Guam PDMP Data Request

HIJ Action Lab filed this request with the Department Of Public Health And Social Services of Guam.
Submitted Oct. 3, 2019
Status
Awaiting Acknowledgement

Communications

From: HIJ Action Lab

Subject: Sunshine Law Request: Guam PDMP Data Request

Fax

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 Guam 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 Department of Public Health and Social Services is using the Guam Prescription Drug Monitoring Program, and how it impacts public health and civil liberties in Alaska, Northeastern University’s Institute on for Health Equity and Social Justice Research is making this request under the The Freedom of Information Act, 5 U.S.C. § 552, 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 Department of Public Health and Social Services and any outside entity regarding the Guam Prescription Drug Monitoring Program;

3. Any and all records including information about the algorithm that determines risk scores in the Guam Prescription Drug Monitoring Program, including but not limited to its source code, developer documentation, and operator manuals;

4. Any and all research, technical reports, or internal audits that define and/or evaluate the Guam Prescription Drug Monitoring Program 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 Guam Prescription Drug Monitoring Program;

7. De-identified records of algorithmic outputs (e.g. predictions or “red flags”)

8. Any record showing the number of patients in the Guam Prescription Drug Monitoring Program by quarter and year (2006-present);

9. Any record showing the number of prescribers and pharmacists in the Guam Prescription Drug Monitoring Program by quarter and year (2006-present);

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

11. Any and all records 20106-3-present of notification to law enforcement about information in the Guam Prescription Drug Monitoring Program Medical Review Group or other channels, including but not limited to how many times law enforcement agencies have been notified about information in the Guam Prescription Drug Monitoring Program, and which agencies have been notified;

12. Any and all internal policy, memoranda, and/or training documentation describing how entities outside of Department of Public Health and Social Services , including law enforcement, may obtain access to information in the Guam Prescription Drug Monitoring Program, including but not limited to the rules, regulations, and procedures of the Department of Public Health and Social Services ;

13. The legal authorization for sharing Guam Prescription Drug Monitoring Program 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 Guam Prescription Drug Monitoring Program, 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 ten days after receipt

Thank you for assistance and looking forward to hearing from you.

Sincerely,

Sarah Seymour

From: HIJ Action Lab

Subject: RE: Sunshine Law Request: Guam PDMP Data Request

Fax

Hi,

I just wanted to follow-up on this request. I am aware given the times we're in a response may not be timely but this request was presented in Oct 2019. Please get back to us with a response at your earliest convenience.

Best,

Sarah Seymour

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