08/18/2026
🚨 Livingston County wants to spend $75,000 in opioid settlement money to analyze opioid prescriptions of county employees and their families and flag patients for potential tapering.
Michigan already has MAPS, a statewide prescription monitoring system.
So I have questions.
What happens when a person who legitimately depends on prescribed opioids is pushed off their medication? Where does that person go when their pain or withdrawal becomes unmanageable? The illicit drug supply? Fentanyl? Because those are certainly not safer.
And why are we spending opioid settlement dollars on this instead of putting those dollars into treatment, recovery, prevention, harm reduction, and services for people actually struggling with substance use disorder?
I sent the Livingston County Commissioners a letter demanding answers and asking them to show me the evidence.
MY LETTER TO Dear Livingston County Commissioners,
I am writing regarding the proposed $75,000 Opioid Prevention and Clinical Risk Reduction Initiative involving the opioid prescription data of Livingston County employees and family members covered by the county health plan.
I have serious concerns about this proposal, both as an advocate who has spent years working on the opioid epidemic and as someone with lived experience of substance use and recovery.
Let me be very clear at the outset: I absolutely support identifying inappropriate opioid prescribing. I support preventing opioid use disorder. I support treatment, recovery, naloxone, education, and interventions that save lives.
What I do not support is taking a complex medical issue and reducing it to an algorithm that identifies people receiving prescribed opioids and then encourages physicians to transition them off those medications.
A prescription for an opioid is not evidence of opioid use disorder.
Physical dependence is not the same thing as opioid use disorder.
A person can take an opioid exactly as prescribed for a legitimate medical condition, become physically dependent on that medication, and still not have a substance use disorder. A person living with chronic pain is not automatically a person who needs to be "rescued" from their medication.
I am particularly concerned about the stated goal of encouraging physicians to taper patients based upon information generated by this program.
What happens to the patient who does not want to be tapered?
What happens to the patient whose medication is controlling severe chronic pain?
What happens when an algorithm identifies a patient as "high risk" but the patient's physician believes continued treatment is medically appropriate?
And perhaps most importantly, what happens when a patient is involuntarily or inappropriately tapered and suddenly has uncontrolled pain or opioid withdrawal?
Where do you think some people will turn?
The illicit drug supply?
Street fentanyl?
Because those alternatives are certainly not safer.
We have spent years watching people become exposed to an increasingly unpredictable illicit drug supply. If the goal is to reduce overdose deaths, we should be extremely careful about policies that could push people who are physically dependent on prescribed opioids toward illicit opioids.
A patient's treatment plan should be based on an individualized clinical assessment and a relationship between the patient and their treating clinician. It should not be driven by a county-funded algorithm whose fundamental intervention is to encourage tapering.
I am also deeply concerned about the apparent redundancy of this proposal.
Michigan already has the Michigan Automated Prescription System, MAPS, specifically designed to monitor controlled-substance prescribing and dispensing and identify potentially concerning prescribing patterns.
So I want to know:
Why does Livingston County need another system?
What specific deficiency in MAPS does this program address?
What evidence demonstrates that this additional $75,000 expenditure will produce better outcomes than the systems and resources already available?
And where is the evidence that this particular approach will reduce overdose deaths rather than simply reduce the number of opioid prescriptions?
Those are not the same outcome.
I also have significant questions about the use of opioid settlement funds for this initiative.
These funds exist because of the devastation caused by the opioid epidemic. Livingston County has approximately $9 million in opioid settlement funds available over time. Those dollars should be used strategically to address the opioid crisis and save lives.
Before spending $75,000 on this program, I believe the county owes the public a clear explanation of why this is the highest and best use of those dollars.
How much funding is currently being directed toward:
- Evidence-based substance use disorder treatment
- Recovery support
- Peer recovery services
- Naloxone distribution
- Harm reduction
- Prevention and education
- Family support
- Services for people at immediate risk of overdose
- Services for people who are already experiencing opioid use disorder
If there are unmet needs in those areas, why is $75,000 being directed toward another prescription surveillance system?
I also want complete transparency regarding the data.
I understand that proponents describe the information as de-identified and say that HIPAA-compliant agreements will protect employees and their families. But "de-identified" should not end the discussion.
The county needs to explain precisely:
Who receives the data?
What information is provided?
Who has access to it?
What information is retained?
For how long?
Who can re-identify individuals, if anyone?
Who receives the algorithm's risk determinations?
