Unallowable Opioid Settlement Spending

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, have published guidance identifying specific items and activities that are unallowable uses of opioid settlement money. This searchable and downloadable database consolidates those lists and adds a rationale for each item's inclusion. We have also added additional items that Opioid Policy Institute (OPI) considers unallowable. This is informed by our subject matter expertise, the intention of the opioid settlement money, and Exhibit E. OPI-listed items may not yet be included on any state lists and are clearly marked as OPI additions that we hope you will consider when creating or updating your unallowable opioid settlement spending guidance.

Unallowable Spending Data

In the table below, browse items and activies definied as unallowable ways to spend opioid settlement money by various states and/or OPI.

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State Inclusion Legend
Explicitly prohibited
Not explicitly mentioned; implied under a broader prohibition
OPI addition; not on any state list
Show items on list of (Click as many as you'd like)
Category
State position
OPI resources
Showing of items
Item or activity State inclusion Rationale

Best practices

Drawn from OPI's whitepaper, Stop Wasting Opioid Settlement: Best Practices for Unallowable Opioid Settlement Spending Guidance, these principles guide how unallowable spending guidance should be developed, updated, and used.

  1. Explicit, proactive guidance is needed

    Defining what is unallowable helps decision-makers spend in ways that align with the intent of the opioid settlement money, which is reducing opioid-related death and disease. When developing guidance, start from the examples set by the states above, and the Opioid Policy Institute's additions.

  2. Responsive, reactive guidance is needed

    An ongoing review of spending can identify problematic patterns. Guidance should be updated to reflect emerging issues or provide clarification. A clear changelog and dissemination strategy helps decision-makers keep track of evolving guidance and avoid wasteful spending.

  3. Prioritize public health approaches

    The widespread prohibitions on traditional law enforcement equipment and activities signal a clear collective intent to shift funding away from supply-side enforcement and toward evidence-based, public health, and demand-side strategies. Unallowable spending guidance must support Exhibit E and the intention of the opioid settlements.

  4. Unallowable spending streamlines planning, spending, evaluation, oversight, and enforcement efforts

    Decision-makers tasked with spending opioid settlement money will benefit from clear, upfront guidance on what is and is not allowable. The same guidance helps evaluation, oversight, and enforcement bodies consistently review spending decisions.

Additional context

OPI's Perspective. Opioid settlement funds are intended improve the health and wellbeing of our communities by reducing opioid-related death and disease. Regardless of the settlement language, every dollar must be spent working towards this goal. To do this, communities should work closely with and heavily favor the input of experts-through-lived/-living experience and experts-through-training when planning, spending, and evaluating the impact of opioid settlement dollars.

OPI’s Analysis. Our analysis of the opioid settlements reflects a collaborative, team-based approach. We blend real-world and academic experience to help ensure our work is methodologically sound, grounded in evidence, and attentive to real-world implementation challenges. We focus on asking the right questions, surfacing tradeoffs, and helping communities build robust responses to addiction. OPI's team consists people with advanced degrees (PhD, MD, MPH), as well as working closely with people with lived experience.

OPI's Bias. We are skeptical of vendor claims and profiteering. These have long been issues in addiction domains and we have a finely honed sense for both.

OPI's Opioid Settlement Spending Principles:

OPI's The Opioid Settlement F.I.T. Test:

We provide a quick heurstic to help you decide if spending on an item or program aligns with the intention of the opioid settlement money. Money spent on an item or program should align with all three aspects of the F.I.T. Test:

OPI's Additions. Items marked OPI addition are not currently on any state list (April 2026). They might be added to state lists in the future. They reflect OPI's own position and rationale based on our subject matter expertise, the intention of the opioid settlement money, and Exhibit E. OPI-listed items may not yet be included on any state lists and are clearly marked as OPI addition. We hope you will consider these items and their rationales when creating or updating your unallowable opioid settlement spending guidance.

Explicit vs. Implied. A state's position on whether an item is unallowable can take two forms:

Use the state filters to see each state's list on its own, or combine filters. The "OPI additions" filter isolates items that no state lists but OPI suggests are unallowable based on our subject matter expertise, the intention of the opioid settlement money, and Exhibit E.

Source documents

The underlying guidance each state has published, plus OPI's whitepaper on unallowable spending.

Changelog

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