Conneticut PDMP Data Request

HIJ Action Lab filed this request with the Department of Consumer Protection of Connecticut.
Est. Completion None
Status
Fix Required

Communications

From: HIJ Action Lab

To Whom it May Concern,

We am interested in the state’s prescription monitoring program, the Connecticut Prescription Monitoring and Reporting System. Specifically, our lab, Health in Justice Action lab at Northeastern School of Law, wants to learn more about law enforcement access to the database, the use of any algorithms that produce risk assessment scores or other warning flags to analyze its contents, and the data access and retention rules governing the system. In order to permit the public to understand how the Department of Consumer Protection is using the Connecticut Prescription Monitoring and Reporting System, and how it impacts public health and civil liberties in Connecticut, we are making this request under the CT Gen Statute §§21a--254; 21a-254a; 21a-265; 21a-274;20-578; 20-626 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 risk assessment systems or services by Appriss or other vendor, including any product or service offered;

2. Any and all records including information about the algorithm that determines risk scores in the Connecticut Prescription Monitoring and Reporting System, including but not limited to its source code, developer documentation, and operator manuals; and

3. Any and all research, technical reports, or internal audits that evaluate the risk assessment tools’ effectiveness or performance

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: Department of Consumer Protection

Dear Sir:

This is to acknowledge receipt of your FOI request seeking the state’s prescription monitoring program, the Connecticut Prescription Monitoring and Reporting System. Specifically, your lab, Health in Justice Action lab at Northeastern School of Law, wants to learn more about law enforcement access to the database, the use of any algorithms that produce risk assessment scores or other warning flags to analyze its contents, and the data access and retention rules governing the system. In order to permit the public to understand how the Department of Consumer Protection is using the Connecticut Prescription Monitoring and Reporting System, and how it impacts public health and civil liberties in Connecticut, you are making this request under the CT Gen Statute §§21a--254; 21a-254a; 21a-265; 21a-274;20-578; 20-626 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 risk assessment systems or services by Appriss or other vendor, including any product or service offered;
2. Any and all records including information about the algorithm that determines risk scores in the Connecticut Prescription Monitoring and Reporting System, including but not limited to its source code, developer documentation, and operator manuals; and
3. Any and all research, technical reports, or internal audits that evaluate the risk assessment tools’ effectiveness or performance

As I understand your request, because this request involves a matter of public concern and because it is made on behalf of a nonprofit organization, you ask that the Department waive any fees. If the Department decides not to waive fees, you request that the Department permit you to examine, at your election, the responsive documents before deciding which portions to transmit. You prefer the documents in electronic format. Should the Department determine that some portion of the documents requested are exempt from disclosure, please release any reasonably segregable portions that are not exempt. In addition, you ask that the Department note the applicable statutory exemption and explain why it applies to the redacted portions. As a custodian of public records we are to comply with a request within 10 days after receipt.

Please be advised that your request will be reviewed and documentation provided if subject to disclosure within the next 20 business days. The Department will contact you if there is a fee for copies. Pursuant to the statute, copies are .25 per page.

I trust this is helpful.
Sincerely,

Vicky E. Bullock| Staff Attorney| Department of Consumer Protection|
450 Columbus Boulevard| Suite 901|Hartford CT 06103
T:860-713-6091|F:860-706-1327|vicky.bullock@ct.gov
And
Myrna Rodriguez
Paralegal Specialist
Department of Consumer Protection
Legal Division
450 Columbus Blvd. Ste. 901
Hartford, CT 06103
Rodriguez, Myrna: Myrna.Rodriguez@ct.gov
Tel. No. (860) 713-6109
Fax No. (860) 706-5401

From: Department of Consumer Protection

Dear Sir:
Let me follow-up on your previous FOI request and get back to you.
Thanks,
Vicky E. Bullock| Staff Attorney| Department of Consumer Protection|
450 Columbus Boulevard| Suite 901|Hartford CT 06103
T:860-713-6091|F:860-706-1327|vicky.bullock@ct.gov

From: HIJ Action Lab

Hi Vicky,

Thank you!

Best,

Sarah Seymour

From: Department of Consumer Protection

Dear Ms. Seymour:
In response to your recent FOI inquiry, attached please find copies of the Department’s files relative to your request. Please be advised that with regard to the question concerning the algorithm – that information is proprietary – DCP does not see or have it- but it is strictly designed according to the CDC guidelines. A lot of the specific engineering is also proprietary and would also have to be provided by Appriss directly. Should you have any additional questions, please let us know. There is no cost to you associated with this response. I trust this is helpful.

Vicky E. Bullock| Staff Attorney| Department of Consumer Protection|
450 Columbus Boulevard| Suite 901|Hartford CT 06103
T:860-713-6091|F:860-706-1327|vicky.bullock@ct.gov

From: HIJ Action Lab

Hi Vicky,

Thank you so much. Do you know an Appriss representative to connect me with regarding the risk scoring? Let me know!

Best,

Sarah Seymour

From: Department of Consumer Protection

Unfortunately the Customer Representative Manager assigned to CT would not be the appropriate contact for this inquiry. The following contact information will get the attention to who needs to address this inquiry. Thanks!

MEDIA INQUIRIES
If you’re a journalist looking to reach a Company representative on our latest news, please email us. Make sure to include contact information and deadline.
mediarelations@appriss.com

From: HIJ Action Lab

Hi Vicky,

Hope you're doing well. I just wanted to follow up on a few points.

1. The number of patient profiles within the CT PDMP.

2. Any legislation or documentation detailing the entities are allowed access into the PDMP database and to data in general.

Thank you.

Best,

Sarah

From: Department of Consumer Protection

Dear Sarah,

This is to acknowledge receipt of your email of today, April 28, 2020, and previous email. As I understand your request, you are seeking:

1. The number of patient profiles within the CT PDMP, and

2. Any legislation or documentation detailing the entities are allowed access into the PDMP database and to data in general.

Please know, per the Governor's Executive Order, we are all working remotely and our responses may be delayed.
Thanks for your patience.
Sincerely,
Vicky Bullock
Staff Attorney
Department of Consumer Protection
450 Columbus Blvd., Suite 901
Hartford, CT 06103

From: Department of Consumer Protection

Sarah,

Good Morning,

Can you provide me with a phone number so that I may contact you and hopefully address this issue. Not sure what information you have not received.

Thanks,

Vicky

_____________________________________

On April 28, 2020:
Subject: Re: Connecticut Freedom of Information Act Request: Connecticut PDMP Data Request
Dear Sarah,

This is to acknowledge receipt of your email of today, April 28, 2020, and previous email. As I understand your request, you are seeking:

1. The number of patient profiles within the CT PDMP, and

2. Any legislation or documentation detailing whether entities are allowed access into the PDMP database and to data in general.

Please know, per the Governor's Executive Order, we are all working remotely and our responses may be delayed.
Thanks for your patience.
Sincerely,
Vicky Bullock
Staff Attorney
Department of Consumer Protection
450 Columbus Blvd., Suite 901
Hartford, CT 06103

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