What exactly is communicated to prescribing physicians?
What happens after a physician is contacted?
Can the county, the vendor, or any third party ever identify an individual employee or family member?
What contractual safeguards exist against future use of the data for purposes unrelated to this initiative?
What happens to the data when the contract ends?
And what independent legal and privacy review has been conducted before this program is implemented?
The fact that a program can be structured to comply with HIPAA does not automatically make it a good public policy.
There is also a fundamental question about what problem the county believes it is solving.
If someone has opioid use disorder, that person needs access to appropriate treatment and recovery services.
If someone is being prescribed opioids inappropriately, that prescribing needs to be addressed.
If someone is taking a prescribed opioid appropriately for legitimate pain, that person needs appropriate medical care.
Those are three different situations.
They should not be collapsed into one category simply because an algorithm identifies opioid exposure as a risk factor.
I am also concerned about the message this sends to patients.
We have spent years trying to reduce stigma around substance use disorder and encourage people to seek help. People need to be able to talk honestly with their doctors about pain, substance use, recovery, and medication without fearing that an outside entity is monitoring their prescriptions and attempting to influence their medical care.
If someone develops opioid use disorder, I want them to be able to say so.
I want them to be offered treatment.
I want them to have access to naloxone.
I want them to have recovery support.
I want their physician to be able to have an honest conversation with them.
I do not want the response to be an automated determination that the patient needs to be moved off medication.
I have lived this epidemic from multiple sides.
I lost my only child, Mitchell, to an overdose.
I am also a person in recovery.
I have spent years advocating for substance use disorder treatment, overdose prevention, naloxone access, recovery, education, and families who have lost loved ones. I have a BA in Sociology from the University of Michigan with a minor in Substance Abuse Treatment, and I am a Certified Peer Recovery Coach and Certified Naloxone Trainer of Trainers.
I am not opposed to addressing opioid prescribing.
I am opposed to bad policy masquerading as opioid prevention.
We cannot say that our goal is to prevent overdose deaths while implementing policies that could destabilize legitimate medical patients and potentially push some of them toward an illicit drug supply that is far more dangerous and unpredictable.
Before Livingston County moves forward, I am asking the Commissioners to make the following information publicly available:
1. The complete resolution and scope of the proposed initiative.
2. The complete proposal submitted by Opioid Free America.
3. Any proposed contract or agreement with the vendor.
4. The specific algorithmic criteria that will be used to identify "risk."
5. The evidence supporting the use of those criteria.
6. The data-sharing, privacy, and security agreements.
7. Any legal opinions concerning HIPAA and employee/family privacy.
8. Any analysis comparing this program with the existing Michigan MAPS system.
9. The evidence demonstrating that this program will reduce overdose deaths or opioid use disorder rather than simply reduce opioid prescribing.
10. The specific opioid-settlement remediation category under which this expenditure is being justified.
11. Any evaluation of potential harms associated with inappropriate or involuntary tapering.
12. The county's plan for patients who experience withdrawal, uncontrolled pain, or transition to illicit opioids following a taper.
13. The proposed metrics for determining whether the program is actually successful.
And I am asking the Commissioners to pause this initiative until those questions have been answered publicly.
We have an opportunity to use opioid settlement dollars to do something meaningful for Livingston County.
Let's use those dollars to help people who are actually struggling with substance use disorder. Let's expand treatment. Let's strengthen recovery services. Let's put naloxone where people can access it. Let's support prevention. Let's support families. Let's invest in evidence-based interventions that save lives.
If the county can demonstrate, with credible evidence, that this program will accomplish those goals without harming legitimate medical patients, then the public deserves to see that evidence.
But "we can identify people at risk" is not enough.
And "it's HIPAA compliant" is not enough.
And "it might encourage doctors to taper patients" is certainly not enough.
We should not measure success by how many people we get off opioids.
We should measure success by how many people we keep alive, how many people with substance use disorder are able to access effective treatment and recovery, how many overdoses we prevent, and how many families do not have to bury someone they love.
I have already buried my child.
I do not want another Livingston County family to have to do the same.
Please take this proposal seriously enough to examine not only what it intends to accomplish, but also the unintended consequences it could create.
Sincerely,
Michele L. Wagner
President, Mitchell's Hope INC
Certified Peer Recovery Coach
Certified Naloxone Trainer of Trainers
SENT TO LIVINGSTON COUNTY COMMISSIONERS, OAC, MDHHS & NEWS OUTLETS 😀
