New Hampshire PDMP Request

Sarah Seymour filed this request with the Board Of Pharmacy of Concord, NH.
Status
Completed

Communications

From: Sarah Seymour

To Whom It May Concern:

Northeastern University's School of Social Justice and Health Equity is interested in the New Hampshire Prescription Drug Monitoring Program ("PDMP"). Specifically, we want to learn more about law enforcement access to the database, the use of an algorithm that produces a risk score to analyze its contents, and the data access and retention rules governing the system. We understand the algorithm was produced by the corporation Appriss.

In order to permit the public to understand how the Board of Pharmacy is using the PDMP and how it impacts public health and civil liberties in New Hampshire, Northeastern University's Health in Justice Action Lab is making this request under New Hampshire's Right-to-Know law, R.S.A. Ch. 91-A for the following records:

1. Any and all records including information about the algorithm that determines risk scores in the PDMP, including but not limited to its source code, developer documentation, and operator manuals (e.g. Narx Score, Overdose Risk Score);
 
2. Any and all research, technical reports, or internal audits that evaluate the Appriss risk assessment tool’s effectiveness or performance;

3. Any and all records of de-identified red flag algorithm outputs (e.g. provider red flag, pharmacy red flag, 40 MED red flag) and patient behavioral red flags (e.g., anxious patient demeanor, distance between prescriber and dispenser) with prescriber/dispenser training documentation on how to address the red flags;
 
4. Any record showing the number of patients in the PDMP by quarter and year (2006-present);

Because this request involves a matter of public concern and because it is made on behalf of a nonprofit organization, we ask that you waive any fees. If you decide not to waive fees, we request that you permit us to examine, at our election, the responsive documents before deciding which portions to transmit. We prefer the documents in electronic format.

Should you determine that some portion of the documents requested are exempt from disclosure, please release any reasonably segregable portions that are not exempt. In addition, please note the applicable statutory exemption and explain why it applies to the redacted portions. As you know, a custodian of public records shall comply with a request within five days after receipt.

Thank you for your assistance. We look forward to your response.

Sincerely,
Sarah Seymour

From: Board Of Pharmacy

Dear Ms. Seymour:

The Board of Pharmacy/Prescription Drug Monitoring Program is in receipt of your September 12, 2019, Right to Know request for information regarding the PDMP program. The Program must conduct a search of its records in order to determine whether it has any responsive documents and review whether any such documents are exempt from disclosure. The Program anticipates it will be able to respond to your request within 30 days.
Regards,

Lindsey

Lindsey B. Courtney, J.D. | Director, Division of Health Professions
NH Office of Professional Licensure and Certification
Philbrook Building, 121 South Fruit St. Concord, NH 03301-2412

From: Sarah Seymour

Hi Lindsey,

Thank you and looking forward to hearing from your department in regards to our request.

Best,

HIJ Action Lab

From: Board Of Pharmacy

Good Afternoon,

Please accept the following as our response to the Right to Know Request dated September 12, 2019.

1. Any and all records including information about the algorithm that determines risk scores in the PDMP, including but not limited to its source code, developer documentation, and operator manuals (e.g. Narx Score, Overdose Risk Score);

NH PDMP does not use NaRX Care and it is our understanding that his information is proprietary to the vendor APPRISS.

2. Any and all research, technical reports, or internal audits that evaluate the Appriss risk assessment tool's effectiveness or performance;

N/A

2. Any and all records of de-identified red flag algorithm outputs (e.g. provider red flag, pharmacy red flag, 40 MED red flag) and patient behavioral red flags (e.g., anxious patient demeanor, distance between prescriber and dispenser) with prescriber/dispenser training documentation on how to address the red flags;

NH Clinical Alerts are pending. The first clinical alert planned for release will be for multi provider/multi pharmacy. This algorithm is set to create a report to a prescriber when a patient has exceeded three or more prescribers OR three or more pharmacies.

