Since 1999, more than 700,000 people have died of a drug overdose in the United States, with about 48,000 dying of an opioid overdose in 2017 alone. The Drug Enforcement Administration (DEA) administers and enforces the Controlled Substances Act as it pertains to ensuring the availability of controlled substances, including certain prescription drugs, for legitimate use while limiting their availability for abuse and diversion.
The Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act, enacted in 2018 included a provision for the Government Accountability Office (GAO) to study the reporting of suspicious opioid orders on a real-time basis nationally using computer algorithms.
In its January 29 report, GAO wrote that DEA collects industry-reported data on the sale and purchase of controlled substances and prescription drugs, including opioids – and uses these data to support ongoing investigations into the diversion of such substances into the illegal market place and to identify investigative leads for its field division offices.
The report identified deficiencies associated with DEA’s drug diversion efforts. First, GAO found limited proactive and robust analysis of industry-reported data. While DEA’s current data systems are not designed to conduct real-time analysis, and it conducts some analyses of industry-reported data, such as in response to requests from its field division offices, GAO said DEA could conduct more analyses using automated computer algorithms to help identify questionable patterns in the data. For example, DEA could analyze data to identify unusual volumes of deleted transactions or unusual volumes of drugs that were disposed of rather than sold. It could also analyze data to identify trends in distribution or drug purchases in a given geographic area. Other analysis DEA could perform is to look for unusual patterns when comparing drug orders in one geographic area with other nearby areas.
GAO’s review also discovered a lack of data governance structure to manage all drug transaction data. Although DEA has guidance, policies and procedures for the use of some information systems, GAO found it has not established a formal data governance structure to manage all data it collects and maintains, which are integral to its diversion control activities.
A data governance structure is defined as an institutionalized set of policies and procedures for providing data governance throughout the life cycle of developing and implementing data standards. Industry and technology councils, domestic and international standards-setting organizations, and federal entities endorse the use of a governance structure to oversee the development, management, and implementation of data standards, digital content, and other data assets.
GAO’s report noted that while DEA began efforts to develop a governance structure, it is in the early stages of development and does not have additional details or documentation of its efforts.
The report sets out four recommendations to DEA:
- Develop and implement additional ways to use algorithms in analyzing ARCOS and other data to more proactively identify problematic drug transaction patterns.
- Establish and document a data governance structure to ensure DEA is maximizing its management of industry-reported drug transaction data.
- Establish outcome-oriented goals and associated measurable performance targets related to opioid diversion activities, using data it collects, to assess how the data it obtains and uses supports its diversion control activities.
- Identify solutions (in consultation with industry) to address the limitations of the ARCOS Enhanced Lookup Buyer Statistic Tool, to ensure registrants have the most useful information possible to assist them in identifying and reporting suspicious orders to DEA.
DEA mostly concurred with these recommendations and has already begun work on meeting them, such as consulting with industry stakeholders to meet the fourth recommendation.