Public comment

August 31, 2015
Leroy A. Richardson
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road, NE., MS-D74
Atlanta, GA 30329
Re: Public Comment and Recommendations on Proposed Data Collection: “Prevent Hepatitis
Transmission Among Persons Who Inject Drugs;” Department of Health and Human Services, Centers
for Disease Control and Prevention; Docket No. CDC-2015-0047
Submitted electronically via Federal eRulemaking Portal

To Whom It May Concern:
The National Viral Hepatitis Roundtable (NVHR), a broad coalition working to fight, and ultimately end,
the hepatitis B and hepatitis C epidemics, and the National LGBTQ Task Force, an advocacy organization
working to advance full freedom, justice, and equality for LGBTQ people, appreciate the opportunity to
provide comment on the Centers for Disease Control and Prevention’s (CDC) Proposed Data Collection –
“Prevent Hepatitis Transmission Among Persons Who Inject Drugs.” The emerging hepatitis C epidemic
among primarily rural youth under 30 years of age is cause for alarm, and we are pleased CDC has
initiated these studies.
In order to obtain the most robust and relevant data set possible, best informing future programmatic
and policy interventions, we propose the following recommendations for the initial and follow up
surveys:




1

“Section: Demographics/Basic Info” – We recommend the inclusion of a sexual orientation
question. With LGBTQ youth at increased risk for substance use disorder, it is critical to attempt
to capture the proportion of LGBTQ youth at risk for hepatitis C. The question currently in use
on the CDC’s Youth Risk Behavior Survey may be appropriate here.1
“Section: First Injection” and “Section: Injection Practices” – We recommend the addition of
“street hormones” as an option, in order to gauge if and how transgender youth in particular
may be at increased risk for hepatitis C due to not just illicit drug use, but also hormone use for
medical transition.

The Youth Risk Behavior Survey asks: “Which of the following best describes you? A. Heterosexual (straight); B.
Gay or lesbian; C. Bisexual; or D. Not sure.” Survey available at:
http://www.cdc.gov/healthyyouth/data/yrbs/pdf/crosswalk_1991-2015.pdf. See p. 31.





“Section: Sex Partners” – We recommend the inclusion of a question regarding the gender of
sex partner(s) in this section, as a demographic question capturing sexual orientation is
insufficient to understand the circumstances of youth who may be engaged in sex work/trade.
The sexual behavior question currently in use on the Youth Risk Behavior Survey may be
appropriate here.2
Addition of Section on Hepatitis B Testing and Vaccination – CDC viral hepatitis surveillance
data from 2013 indicates the first rise in hepatitis B acute infection since 1990. While attributing
this rise to injecting behavior is premature, anecdotal evidence also shows increases in hepatitis
B transmission among the population this study seeks to engage. Given the lack of resources for
a robust, coordinated viral hepatitis surveillance system generally, we strongly encourage using
this opportunity to collect hepatitis B data as was done with HIV, physical health, and mental
health.

Again, NVHR and the National LGBTQ Task Force thank you for the opportunity to provide comment on
this Proposed Data Collection; the aims are timely and a more thorough understanding of this emerging
epidemic is vital. We look forward to learning more from future results. If you have any questions
about these recommendations, please contact Christine Rodriguez by phone at (202) 408-4848 or by
email at [email protected], or Meghan Maury by phone at (202) 639-6322 or by email at
[email protected]

Sincerely,
National LGBTQ Task Force
National Viral Hepatitis Roundtable

2

The Youth Risk Behavior Survey asks: “During your life, with whom have you had sexual contact? A. I have never
had sexual contact; B. Females; C. Males; D. Females and males.”