Public Comments

12, 2022
July XX,

Jeffrey M. Zirger
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road NE, MS H21-8
Atlanta, GA 30329

regulations.gov
SUBMITTED VIA ELECTRONIC
MAIL
RE: Comment on the National HIV Behavioral Surveillance: Brief HIV Bio-behavioral
Assessment (NHBS-BHBA); Docket No. CDC-2022-0064
Dear Dr. Zirger,
Thank you for this opportunity. The National LGBTQ Task Force respectfully submits this
comment on the National HIV Behavioral Surveillance: Brief HIV Bio-behavioral Assessment
(NHBS-BHBA) - New; Docket No. CDC-2022-0064.
We appreciate and commend the work that the CDC has done with this program in collecting
data on populations at-risk for HIV and ensuring that those populations are diverse and represent
all of those at risk. We ask that the CDC continue that work with this future component.
I. Task Force History
The National LGBTQ Task Force advances freedom, justice and equality for LGBTQ people.
We are building a future where everyone can be free to be their entire selves in every aspect of
their lives. Today, despite all the progress we have made to end discrimination, millions of
LGBTQ people face barriers in every aspect of their lives: in education, housing, employment,
healthcare, retirement, and basic human rights. The Task Force recognizes and appreciates the
work that the CDC has put into reducing the disparate impact that HIV and other STIs have on
the LGBTQ community by advancing data collection to inform HIV prevention, treatment, and
diagnosis methods.
The National LGBTQ Task Force’s history is deeply rooted in AIDS activism and advocacy. For
over 30 years, we have fought the stigma associated with HIV/AIDS and other STIs. Recently,
the Task Force has partnered with other organizations to advocate for the implementation of
complete, medically accurate sex education programs. These programs work to prevent STIs and
reduce their prevalence, focusing predominantly on young people from marginalized

communities. Education, medical prevention, and treatment that excludes LGBTQ identities
further alienates an already at-risk community. This is why the CDC’s work on studying HIV in
MSM, youth MSM, transgender, and other at-risk populations to improve HIV treatment and
access to prevention and treatment resources is so important. It is also why we recommend that
the CDC is clear about which locations and populations will be studied in this future component
of the NHBS.
II. Support for Current Approach
First, we would like to recognize that the CDC has done an exceptional job with the NHBS so
far. The NHBS is a well-designed study that provides essential information to the public health
community about HIV prevention, treatment, and diagnosis methods and we are glad to see the
project continue.1 The information that the study provides about the behaviors of the populations
that are most at risk for HIV is essential to decreasing new HIV infections, increasing the amount
of people who know their HIV status, and connecting people with treatment and prevention
resources.2 This is the only national study that is gathering this information.3 Findings from
NHBS are used to guide local and national HIV prevention programs and to evaluate existing
programs and services by assessing exposure to and use of prevention services over time, and to
determine gaps in provision of, access to or use of HIV prevention services.4 The prevalence of
HIV-related behaviors can be used to target testing, response, treatment and other prevention
efforts and to evaluate uptake of current HIV testing and other prevention guidelines. 5 The
NHBS gathers data in 25 locations that have high HIV rates, which helps to inform actions that
health departments in those cities can take in order to help decrease those rates and to give a
comprehensive look at national trends.6
Multiple studies state that the data gathered by the CDC is important, reliable, and of high
quality.7 The NHBS question formatting follows many of the suggested sexual orientation and
gender identity (SOGI) data collection survey question formats from the National Academies of
Sciences, Engineering, and Medicine (NASEM), including the two step gender question.8
Formatting questions this way has been shown to increase the accuracy and quality of the data. 9
Multiple studies also state that the information helps improve HIV public health outcomes in
cities that have higher rates of HIV than the national average.10 We commend the CDC on the
collection of reliable, high quality, accurate, and important HIV behavioral data.
In addition to gathering extremely helpful information to help improve the lives of the affected
communities, CDC’s confidentiality procedures on these projects are comprehensive and help to
ensure that patient privacy won’t be violated. 11 This is important to continuing to gather the
necessary data while protecting patients from possible backlash due to the lingering stigma
around HIV in the United States. We applaud the CDC on its past work and look forward to

seeing the study continue into a new phase: the National HIV Behavioral Surveillance: Brief
HIV Bio-behavioral Assessment.
III. Our Request: Release Information About Which Locations Will Provide Data and
the Exact Populations That Will Be Studied
In the past, the CDC has stated that the NHBS will work with men who have sex with men,
people who use injectable drugs, heterosexual people, transgender women, and female sex
workers.1 These are all populations that are at heightened risk of HIV and studying the behavior
of these populations helps to further the CDC’s goal of reducing new HIV infections and
increasing access to treatment and prevention resources.2 However, from the proposal in the
federal register it is unclear which locations will provide data or the exact populations that will
be studied in each location in this new component. If that data is not included, it is hard to
evaluate how useful and effective the collection will be. From the model instruments and
proposal, it is our understanding that the CDC is looking to collect data from traditionally
underserved geographic communities, such as rural areas.3 We recommend that the CDC release
information about which locations the data will be collected from and which populations will be
studied for comment before starting the study so that interested organizations, such as Whitman
Walker, may offer their opinions on the utility of that data collection.
IV. Summary
In summary, the National LGBTQ Task Force has a long history of advocating for quality
HIV/AIDS research and medical care for the queer community. As part of our continuing
advocacy work, we seek to support and improve HIV/AIDS studies, such as the CDC’s work on
studying HIV in MSM, youth MSM, transgender, and other at-risk populations through the
NHBS-BHBS. We appreciate the work that the CDC has done with this study and recommend
that the CDC release information about which locations and which populations will be studied
before starting the study so interested organizations, such as Whitman Walker, may offer their
opinions on the utility of that data collection. Thank you for the opportunity to comment and we
hope that you will consider our request.
Thank you for the consideration of our request. For more information, please contact Clermon
Acklin, Federal Regulatory Counsel, at [email protected] or 202-604-9830.

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Id.
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Centers for Disease Control and Prevention. 60-day FRN Publication Request for Information

Collection. 2021.

Sincerely,

Kierra Johnson
Executive Director