Over the past number of decades there has been an increasing amount of literature and media attention concerning the use of cognitive enhancing drugs (CEDs), particularly by higher education students. This increased interest in the use of CEDs by contemporary higher education students, has seemingly coincided with the spread of neoliberalism, principally in the West, into every sphere of the social environment, including higher education. Accordingly, along with the trend in wider enhancement drug use, the use of CEDs by higher education students and the apparent significance of neoliberalism to this drug trend, requires innovative theoretical developments in the area of drugs and drug use. Certainly, the use of CEDs by higher education students does not neatly fit within dominant, established drug use theories, often developed in accordance with medical perspectives, which frequently individualise, pathologize and stigmatise, via the subsequent positioning of drug users within dichotomic binaries, such as, the prevailing recreational or problematic, dichotomic binary. Therefore, this paper draws on the author’s qualitative research, to establish an innovative, ‘Functional Response Framework’ for augmenting understandings of CED use by students in higher education. In addition, a Functional Response Framework can make a significant contribution to advancing theoretical understandings of drug use, more broadly.