Oregon PDMP Data Request
| Submitted | Nov. 4, 2019 |
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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 OR PDMP. 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 Oregon Health Authority is using the OR PDMP and how it impacts public health and civil liberties in Oregon, Northeastern University’s Health in Justice Action Lab is making this request under the Oregon Public Records Law § 192.410 et seq., for the following records:
1. Any and all memoranda of understanding between the Oregon Health Authority and any outside entity regarding the OR PDMP.
2. Any and all records including information about the algorithm that determines risk scores in the OR PDMP, including but not limited to its source code, developer documentation, and operator manuals;
3. Any and all research, technical reports, or internal audits that define and/or evaluate the OR PDMP effectiveness or performance;
4. Any record showing the number of patients in the OR 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 ten days after receipt.
Thank you in advance for your anticipated cooperation in this matter.
I look forward to receiving your response to this request within ten days.
Sincerely,
Sarah Seymour
From: Oregon Health Authority
Thank you for your request. I am forwarding this to the OHA Public records email. Please use this box for future requests.
My colleague Jeanne will begin processing your request.
Keely L. West, J.D.
Central Operations Manager
Oregon Health Authority
503-945-6292
She|Her|Hers
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~WRD000
From: Oregon Health Authority
VIA EMAIL ONLY - s.seymour@northeastern.edu<mailto:s.seymour@northeastern.edu>
November 4, 2019
Ms. Sarah Seymour
Project Coordinator, Health In Justice Action Lab
School of Social Justice and Health Equity
Northeastern University
360 Huntington Avenue
Boston, MA 02115
Re: Public Records Request - Oregon Prescription Drug Monitoring Program (2019-0969)
Dear Ms. Seymour,
This will confirm that Oregon Health Authority received your November 4, 2019 public records request for records related to the Oregon Prescription Drug Monitoring Program, specifically:
1. Any and all memoranda of understanding between the Oregon Health Authority and any outside entity regarding the OR PDMP;
2. Any and all records including information about the algorithm that determines risk scores in the OR PDMP, including but not limited to its source code, developer documentation, and operator manuals;
3. Any and all research, technical reports, or internal audits that define and/or evaluate the OR PDMP effectiveness or performance; and
4. Any record showing the number of patients in the OR PDMP by quarter and year (2006-present);
These specific requests were included in your earlier 14 public records requests of June 24, 2019. I will, however, restate the responses in RED, as follows:
1. Any and all memoranda of understanding between the Oregon Health Authority and any outside entity regarding the OR PDMP
We have memoranda of understandings with several states and the National Association of Boards of Pharmacy for purposes of interstate data sharing to prescribers and pharmacists only
1. Any and all records including information about the algorithm that determines risk scores in the OR PDMP, including but not limited to its source code, developer documentation, and operator manuals
There are no responsive records to this request. The Oregon PDMP does not produce "risk scores" or "risk assessments" regarding patient data
1. Any and all research, technical reports, or internal audits that define and/or evaluate the OR PDMP effectiveness or performance
Please see attached Oregon Secretary of State Audit:
1. Any record showing the number of patients in the OR PDMP by quarter and year (2006-present);
Please see our Opioid Data for Oregon dashboard, this is our most current analysis of data from the PDMP:
https://www.oregon.gov/oha/PH/PREVENTIONWELLNESS/SAFELIVING/PDMP/Pages/reports.aspx
This will complete your request.
Jeanne Windham
Public Records and Internal Litigation Process Coordinator
OREGON HEALTH AUTHORITY
Fiscal and Operations Division
500 Summer St. NE, E-20
Salem, OR 97301
(503) 947-5593
jeanne.windham@dhsoha.state.or.us<mailto:jeanne.windham@dhsoha.state.or.us>
http://www.oregon.gov/OHA
From: HIJ Action Lab
Hi Jeanne,
Apologies for the late response and hope you're staying well. I wanted to clarify a couple of points and request a follow-up if you do not mind.
First, may you please provide documentation detailing the NABP MOU.
Second, in regard to the number of patients in the PDMP, we are specifically requesting the number of unique patients within the PDMP, whether that be annually or quarterly. They do not have to be broken down by type of prescription they are receiving or any other dispensing information.
Lastly, in following risk indicators for "doctor-shopping", does your department possess any trainings on how to identify and respond to patient behavioral red flags (e.g., anxious patient demeanor, distance between prescriber and dispenser)?
Let us know if you need more clarification or do not have the responsive documents on hand.
Thank you!
