Goal 1; Objective B: Improve health care quality and patient safety: Performance measure

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1 TRUST FOR AMERICA S HEALTH COMMENTS ON THE DEPARTMENT OF HEALTH AND HUMAN SERVICES (HHS) DRAFT STRATEGIC PLAN Goal 1; Objective B: Improve health care quality and patient safety: Performance measure Goal 1; Objective B Performance Measure: Add a measure on seasonal influenza vaccination rates of healthcare workers. The Advisory Committee on Immunization Practices has recommended since 1986 that all healthcare personnel, except those with medical contraindications, receive the seasonal flu vaccine. The Secretary and CDC director have publicly identified flu vaccination of healthcare personnel as a goal. According to the most recent data, for , seasonal vaccine coverage for healthcare personnel was 61.9 percent, the first year the rate has exceeded 50 percent. 1 CDC already collects and publishes this data. We urge HHS to set this goal as close to 100 percent as possible by Goal 1: Transform Health Care; Objective C: Emphasize primary and preventive care linked with community prevention services Trust for America s Health commends the Department for recognizing the important link between clinical preventive services and community-based prevention. Too often, clinical prevention activities, including screenings and other provider-based services, have been disconnected from efforts to promote prevention at the community-level, such as improving communities access to nutrition foods, creating environments that encourage physical activity, and building smoke-free communities, Clinical health services and public health must work in concert to transform the health care system from a sick care system to one that value and promotes health. TFAH urges HHS to further emphasize the importance of improving the association between clinical and community prevention by developing strategies to promote coordination among the relevant practitioners in each field. In the HHS Strategic Plan, TFAH encourages the Department to add an additional strategy to Goal 1; Objective C, as follows: Support rapid communication and coordination between public health practitioners and clinicians to ensure evidence-based prevention of risk factors and conditions. In addition to promoting coordination among practitioners, HHS should improve coordination of prevention-related activities across its agencies.. For example, investments in promoting physical activity through the Centers for Disease Control and Prevention (CDC) can reinforce the Administration on Aging s efforts to prevent falls among seniors, the Substance Abuse and Mental Health Services Administration s work to reduce depression and the Centers for Medicare and Medicaid Services activities to reduce complications from diabetes. The Affordable Care Act (ACA) presents the opportunity to better align these efforts through the 1 CDC, MMWR Weekly, Interim Results: Influenza A (H1N1) 2009 Monovalent and Seasonal Influenza Vaccination Coverage Among Health-Care Personnel --- United States, August January April 2, 2010 / 59(12);

2 development of the National Prevention and Health Promotion Strategy and the investments of the Prevention and Public Health Fund. TFAH urges HHS to include a strategy under Goal 1; Objective C focused on coordinating prevention activities among HHS agencies. Goal 1; Objective C Performance Measure: TFAH urges the Department to identify and include measures of CDC s performance in funding, implementing and monitoring community preventive services. Goal 1, Objective F: Promote the adoption and meaningful use of health information technology The Office of the National Coordinator for Health IT (ONC) has a tremendous opportunity to improve the public s health. Widespread use of HIT can increase the utilization and effectiveness of preventive health services, through processes such as automatic vaccine reminders, registries to identify and monitor at-risk populations and other tools. As public health departments develop IT capacity and become appropriately linked with clinical electronic health records (EHRs), HIT holds the potential to significantly improve biosurveillance, disease detection, and response. However, many public health departments lack the technological capability, workforce expertise and connections to EHRs to maximize HIT s potential to improve public health. Trust for America s Health urges HHS to bolster the public health potential of HIT and to include an additional strategy under Goal 1; Objective F, as follows: Build the capacity of public health departments, with appropriate privacy safeguards, to use electronic health data to support rapid detection and response to disease outbreaks, identify at-risk populations, and develop appropriate public health interventions. Goal 2, Accelerate Scientific Knowledge and Innovation. The growing spate of antimicrobial resistant (AMR) organisms is perhaps the most significant public health risk the nation faces in the next few decades. What were once treatable infections could become as deadly as any new pathogen. Combating AMR through judicious use of antibiotics and shoring up the pipeline of new antimicrobial products are imperative. Trust for America s Health urges HHS to develop a new objective under Goal 2 (or as part of Goal 3, Objective E), as follows: Objective: Stem the growth of antimicrobial resistance. This new goal can be achieved through numerous strategies, some of which are already underway at HHS and USDA: 2

