More on S. 3898

Revere has a very good summary of the Senate Bill which would “provide for the health of Americans by implementing a system that detects and identifies in a timely manner diseases, conditions, and events that represent a threat to humans, animals, food production and the water supply.” Clearly, no one who wrote the bill talked–or more importantly, listened–to anyone who has ever tried to establish a surveillance system. Here’s what’s troubling with it:

1) As Revere notes, DHS, not public health officials are in charge. Ultimately, people who don’t know very much about infectious disease will be making critical decisions.
2) The data collected will be placed under lock and key and DHS, not CDC, will decide who gets to see the data. The militarization of public health data is not a good thing.
3) Figuring out what the reportable “data elements” are is the crux of any good surveillance system. Any data left out of the system will simply ‘vanish’ and not be collected.
4) Related to #3, there is a provision that allows the list of reportable conditions to be updated yearly. This is an implementational nightmare. You just don’t casually reprogram a national computerized system.
5) How will this related to other national systems like PulseNet and FoodNet? Will it replace them, or supercede them? Will future data collected under these programs belong to DHS and be restricted?
6) Nowhere are the potential sources of costs for the program mentioned, other than research grants to determine what could go wrong.
7) It’s not entirely clear what the whole purpose of collecting these data is. While surveillance systems aren’t hypothesis-driven, they do try to address specific needs (improving clinical care, determining the ecological source of outbreaks, etc.). What need would this system meet that isn’t met already by CDC–were it to be adequately funded?

This is a bad bill that shows a lack of understanding of the complexities of what they are trying to do. Here’s my favorite bit:

”(2) ESTABLISHMENT OF NATIONAL REPORTABLE CONDITIONS SYSTEM.–Not later than 1 year after the date of enactment of this section, the Secretary shall establish an electronic National Reportable Conditions System for the collection, analysis,and transmission of reports between reporting entities and the Department, and any such other persons or entities as determined appropriate by the Secretary. The System shall use the most appropriate technical approach to achieve the purpose of this section.

One year?! Good luck with that. It can take several years just to set up of system to monitor one disease. And “The System shall use the most appropriate technical approach to achieve the purpose of this section”? I suppose that’s better than using the least appropriate approach. Everything is in the details when you build something like this. Given DHS’s track record in computerizing things, I’m not optimistic.
Another crappy piece of Republican–no Democrats are co-sponsoring this bill yet–legislation.

This entry was posted in Uncategorized. Bookmark the permalink.