Justification

The National Survey of Substance Abuse Treatment Services (N-SSATS) (OMB No. 09300106, expires 12/31/2018) was approved on December 14, 2015. In March 2015, the White
House’s Office of Digital Strategy and Google expressed interest in helping the public find
substance use and mental health treatment providers by expanding the availability of and access
to SAMHSA's Behavioral Health Treatment Services Locator (https://
findtreatment.samhsa.gov). Google is currently launching a new search feature that could
provide enhanced search results for the user (akin to how searching for a movie or a restaurant
yields a map and results in the vicinity). For this purpose, Google will use SAMHSA's API
(application programmer interface) to pull treatment facility data directly from the Locator
database and render as Google search results.
The National Survey of Substance Abuse Treatment Services (N-SSATS) is one of the surveys
that feed facility data into the Locator. As this project moved forward, SAMHSA had concerns
about whether the N-SSATS informed consent language around data use covered the situation
where facility data would be shared directly with a commercial entity.
SAMHSA had HHS OGC review the informed consent language provided in the N-SSATS
questionnaire. OGC rendered an opinion that the informed consent language that covered data
sharing with “other publically available listings” was not inclusive of Google or other
commercial entities. OGC recommended that SAMHSA give notice to facilities that their
Locator information may be shared with a commercial entity such as Google.
Action Taken: When OGC’s recommendation came to SAMHSA, there was exactly one week
before the 2016 N-SSATS was scheduled to start data collection. CBHSQ had little time to meet
the desires of the White House for sharing data with Google and making a good faith effort to
notify facilities that their data would soon be shared with a commercial entity. After internal
discussion and weighing options on how to notify facilities in the most expeditious manner while
implementing the recommendations of OGC, two actions were undertaken:
(1) A survey question was added to the 2016 N-SSATS questionnaire. This question permits
the facility to express permission for basic facility contact information to be shared with
large commercially available Internet search engines such as Google; and
(2) A notification flyer was added to the survey mailing packet about the change in data
sharing policy.
The question that was added to the N-SSATS is:

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32a. To increase public awareness of behavioral health services, SAMHSA may be sharing facility
contact information with large commercially available Internet search engines, such as Google,
Bing, Yahoo!, etc. Do you want your facility information shared on these Internet search
engines?
•

(Information to be shared would be: facility name, location address, telephone number,
and website address.)
□
□

Yes
No

Because of time constraints in making this decision, and (1) having adequate time so that the
new question 32a could be programmed into the web survey instrument and (2) getting the
notification flyer inserted into the mailing of the 2016 N-SSATS survey packets, SAMHSA
neglected to contact OMB for emergency approval of these two actions.

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