Iowa Supreme Court Issues Opinion on Public Disclosure of Documents Submitted to Board as Part of Pharmacy Investigation

Topics: Pharmacists

In an appeal filed by the Des Moines Register and Tribune Company, the Iowa Supreme Court concluded that under the state’s law, an internal audit report created by a pharmacist and voluntarily submitted to the Iowa Board of Pharmacy is subject to public disclosure. Among other things, the court held that the pharmacist’s audit report was not protected from disclosure because the report was prepared for purposes that were independent of the Board’s investigation into alleged drug diversion and the pharmacist contemporaneously provided the completed report to the medical center, the pharmacist’s employer, and the Board. The opinion in Hall v. Broadlawns Medical Center and Des Moines Register and Tribune Company (PDF) is available for download from the Iowa Judicial Branch Web site.