Comment from Janice Garland

I have a problem with Bamboo Health's Narxcare scoring application. It was created, implemented and used without any disclosure of how this software was created. However through the years I read that Appriss , the original developer was allowed access to the records of deceased "overdose" patients records. The fact that this scoring tool was created by using autopsy and PDMP data simply doesn't guarantee anything b/c the CDC own data at the time of development was counting prescription opiods with illicit fentanyl. This is a known fact because the CDC representative testified in front of Congress in 2018. In addition to that the CDC's own data base called WONDER listed the overdose deaths as poly substance with an average of 6 substances almost always including alcohol and marijuana. Bamboo Health purchased the PDMP systems which included Narxcare from Appriss. It's more disturbing that the owners of this software is owned by 2 equity firms which often are only profit driven with little oversight. It's imperative that the FDA review these software tools used on the public. Appriss now Bamboo health has refused repeatedly since Narxcare 's inception that the information is proprietary. There's no device or drug that the companies can say how it works is "proprietary" and we aren't going to tell the FDA or the public how it is used. Especially in the case of Narxcare that weaponizes life events such as abuse or medications prescribed together for decades. We the public that this software is being used as a weapon to deny even carefully prescribed opioids is leading to deaths by suicide. So tell me how the Narxcare is helping?