation Pill Nation in 2010-2011 targeted Florida's pain clinic corridor, resulting in dozens of arrests and clinic closures. The Appalachian Regional Prescription Opioid Strike Force, launched in 2019, has charged over 150 defendants across multiple states. In 2023 alone, DOJ announced charges against more than 300 defendants in healthcare fraud enforcement actions, many involving opioid prescribing schemes. Operation Tidal Wave in 2017 resulted in the largest healthcare fraud takedown in DOJ history at the time, with 412 defendants charged across 41 federal districts.
Individual cases have resulted in severe sentences. Dr. Xiulu Ruan of Alabama was sentenced to 21 years in federal prison after being convicted of prescribing opioids outside the usual course of professional practice — a case that reached the Supreme Court on the question of criminal intent standards. Dr. Joel Smithers of Virginia received a 40-year sentence for illegally distributing opioids that contributed to patient deaths. These sentences signal that federal prosecutors and judges view pill mill operations as serious violent crimes, not merely regulatory violations.
These prosecutions have a measurable deterrent effect. In states where high-profile pill mill prosecutions have occurred, we observe a subsequent reduction in the number of extreme statistical outliers in Medicare data — suggesting that enforcement actions influence prescribing behavior beyond the individual defendants.
However, enforcement alone has limitations. Criminal cases typically take years to develop, during which patients continue to receive inappropriate prescriptions. The evidentiary standard for criminal prosecution — proof beyond a reasonable doubt that prescriptions lacked legitimate medical purpose — is far higher than the statistical standard for identifying an outlier. Many providers who exhibit extreme prescribing patterns will never face criminal charges, either because their behavior falls short of provable criminal intent or because enforcement resources are insufficient to pursue every case.
Administrative actions by state medical boards and CMS exclusions from federal healthcare programs represent a middle ground between criminal prosecution and no intervention at all. These actions have lower evidentiary thresholds and can be implemented more quickly, potentially preventing harm while criminal investigations proceed.
What Our ML Model Finds
Our ML fraud detection model — trained on 281 providers actually convicted of healthcare fraud — identifies patterns that rule-based systems miss. The model learns the combination of features that distinguish fraud cases from legitimate outliers. It flagged thousands of providers that our rule-based scoring missed entirely.
The most informative features the model identifies are not the obvious ones. While high opioid rate is predictive, the model places significant weight on temporal patterns — providers whose prescribing volume increased dramatically over a short period, or whose drug mix shifted suddenly toward controlled substances. These trajectory features capture the moment a practice transitions from legitimate to problematic.
The model also detects geographic-demographic mismatches: providers whose patient panel demographics are inconsistent with their practice location. A clinic in a retirement community with a patient base that skews young, or a rural practice drawing patients from urban ZIP codes hundreds of miles away, generates a signal that rules-based systems would not capture without explicit programming.
Importantly, the model produces a probability score, not a binary classification. Providers scoring above the 95th percentile of the model's output distribution are flagged for review, but the continuous nature of the score allows for nuanced triage. A provider at the 97th percentile with three corroborating risk flags presents a different picture than one at the 96th percentile with a plausible specialty explanation.
Network analysis represents the next frontier. By examining referral patterns, shared patients, and geographic clustering among high-risk providers, the model can identify coordinated operations that would be invisible when examining individual providers in isolation. A group of five providers, each individually below the extreme outlier threshold, may collectively exhibit patterns that indicate a distributed pill mill operation — sharing patients, prescribing complementary drugs, and operating in geographic proximity.
We also examine prescription-to-patient ratios and day-supply distributions. Providers who consistently write 30-day supplies of maximum-dose opioids for every patient — regardless of diagnosis or treatment history — generate a uniformity signal that differs markedly from providers who titrate doses individually. This "cookie-cutter prescribing" pattern, where every patient receives essentially the same prescription, is a strong indicator of prescribing without individualized medical judgment.
The Human Cost
Behind the statistics are lives destroyed. The CDC estimates that nearly 645,000 Americans died from opioid overdoses between 1999 and 2021. While not all of these deaths trace directly to pill mill prescribing, the diversion pipeline from high-volume prescribers to street-level distribution has been documented extensively in federal court proceedings. For every death, there are dozens more lives upended by addiction — lost jobs, broken families, children placed in foster care, and a cycle of suffering that spans generations.