4. Any record showing the number of patients in the PDMP by quarter and year (2006-present);

NH data by law had to be purged every six months until legislation was changed in 2014 with SB31 but not before all data from 2014 was purged and most of Q1 2015.
Here are data by Calendar Year Quarters 2015 thru Q3 of calendar year 2019, which was last Monday.
These represent patients with NH addresses who filled at least one RX in the quarter.
As you know, please remind the recipients, one cannot sum each quarter to get a full year for distinct patients as some patients appear in multiple quarters.
The past 2 state fiscal years had approximately 300,000 distinct patients each SFY.

Distinct Patient ID Count

Q1

Q2

Q3

Q4

Calendar Year 2015

11,392

168,086

193,422

191,954

Calendar Year 2016

189,138

183,661

179,760

179,602

Calendar Year 2017

174,200

170,479

166,583

165,962

Calendar Year 2018

164,379

162,187

157,674

145,461

Calendar Year 2019

135,404

132,314

128,342

Kind Regards,

Michelle

Michelle R. Ricco Jonas, M.A., CPM
Program Administrator
Office of Professional Licensure and Certification
NH Prescription Drug Monitoring Program
121 South Fruit Street
Concord, NH 03301
Tele: (603)271-6980
Fax: (603) 271-2856

"He who makes a difference in one life, changes the world." - Unknown

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From: Sarah Seymour

Hi Michelle,

Thank you so much for assistance. Does the New Hampshire PDMP utilize any other risk score algorithms apart from NarxCare? If so, could you provide any related documentation pertaining to those risk scores. Thanks again!

Best,

HIJ Action Lab

From: Board Of Pharmacy

Good Afternoon,

There were a total of three algorithms approved however we are currently only initiating one – multiple provider/multiple pharmacy.

The other two algorithms include but have not been initiated at this time and are still under evaluation:

High MME:

What is our definition? A patient’s active current prescriptions are estimated to provide a daily dose of opioids that exceeds
What is our criteria/value? 100 MME
What is our threshold/? over a 90 day period.

Concurrent Benzodiazepines and Opioids:

What is our definition? A patient’s active current prescriptions include
What is our criteria? both an opioid and a benzodiazepine
What is our threshold? over a 90 day period

Kind Regards,

Michelle

Michelle R. Ricco Jonas, M.A., CPM
Program Administrator
Office of Professional Licensure and Certification
NH Prescription Drug Monitoring Program
121 South Fruit Street
Concord, NH 03301
Tele: (603)271-6980
Fax: (603) 271-2856

“He who makes a difference in one life, changes the world.” – Unknown

Confidentiality Note: This e-mail, and any attachment to it, is intended to be confidential and might be legally privileged. It is intended solely for the use of the addressee. If you are not the intended recipient, you are hereby notified that reading, copying, disseminating or distributing this email is strictly prohibited. If you have received this e-mail in error, please immediately return it to the sender and delete it from your system. Thank you.

From: Sarah Seymour

Hi Michelle,

Great! Thank you! Is there any evaluation reports on the multiple provider/multiple pharmacy algorithm? If so or if not, let me know. I really appreciate your help.

Best,

Sarah Seymour
HIJ Action Lab

From: Board Of Pharmacy

Good Morning
No there is no evaluation on this metric.

Kind Regards,

Michelle

Michelle R. Ricco Jonas, M.A., CPM
Program Administrator
Office of Professional Licensure and Certification
NH Prescription Drug Monitoring Program
121 South Fruit Street
Concord, NH 03301
Tele: (603)271-6980
Fax: (603) 271-2856

“He who makes a difference in one life, changes the world.” – Unknown

Confidentiality Note: This e-mail, and any attachment to it, is intended to be confidential and might be legally privileged. It is intended solely for the use of the addressee. If you are not the intended recipient, you are hereby notified that reading, copying, disseminating or distributing this email is strictly prohibited. If you have received this e-mail in error, please immediately return it to the sender and delete it from your system. Thank you.

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