3 Identify an entity within HHS to oversee a national antimicrobial resistance strategy and coordinate its implementation across the Department, including FDA, NIH, CDC, and CMS, and in coordination with other agencies, including USDA. Reduce the overuse of antimicrobials in healthcare settings through education of consumers and clinicians about appropriate use. Develop and clarify new and existing regulatory pathways at FDA to encourage development of new antimicrobial products. Goal 2; Objective C: Invest in the regulatory sciences to improve food and medical product safety There must be increased coordination and leadership across HHS to prompt development of new antimicrobial products. FDA leadership has expressed a commitment to regulatory science as a means of spurring innovation. 2 Existing clinical trial designs are insufficient for antimicrobial development, so FDA must work with NIH and other scientific entities to develop new clinical trial end-points. New Goal 2; Objective C Performance Measure: FDA should publish new guidances on the use of novel end-points that reliably measure how a patient feels and functions or predict survival. These new end-points would promote innovation and predictability in the development of safe and effective antimicrobial products by developing new scientific standards and evaluation frameworks to guide antimicrobial-related regulatory decisions. Goal 2: Advance Scientific Knowledge and Innovation; Objective D: Increase our understanding of what works in public health and human service practice Trust for America s Health applauds Objective D s emphasis on learning what works in public health practice and rapidly integrating this learning into program implementation. We strongly support the Department s focus on improving the quality of public health practice by conducting applied, translational, and operations research and evaluations. TFAH has long supported developing a comprehensive system of accountability for investments in public health and prevention. We believe in measurement, including the development of appropriate measures of public health performance. We encourage the Department to include strategies in Goal 2; Objective D that focus on building the tools, such as performance measures, that can help us better evaluate investments in public health. Additionally, TFAH supports the Department s commitment in Objective D to expanding the evidence base for public health. An important component in identifying what works in public health is to support investments that will help to build the evidence base. It is imperative to continue to test new, innovative public health strategies that can contribute to our understanding of promising practices, in addition to funding those programs already proven to work. 2 /BBND/FDA-NIAID-IDSA_Public_Workshop/Session%204B%20- %2015%20Borio%20AR%20Presentation_optimized.pdf 3

4 The Affordable Care Act included specific provisions to improve the research and practice of evidence-based public health, specifically Section 4301 regarding Research on Optimizing the Delivery of Public Health Services. Section 4301 directs the Secretary to fund public health services and systems research. These investments should include examining best practices relating to prevention, with a particular focus on high priority areas identified by the Secretary in the National Prevention Strategy or Healthy People 2020; analyzing the translation of interventions to real-world settings; and identifying effective strategies for organizing, financing or delivering public health services in real world community settings, including comparing State and local health department structures and systems in terms of effectiveness and cost. TFAH urges the Department to include in the strategies for Goal 2; Objective D support for and investments in innovative public health practices to help develop new evidence-based programs and practices. Goal 3: Advance the Health, Safety, and Well-Being of the American People Trust for America s Health applauds the inclusion of Goal 3 in the HHS Strategic Plan. However, the description of Goal 3 overlooks important provisions in the Affordable Care Act focused on improving the nation s health, specially the National Prevention, Health Promotion and Public Health Council; the National Prevention and Health Promotion Strategy and the Prevention and Public Health Fund. Together, these provisions will help to establish and fund a national framework for prevention, wellness and public health activities that will drive success on Goal 3 of the Department s strategic plan. TFAH urges the Department to amend is description of Goal 3 to focus on the role the National Prevention, Health Promotion and Public Health Council; the National Prevention and Health Promotion Strategy and the Prevention and Public Health Fund will play in the Department s efforts to advance the health, safety and well-being of the American People between now and Goal 3; Objective D: Promote prevention and wellness Although Trust for America s Health is pleased to see prioritization of disease prevention and wellness included in the Strategic Plan, we urge HHS to broaden its focus beyond those conditions that result in the most deaths, disability, and costs. To best promote prevention and wellness, the Department s plan should recognize that public health priorities may vary by community, demographic population, or state. Similarly, the effects of different types of interventions will vary depending on cultural or other demographic, geographic, and socioeconomic features. There should not be a one size fits all approach to wellness promotion. In addition, focusing only on the leading causes of death will reinforce the condition-specific federal funding stovepipes that currently exist and limit our capacity to invest in comprehensive, innovative, and cross-cutting approaches to disease prevention. TFAH urges the Secretary to focus on the interactions of conditions and risk factors, rather than disease silos. We urge HHS to include in its strategies the development of interventions that 4