Communities where pill mills operated experienced cascading effects beyond overdose deaths: increased rates of neonatal abstinence syndrome as opioid-dependent mothers gave birth, overwhelmed emergency departments, rising hepatitis C rates from injection drug use that often follows prescription opioid addiction, collapsed workforce participation, and shattered families. Counties in eastern Kentucky and southern West Virginia that were targeted by aggressive opioid marketing in the 2000s are still struggling to recover two decades later. Some rural communities lost an entire generation of working-age adults to addiction, creating economic and social voids that persist long after the pill mills themselves were shuttered.
The impact on children has been particularly devastating. The number of children entering foster care due to parental substance abuse more than doubled between 2000 and 2017 in states most affected by the opioid crisis. These children face elevated risks of developmental delays, behavioral problems, and their own future substance use disorders. The intergenerational trauma inflicted by pill mills extends far beyond the immediate victims of addiction.
The transition from prescription opioids to heroin and fentanyl — driven in part by the crackdown on pill mills — created a second wave of the crisis. When patients who had become dependent on prescribed opioids lost access, many turned to cheaper and more dangerous alternatives. This is not an argument against enforcement, but it underscores the need for simultaneous investment in treatment infrastructure when supply-side interventions disrupt established patterns of dependence.
Medicare beneficiaries are particularly vulnerable. The population served by Medicare Part D skews older and sicker, with higher rates of chronic pain conditions. Elderly patients prescribed high-dose opioids face elevated risks of falls, respiratory depression, cognitive impairment, and death. When a provider is prescribing opioids to 70% or more of their Medicare panel, the aggregate harm to a vulnerable population compounds rapidly.
The economic costs extend beyond healthcare. A 2019 CDC study estimated the total economic burden of the opioid crisis at $1.02 trillion annually, encompassing healthcare costs, lost productivity, criminal justice expenses, and the value of lives lost. Communities that hosted pill mills bear a disproportionate share of this burden — reduced property values, strained social services, and a generation of children raised in families affected by addiction.
Policy Implications
Identifying pill mill patterns in Medicare data is only useful if it connects to actionable policy. Several implications emerge from our analysis.
First, CMS already has the data to identify extreme prescribing outliers in near-real-time. The gap is not data availability but the speed and consistency of response. Providers who exhibit pill mill signatures for multiple consecutive years without intervention represent a system failure. Our risk scoring methodology demonstrates that straightforward statistical techniques can surface high-priority cases without sophisticated infrastructure.
Second, state-level variation in PDMP requirements creates regulatory arbitrage opportunities. Providers operating near state borders can exploit differences in monitoring intensity. Federal standardization of PDMP requirements — including mandatory interstate data sharing and real-time checking before prescribing — would close this gap.
Third, telehealth prescribing of controlled substances requires updated oversight frameworks. The pandemic-era flexibilities that enabled telehealth prescribing of Schedule II substances without an in-person visit were appropriate as emergency measures. Making them permanent without corresponding surveillance infrastructure creates new vulnerabilities.
Finally, enforcement must be paired with treatment. Every pill mill closure disrupts supply to patients who have become dependent — some through no fault of their own. Without adequate medication-assisted treatment capacity in the same communities, enforcement actions risk driving patients to illicit markets. The most effective interventions combine supply-side enforcement with demand-side treatment expansion.
Data transparency itself is a policy tool. By making prescribing patterns visible and searchable, platforms like OpenPrescriber enable journalists, researchers, advocacy organizations, and patients themselves to identify concerning patterns and demand accountability. The opioid crisis analysis we publish is not a substitute for regulatory action, but it can accelerate it by lowering the cost of information gathering for the entities with authority to act.
Medical education reform is another critical lever. Many physicians who became high-volume opioid prescribers were trained during an era when undertreating pain was considered the greater sin. Updating medical school curricula and continuing education requirements to reflect current evidence on opioid risks — including the limited evidence for long-term opioid therapy in chronic non-cancer pain — can shift prescribing norms at the population level.
