Comment from New York State Department of Health on VA-2026-VHA-0166-0001

Summary: The New York State Department of Health opposes the proposed rule because it expands access to sensitive Prescription Drug Monitoring Program (PDMP) data to a broad range of non-clinical users and lacks sufficient protections for non-veteran patient privacy. The Department argues that the rule should narrow the definition of authorized users, exclude researchers from real-time data access, and establish strict parameters for data interoperability and retention.