5 cross-cutting and responsive to local needs, as envisioned in the Community Transformation Grants created in ACA. For Goal 3; Objective D Performance Measures: TFAH urges the Department to identify and include measures of physical activity promotion and obesity prevention and reduction; measures of prevention of STDs; measures of injury prevention and other measures of public health performance in promoting prevention and wellness. Goal 3; Objective D Performance Measures: Add a performance measure reflecting CDC s stated goal for 75 percent of foodborne outbreaks to have a preliminary report in the electronic Food-borne Outbreak Reporting System (efors) within 60 days of the date the first individual became ill. 3 The ability of state and local health departments to detect and report foodborne outbreaks varies widely by jurisdiction. Not only is food safety a primary function of health departments, but is an indication of the state/local department s ability to detect and respond to other infectious agents. HHS must work to support and build capacity to track and respond to foodborne illness at the frontlines. Goal 3; Objective E Performance Measures: TFAH urges the Department to identify and include measures of HIV screening, STD screening, TB screening and other infectious disease prevention strategies. We also urge you to include a new performance measure to increase the number of children receiving all recommended vaccines by pre-school age. CDC collects this data through the National Immunization Survey. 4 Through implementation of ACA, most American children should be eligible for recommended vaccines at no out-of-pocket cost. Including such a measure would test both the nation s vaccine system and implementation of prevention provisions in health reform. Goal 5: Strengthen the Nation s Health and Human Service Infrastructure and Workforce; Objective C: Enhance the ability of the public health workforce to improve public health at home and abroad. Trust for America s Health is pleased that the public health workforce is identified as one of HHS workforce priorities. TFAH has long noted that unpredictable funding streams, compounded by the economic recession, have led to a substantial erosion of the public health workforce. Without a well-trained public health workforce working at capacity, our ability to prevent diseases and respond to public health emergencies in severely diminished. The Affordable Care Act authorized several programs that are intended to bolster the public health workforce, including Public Health Workforce Recruitment and Retention Programs (Sec. 5204), Training for Mid-Career Public and Allied Health Professionals (Sec. 5206), Grants to Promote the Community Health Workforce (Sec. 5313), and Fellowship Training in Public Health (Sec. 5314). 3 U.S. Centers for Disease Control and Prevention. Epidemiology and Laboratory Capacity for Infectious Diseases Funding Announcement FY U.S. Department of Health and Human Services

6 HHS workforce strategy should include implementation of the public health workforce programs authorized by ACA. TFAH urges the Department to include, in Goal 5; Objective C, a strategy aimed at improving recruitment, training and retention of public health professionals across all levels of government. In addition, HHS should explore the role that public health accreditation can play in improving the quality and capacity of the public health workforce. Accreditation of public health departments is a process to ensure governmental public health can meet an accepted set of standards, with the objective of achieving a baseline of quality and performance across the public health system. The strategies identified for Goal 5; Objective C should include supporting measures of public health quality and capacity, such as accreditation of public health departments. They also should include supporting the necessary technical assistance to help health departments meet these standards. Goal 5: Strengthen the Nation s Health and Human Service Infrastructure and Workforce; Objective E: Improve national, state, local, and tribal surveillance and epidemiology capacity. The nation s laboratory and epidemiological capacity has eroded as limited resources have led to the loss of trained staff and an inability to update technologies. Trust for America s Health urges HHS to expand the strategies identified in Goal 5; Objective E to include the following: The Affordable Care Act authorizes important investments in strengthening the nation s surveillance and epidemiology capacity. TFAH urges the Department to include funding of these ACA provisions in its strategies for improving surveillance and epidemiology capacity. The Department s strategic plan should clarify how various disease surveillance programs within the Department will be coordinated across agencies, with other federal departments, and with state and local health departments. FDA and CDC should work together to build the nation s foodborne illness surveillance system at the federal, state, and local levels. The lack of data makes it extremely difficult to track and trace foodborne pathogens, respond to outbreaks, and target prevention efforts. HHS is making a substantial investment in facilitating the adoption of health information technology by healthcare providers and facilities, yet there has not been a similar commitment to developing the technical capacity of public health departments. TFAH urges the Department to include among its strategies for addressing Goal 5; Objective E, the need to building public health departments information technology capacity and appropriate linkages between public health and clinical service providers to help expand and improve the nation s disease surveillance efforts. 6

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