October 30, 2015
Mr. Charles J. Rothwell, MS, MBA, Director
Office of the Director
Division of Health Interview Statistics
Centers for Disease Control and Prevention
Dear Mr. Rothwell:
Today, I write on behalf of the National Council on Disability (NCD). NCD is an independent federal agency authorized to advise Congress, the Administration, and other federal agencies on laws, policies, practices, and procedures that affect people with disabilities. Thank you for the opportunity to comment on the National Health Interview Survey’s (NHIS) 2018 Questionnaire Redesign of content and structure.
NCD has published several healthcare policy research reports with recommendations that when implemented we believe would lead to better physical and mental health supports and outcomes for people with disabilities. During its decades of healthcare policy work, NCD also has facilitated and called attention consistently to the need for inclusive procedures and practices that recognize, welcome, consider and seek direct input and participation from the wide variety of diverse stakeholders across America.
The Centers for Disease Control and Prevention, Office of the Director of the Division of Health Interview and Statistics announcement identifies special interest in several areas. NCD’s comments on four of those priority areas are as follows:
- The uses (or types of products) for NHIS data: NCD and its stakeholders, including the Congress, the Administration, other federal agencies, other policy and funding decision makers need evidence-based national level data for informed decisions about programs, policies, procedures affecting people with disabilities.
- The consequences of not having the NHIS as a source of data on topics of interest: A federally funded valuable national level data source of information about the country’s population would fail to fully include more than 56 million Americans in the database. Comparisons and research that looks at closing the gaps between people with and without disabilities would be precluded.
- The minimum periodicity recommended for topics of interest: NCD and several other federal partners are required by federal legislation to provide an annual progress report to the Administration and Congress. Data from the NHIS needs to be updated and reported on an annual basis.
- The minimum essential content that NHIS is expected to collect annually to provide covariates for analyses regarding the topics of interest: At a minimum, the annual data needs to include content robust enough to capture the full continuum of disability levels
The focus on disability as a demographic and a diversity factor is essential in the NHIS. NCD’s recent letters about public policy intended for the general population are such examples (Letter to Congress the House Energy and Commerce Committee on Mental Health Reform http://www.ncd.gov/publications/2015/ncd-letter-house-energy-and-commerce-committee-mental-health-reform; and NCD Letter to EEOC Urging Employer Wellness Program Guidance http://www.ncd.gov/publications/2015/ncd-letter-house-energy-and-commerce-committee-mental-health-reform#skip_link-block-system-main ).
NCD stands ready as a resource during your agency deliberations to improve national public policy or practice. Some changes can have unintended consequences that exclude the disability community when there is failure to gather data across the diverse broad spectrum of Americans. We want to work with you on ways to ensure that people with disabilities are neither harmed by survey item removal nor denied additional critical items. Full inclusion is needed on par with individuals in other demographic groupings.
Please direct any follow-up communications to Joan Durocher, Director of Policy and General Counsel at email@example.com. We look forward to this and future opportunities for policy collaboration.