Hydrocodone Combination Products: Moving from CIII to CII

The Drug Enforcement Administration recently announced that all hydrocodone products will have a Cll status effective October 6, 2014.

The Drug Enforcement Administration recently announced that all hydrocodone products will have a CII status effective October 6, 2014. This includes all combination products, which represent the vast majority of hydrocodone that is consumed annually.

Knowing the definition of CII status, there is no doubt that hydrocodone should have this status due to the extent of the associated abuse and misuse. Hydrocodone products are the most prescribed pharmaceuticals, controlled substance or not. The US population consumes an enormous amount of this versatile pain killer, which has provided relief to countless patients over several decades—all while these combination products remained in CIII status.

Legitimate patients and some prescribers were against giving hydrocodone combination products a CII status because it would require a new prescription each month, with no refills or call-ins from prescribers. Although there was pushback against more restrictive scheduling, I am frankly surprised that rescheduling took this long. Factually, there was a weak argument for keeping hydrocodone out of the most restrictive class due to the associated level of abuse.

As I mentioned in my January 2014 Pharmacy Times column, law enforcement dedicated to drug diversion spends virtually half of its investigative time on hydrocodone alone. Doctor shopping, forged and altered prescriptions, and street trafficking lead the list of offenses. Many unscrupulous prescribers who have been arrested overprescribed hydrocodone combination products because they have been CIII painkillers, which these prescribers thought kept them under law enforcement’s radar.

Law enforcement has seen cases in which addiction may have started at 15 to 20 tablets per day, and then increased to much higher amounts. One woman, a doctor’s wife and his office manager, confessed to consuming more than 100 hydrocodone extra strength tablets per day for more than 6 months. She was able to acquire this amount of the drug by ordering it for the doctor’s office, without her husband’s knowledge. Of course, acetaminophen toxicity is always a concern when high levels of hydrocodone combination products are consumed.

So how will the rescheduling of hydrocodone products as CII affect drug diversion? Some individuals think they will be prescribed less and that legitimate patients will suffer. Others foresee less diversion of hydrocodone,and possibly a reduction in prescription drug abuse overall. Still others think the rescheduling will drive hydrocodone addicts to abuse the mammoth amounts of cheap heroin saturating our country, or that these addicts will try to switch to an oxycodone prescription drug to get their fix.

The truth is that only time will tell, and to be honest, I don’t know which of these possibilities will come true. Maybe more than one will. My sincere hope is that no legitimate patients suffer due to this rescheduling and that drug diversion is reduced in some way. Perhaps the rescheduling will motivate some lifetime addicts to become serious about rehabilitation and stop their revolving-door lifestyle of becoming sober, relapsing, and doing it all over again.

Solving the drug problem is not an easy task; otherwise, it would have been done long ago. Rescheduling hydrocodone combination drugs won’t eliminate the prescription drug problem, but let’s hope that it helps in some small way.

Cmdr Burke is a 40-year veteran of law enforcement and the current president of the National Association of Drug Diversion Investigators. He can be reached by e-mail at burke@choice.net or burke@naddi.org or via the website www .rxdiversion.com.