Best,
Sarah Seymour
From: Oregon Health Authority
VIA EMAIL ONLY - s.seymour@northeastern.edu<mailto:s.seymour@northeastern.edu>
May 26, 2020
Ms. Sarah Seymour
Project Coordinator, Health In Justice Action Lab
School of Social Justice and Health Equity
Northeastern University
360 Huntington Avenue
Boston, MA 02115
Re: Public Records Request - Oregon Prescription Drug Monitoring Program (2019-0969)
Dear Ms. Seymour,
This will confirm Oregon Health Authority received your May 18, 2020 public records request for a copy of the OHA/National Association of Boards of Pharmacy MOU. You have also requested (1) the number of unique patients within the PDMP, whether that be annually or quarterly and (2) whether OHA possesses any trainings on how to identify and respond to patient behavioral red flags (e.g., anxious patient demeanor, distance between prescriber and dispenser).
Most requests are completed within fifteen (15) business days. However, please be aware that OHA is responsible for many areas of support in response to the current COVID-19 emergency. Program staff with access to records, communications staff, and records staff are being redirected to support essential tasks and may be unavailable to complete requests within statutory timelines. Requests that are expected to go beyond fifteen (15) business days will receive an estimated timeline and periodic updates on the status of the request. Thank you for your patience in this regard.
Sincerely,
Jeanne Windham
Public Records and Internal Litigation Process Coordinator
OREGON HEALTH AUTHORITY
Fiscal and Operations Division
500 Summer St. NE, E-20
Salem, OR 97301
(971) 673-5057
jeanne.windham@dhsoha.state.or.us<mailto:jeanne.windham@dhsoha.state.or.us>
From: Oregon Health Authority
VIA EMAIL ONLY - s.seymour@northeastern.edu<mailto:s.seymour@northeastern.edu>
May 26, 2020
Ms. Sarah Seymour
Project Coordinator, Health In Justice Action Lab
School of Social Justice and Health Equity
Northeastern University
360 Huntington Avenue
Boston, MA 02115
Re: Public Records Request - OHA MOU with National Association of Boards of Pharmacy (2020-0500)
Dear Ms. Seymour,
You have requested a copy of the OHA/National Association of Boards of Pharmacy MOU. You have also requested (1) the number of unique patients within the PDMP, whether that be annually or quarterly and (2) whether OHA possesses any trainings on how to identify and respond to patient behavioral red flags (e.g., anxious patient demeanor, distance between prescriber and dispenser).
The information on the NABP MOU are all publicly available on the NABP's website and details of the NABP hub PMPi can be found here<https://nabp.pharmacy/initiatives/pmp-interconnect/> including descriptions, FAQs, Maps, and funding. A copy of the MOU is attached here as well as the Oregon PMPi worksheet.
Here are the number of patients reported to the PDMP annually*
* 2017: 1,293,706
* 2018: 1,245,947
* 2019: 1,233,426
* Disclaimer The PDMP collects a limited set of information on patients including name, DOB, sex, and location, but does not collect a unique identifier such as SSN, insurance number, medical record, or other identifier that uniquely describes each patient. The vendor provided algorithm to identify patients is allergic to falsely matching records; these numbers are from a public health analytic dataset that uses a secondary probabilistic matching algorithm to more completely match patient records. Further, during this time period, the PDMP changed vendors and thus the initial vendor matching algorithm changed. Additionally, the drugs reported over the time period have not stayed static as more drugs and drug classes have been made reportable to the PDMP so you would expect the number of patients to increase after more drugs/drug classes are reportable.
Finally, the Oregon Prescription Drug Monitoring Program itself does not provide training to prescribers with regards to "doctor shopping" or on other fraudulent behavior, that is outside the scope of the PDMP staff to provide such training. We do however work in cooperation or partnership with organizations that do provide such training including OregonPainGuidance<http://www.oregonpainguidance.org/> and the Oregon Health Authority's various workgroups including the Opioid Prescribing Guidelines Task Force<https://www.oregon.gov/oha/PH/PREVENTIONWELLNESS/SUBSTANCEUSE/OPIOIDS/Pages/task-force.aspx>.
There is no charge for these records. This will complete your request.
Jeanne Windham
Public Records and Internal Litigation Process Coordinator
OREGON HEALTH AUTHORITY
Fiscal and Operations Division
500 Summer St. NE, E-20
Salem, OR 97301
(971) 673-5057
jeanne.windham@dhsoha.state.or.us<mailto:jeanne.windham@dhsoha.state.or.us>
http://www.oregon.gov/OHA
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