Alaska PDMP Data Request
| Submitted | Oct. 3, 2019 |
| Due | Oct. 21, 2019 |
| Est. Completion | None |
MuckRock users can file, duplicate, track, and share public records requests like this one. Learn more.
Communications
From: HIJ Action Lab
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 Alaska 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 Board of Pharmacy is using the Alaska Prescription Drug Monitoring Program, and how it impacts public health and civil liberties in Alaska, Northeastern University’s Health in Justice Action Lab is making this request under the Alaska Open Records Law, A.S. Code § 40-25-110 et seq. for the following records:
1. Any and all memoranda of understanding between the Board of Pharmacy and any outside entity regarding the Alaska Prescription Drug Monitoring Program.
2. Any and all records including information about the algorithm that determines risk scores in the Alaska Prescription Drug Monitoring Program, including but not limited to its source code, developer documentation, and operator manuals (e.g. NarxScore, Overdose Risk Score);
3. Any and all research, technical reports, or internal audits that evaluate the Appriss risk assessment tool’s effectiveness or performance; and
4. 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
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 10 days after receipt.
Thank you for your assistance. We look forward to your response.
Sincerely,
Sarah Seymour
From: Alaska Board Of Pharmacy
Dear Ms. Seymour:
In am in receipt of your email to the Alaska Board of Pharmacy on October 3, 2019, requesting information and documentation with regard to the Alaska Prescription Drug Monitoring Program. I will be your contact regarding this request. Such requests are handled in accordance with the Alaska Public Records Act [AS 40.25.100 et seq.] and the regulations promulgated under the Act [2 AAC 96.100 et seq.].
The responses to your requests are in the order in which they were outlined in your email dated October 3, 2019, as follows:
1. Any and all memoranda of understanding between the Board of Pharmacy and any outside entity regarding the Alaska Prescription Drug Monitoring Program.
This document was provided to you in your request for these same records on April 9, 2019, and that document is the most current document on file with this division. It is also attached to this email.
As this division does not have the following requested records and information available, please direct your requests for the below records and information to Appriss. Contact information for Appriss is as follows: jcooper@apprisshealth.com<mailto:jcooper@apprisshealth.com>; cheslin@apprisshealth.com<mailto:cheslin@apprisshealth.com>.
2. Any and all records including information about the algorithm that determines risk scores in the Alaska Prescription Drug Monitoring Program, including but not limited to its source code, developer documentation, and operator manuals (e.g. NarxScore, Overdose Risk Score);
3. Any and all research, technical reports, or internal audits that evaluate the Appriss risk assessment tool's effectiveness or performance; and
4. 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.
The records and information that was not provided in response to your request is in accordance with the Alaska Public Records Act (AS 40.25.120 et seq.) and the regulations promulgated in accordance with the Act (2 AAC 96.100 et seq.) and is, therefore, denied. All other information the division has responsive to your request has been provided in this response.
Director Sara Chambers has delegated authority to me to deny the parts of this request that have been denied. You may immediately appeal this decision by seeking injunctive relief from the Alaska Superior Court. Additionally, you may ask Ms. Chambers for reconsideration. Such a request does not require the posting of an appeal bond. For more on this process, please review the attached regulations, particularly 2 AAC 96.340. If you choose not to pursue injunctive relief in the Alaska Superior Court, your rights before the division, including requesting reconsideration, will not be adversely affected.
Best regards,
JULIE ANDERSON, COMMISSIONER
[cid:image003.png@01D57CEF.5BA4E9A0]
By:
Marilyn Zimmerman, Paralegal for
Sara Chambers, Director
Division of Corporations, Business
and Professional Licensing
Marilyn Zimmerman, RP
Paralegal II
Division of Corporations, Business and Professional Licensing
Alaska Department of Commerce, Community, and Economic Development
PO Box 110806
Juneau, AK 99811-0806
Phone: (907) 465-1673
marilyn.zimmerman@alaska.gov<mailto:marilyn.zimmerman@alaska.gov>
Fax: (907) 465-2974
Please note I do not have a direct fax line. Sending documents via email will bring them to my attention sooner.
Disclaimer: This message may contain confidential or privileged information and is intended only for the use of the addressee named herein. The documents attached to this email are considered legal documents. If you are not the intended recipient of this message, you are hereby notified you must not use, copy, disclose, or take any action based on this message or information herein. If you have received this message in error, please advise the sender immediately and delete this message. Thank you.
From: Muckrock Staff
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 Alaska 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 Board of Pharmacy is using the Alaska Prescription Drug Monitoring Program, and how it impacts public health and civil liberties in Alaska, Northeastern University’s Health in Justice Action Lab is making this request under the Alaska Open Records Law, A.S. Code § 40-25-110 et seq. for the following records:
1. Any and all memoranda of understanding between the Board of Pharmacy and any outside entity regarding the Alaska Prescription Drug Monitoring Program.
2. Any and all records including information about the algorithm that determines risk scores in the Alaska Prescription Drug Monitoring Program, including but not limited to its source code, developer documentation, and operator manuals (e.g. NarxScore, Overdose Risk Score);
3. Any and all research, technical reports, or internal audits that evaluate the Appriss risk assessment tool’s effectiveness or performance; and
4. 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
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 10 days after receipt.
Thank you for your assistance. We look forward to your response.
Sincerely,
Sarah Seymour
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following Alaska Public Records Act request, copied below, and originally submitted on Oct. 3, 2019. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following Alaska Public Records Act request, copied below, and originally submitted on Oct. 3, 2019. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
Files
pages