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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.

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Anatomy of a Pill Mill: What Medicare Data Reveals

Analysis · February 2026

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"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.

The Data 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

Five Warning Signs in the Data

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.

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.

What Machine Learning Adds

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 2,579 providers that our rule-based scoring missed entirely.

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.

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.

Highest-Risk Providers (1808)

Providers with opioid rate >50% and risk score ≥40. Statistical patterns only — not accusations.

ProviderOpioid RateRisk
Kamyar Cohanshohet62.4%77
Stephen Kelly53.6%70
Jennifer Jenkins60.3%64
Susan Frady67.7%64
Karolina Cichocka69.3%64
Sabera Shabnam57.5%64
Joanne Vogel58.2%64
Victoria Francis73.1%64
Carmen Ackerson68.1%64
Billy Smith69.4%64
Joyce Lee70.1%64
Suzanne Morse61.7%64
Joanna Cole75.3%63
Elizabeth Butterworth71.0%63
Wendell Randall55.9%63
Theresa Peacock55.4%62
Raymond Ketcham61.4%62
Joanna Katz65.5%62
Andrew Mcdowell63.4%62
Medea Karr52.4%61

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