Improving Opportunities for Sharing of Notifiable Disease Data in the Context of Office of Management and Budget Regulations and Oversight of Data Submission to CDC

Brief Summary
Key Objective:  The key objective for this Roundtable is to provide an opportunity for CSTE and CDC participants to engage in discussions to 1) clarify the effects that the CDC/Office of Management and Budget approval process has on the collection/sharing notifiable diseases data, 2) understand improvements CDC, in collaboration with CSTE, has made in the process to date and 3) plan new collaborative approaches to improve the CDC/OMB process in the future.  Summary The Paperwork Reduction Act requires that federal agencies obtain OMB approval for collection of information. Therefore, CDC must obtain OMB approval before public health departments can submit information about persons reported with notifiable conditions to CDC. In addition, OMB approval is required before changes can be made in the data submitted or disseminated by CDC, and a renewal of OMB approval is required every three years. The CDC/OMB/ application and approval process is complex, involves publication of two Federal Register notices and typically takes 6 to 9 months from application submission to approval. Therefore, changes to notifiable disease criteria adopted by CSTE in June of a given year might not be implemented by CDC by January 1^st the following year, if approval is not obtained by then. Public health departments have raised concerns to CDC about the approval process because of potential limitations on timely data sharing. For example, health departments may need to share data regionally or nationally on non-OMB-approved emerging infectious diseases to determine if an outbreak is occurring, limiting the ability of public health to identify outbreaks. Also, concern has been expressed about how the OMB process affects the ability of health departments to submit data for “Nationwide Surveillance” (versus nationally notifiable disease surveillance) and about potential limitations on the ability to meet obligations related to International Health Regulations on reporting potential outbreaks. The CDC Surveillance and Informatics office has taken steps to address some of these concerns, for example, by negotiating with OMB for their approval of a more rapid process for “non-substantive” changes to submissions for notifiable diseases. In addition, for a new application to OMB for re-approval of the Nationally Notifiable Disease Surveillance System, the office is working with other CDC programs and with the CSTE Surveillance and Policy Subcommittee to develop an application that helps address health department concerns. This proposed Roundtable provides CSTE and CDC participants with the opportunity to plan approaches to improve the CDC/OMB process.