Comment from The Doctor Patient Forum

The Doctor Patient Forum (DPF) urges regulators to address the serious risks posed by PDMP-based risk scores like NarxCare. These opaque, algorithm-driven scores lack transparency, penalize stable pain patients, and create systemic barriers to care. Patients and providers have no access to or ability to challenge these scores, yet they are being used to justify denial of treatment, forced tapers, and pharmacy refusals. We have heard from numerous patients who were told their risk scores were too high to prescribe, yet they had no way to challenge or correct these scores. NarxCare’s Overdose Risk Score (ORS) is flawed and discriminatory, elevating risk based on medication history, prescriber and pharmacy count, and even past use of opioid addiction treatment (MOUDs). These factors do not predict actual overdose risk, yet they result in pain patients being labeled as high-risk—even when they are stable and compliant. Patients are left in medical limbo, unable to access necessary treatment, while providers fear scrutiny for prescribing. Furthermore, PDMPs were originally law enforcement tools, not clinical decision aids. The data-sharing practices between PDMPs and law enforcement agencies, often without patient consent, have contributed to the chilling effect on legitimate pain care. Prescribers fear investigation, pharmacies refuse to dispense, and patients are left suffering or forced to seek alternatives outside the medical system. We call for full transparency, regulatory oversight, and due process for patients and providers. No patient should be denied care based on an unregulated, unchallengeable algorithm. PDMP risk scores should never be used as the sole basis for restricting treatment, and patients must have the right to challenge these scores. The Doctor Patient Forum stands with pain patients, demanding fairness, accountability, and an end to the unchecked harm caused by these systems.