Insurance design also plays a role. Prior authorization requirements for high-dose opioids, quantity limits, and mandatory trial of non-opioid alternatives have been shown to reduce inappropriate prescribing. Medicare Part D plan sponsors have implemented many of these controls, but implementation varies significantly across plans. Standardizing these safeguards across all Part D plans would reduce the ability of patients and providers to circumvent controls by switching plans.
The opioid settlement funds — billions of dollars distributed to states and localities from litigation against Purdue Pharma, distributors, and pharmacy chains — represent a once-in-a-generation opportunity to invest in prevention, treatment, and monitoring infrastructure. How these funds are deployed will shape the trajectory of the opioid crisis for the next decade. Allocating a meaningful portion toward prescription monitoring technology, data analytics capacity at state medical boards, and rapid-response intervention programs would directly address the patterns we identify in this analysis.
Legitimate High-Opioid Prescribers Exist
It's important to note: some providers with very high opioid rates are providing essential care. Palliative care, hospice, cancer pain management, and addiction treatment (buprenorphine/Suboxone prescribers) all legitimately generate high opioid prescribing rates. Our methodology accounts for specialty baselines, but no statistical model perfectly distinguishes fraud from specialized care.
Buprenorphine prescribers deserve particular mention. Providers who treat opioid use disorder with medication-assisted treatment (MAT) will have high opioid prescribing rates because buprenorphine is itself an opioid. These providers are part of the solution, not the problem. We flag buprenorphine/Suboxone prescribers separately in our data to avoid conflating addiction treatment with inappropriate prescribing. Users examining individual provider profiles can see whether a provider's opioid prescribing includes significant buprenorphine volume.
Rural providers treating chronic pain in underserved areas also face legitimate challenges. When the nearest pain management specialist is a three-hour drive away, primary care physicians may take on complex pain management cases that would otherwise be referred. These providers may appear as statistical outliers not because they are prescribing inappropriately, but because they are filling a gap in care that their urban counterparts do not face.
That's why we emphasize: these are statistical indicators, not accusations. The goal is to surface patterns that warrant further examination — by CMS, by state medical boards, by journalists, or by the providers themselves. Context matters. A high risk score is a starting point for inquiry, not an endpoint.
Looking Forward
The pill mill problem is not solved. It has evolved. The crude, high-volume strip-mall operations of 2010 have been replaced by more sophisticated schemes that exploit regulatory gaps, telehealth flexibility, and multi-state corporate structures. Detecting these modern operations requires correspondingly sophisticated analytical tools — which is why we continue to refine our machine learning models and expand the dimensions of our risk scoring system.
The data we analyze is public. The methods we use are transparent. Every provider flagged in our system can be examined in full detail through their individual profile page, where the underlying numbers are presented alongside the risk assessment. We believe that sunlight remains the best disinfectant — and that making prescribing patterns visible to the public is a necessary complement to the regulatory and enforcement mechanisms that exist to protect patients.
Highest-Risk Providers (1808)
Providers with opioid rate >50% and risk score ≥40. Statistical patterns only — not accusations.
| Provider | Opioid Rate | Risk |
|---|---|---|
| Kamyar Cohanshohet | 62.4% | 77 |
| Stephen Kelly | 53.6% | 70 |
| Jennifer Jenkins | 60.3% | 64 |
| Susan Frady | 67.7% | 64 |
| Karolina Cichocka | 69.3% | 64 |
| Sabera Shabnam | 57.5% | 64 |
| Joanne Vogel | 58.2% | 64 |
| Victoria Francis | 73.1% | 64 |
| Carmen Ackerson | 68.1% | 64 |
| Billy Smith | 69.4% | 64 |
| Joyce Lee | 70.1% | 64 |
| Suzanne Morse | 61.7% | 64 |
| Joanna Cole | 75.3% | 63 |
| Elizabeth Butterworth | 71.0% | 63 |
| Wendell Randall | 55.9% | 63 |
| Theresa Peacock | 55.4% | 62 |
| Raymond Ketcham | 61.4% | 62 |
| Joanna Katz | 65.5% | 62 |
| Andrew Mcdowell | 63.4% | 62 |
| Medea Karr | 52.4% | 61 |
Related Analysis
The Opioid Prescribing Crisis in Medicare
OpioidsGeographic Opioid Hotspots
OpioidsControlled Substance Pipeline
CostCost Outlier Providers