Georgia PDMP Data Request

Sarah Seymour filed this request with the Department of Public Health of Georgia.
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 state’s prescription monitoring program, the Georgia Prescription Drug Monitoring Program. Specifically, we want to learn more about law enforcement access to the database, the use of an algorithm that produces a risk assessment 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 Health.

In order to permit the public to understand how the Georgia Department of Public Health is using the Georgia PDMP, and how it impacts public health and civil liberties in Georgia, Northeastern University’s Health in Justice Action Lab is making this request under the Georgia Open Records Act § 50.18.70 et seq., for the following records:

1. Any and all records reflecting an agreement for purchase, acquisition, or licensing of, or permission to use, test, or evaluate Appriss’s systems or services, including any product or service offered;

2. Any and all memoranda of understanding between the Georgia Department of Public Health and any outside entity regarding the Georgia PDMP.

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

4. Any and all research, technical reports, or internal audits that define and/or evaluate the Georgia PDMP effectiveness or performance;

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

6. Any document containing a full list of the data fields in the Georgia PDMP;

7. 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;

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

9. Any record showing the number of prescribers and pharmacists in the Georgia PDMP by quarter and year (2006-present);

10. Any and all records containing Georgia Department of Public Health analysis of whether and/or how the Georgia PDMP has impacted public health in Georgia (e.g. decrease or increase in overdose rates, “doctor shopping,” prescribing volume, etc.) over time;

11. Any and all records 2006-present of notification to law enforcement about information in the Georgia PDMP Medical Review Group or other channels, including but not limited to how many times law enforcement agencies have been notified about information in the Georgia PDMP, and which agencies have been notified;

12. Any and all internal policy, memoranda, and/or training documentation describing how entities outside of Georgia Department of Public Health, including law enforcement, may obtain access to information in the Georgia PDMP, including but not limited to the rules, regulations, and procedures of the Medical Review Group;

13. The legal authorization for sharing Georgia PDMP information with the law enforcement entities; and

14. Any and all records showing how often law enforcement entities or individuals have requested information or records from the Georgia PDMP, or made electronic queries of the system, including but not limited to what types of information or records have been requested, which agencies have made the requests, the percent of requests that were accepted versus denied, temporal trends, the form of the request (e.g. subpoena, warrant, etc.), and whether the requests were granted or denied.

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 three days after receipt.

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

Sincerely,
Sarah Seymour

From: Department of Public Health

Good afternoon,

Please see the attached pdf and zipped folder containing the Department’s response to your below Georgia Open Records Act request.

Do not hesitate to reach out should you have any difficulties with the attachments or accessing the files contained therein.

Sincerely,

Meredith Grant
Associate General Counsel, Privacy Officer
Georgia Department of Public Health
2 Peachtree Street NW, Floor 15
Atlanta, GA 30303
Phone: (404) 657-2700
Email: DPH-OpenRecords@dph.ga.gov<mailto:DPH-OpenRecords@dph.ga.gov>

Reader Advisory Notice: Email to and from a Georgia state agency is generally public record, except for content that is confidential under specific laws. Security by encryption is applied to all confidential information sent by email from the Georgia Department of Public Health (DPH). This message is only intended for specific recipient(s) and may contain privileged, private or sensitive information. If you received this message in error, please delete it and contact me.

From: Sarah Seymour

Hi Meredith,

Thank you for your response. Could you potential reference to which article contains both point 12 and 13. Thank you.

Sincerely,

HIJ Action Lab

From: Department of Public Health

O.C.G.A. § 16-13-57, et seq. and Ga. Comp. R. & Regs. 511-7-2

From: Sarah Seymour

Hi Meredith,

Again, thank you so much for your assistance. We were wondering if you have any related documents for item numbers 2, 3, 5, and 7? Let us know when you get a chance.

Best,

Sarah Seymour
HIJ Action Lab

From: Department of Public Health

Good morning,

As stated in the Department’s letter dated September 17, 2019 (attached for reference), the Department has no records in response to your second, third, fifth, and seventh requests.

Sincerely,

Meredith Grant
Associate General Counsel, Privacy Officer
Georgia Department of Public Health
2 Peachtree Street NW, Floor 15
Atlanta, GA 30303
Phone: (404) 657-2700
Email: DPH-OpenRecords@dph.ga.gov<mailto:DPH-OpenRecords@dph.ga.gov>

Reader Advisory Notice: Email to and from a Georgia state agency is generally public record, except for content that is confidential under specific laws. Security by encryption is applied to all confidential information sent by email from the Georgia Department of Public Health (DPH). This message is only intended for specific recipient(s) and may contain privileged, private or sensitive information. If you received this message in error, please delete it and contact me.

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