60d FRN - Public Comment

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Comment from (David Harvey)

The is a Comment on the Centers for Disease Control and
Prevention (CDC) Notice: Network Epidemiology of Syphilis
Transmission (NEST) 0920-18MY 2018-04329
For related information, Open Docket Folder

ID: CDC-2018-0018-0002
Tracking Number: 1k2-92xt-sray

Document Information
Comment
May 3, 2018
Re: Network Epidemiology of Syphilis Transmission (NEST)
Study; Docket No (CDC-2018-0018)
Thank you for the opportunity to submit comments regarding
the Center for Disease Preventions Division of STD
Prevention (DSTDP) request for approval of a new threeyear data collection entitled, Network Epidemiology of
Syphilis Transmission (NEST). On behalf of the National
Coalition of STD Directors (NCSD), these comments are
submitted in support of NEST. NCSD is a nonprofit,
nonpartisan membership organization that advances
effective sexually transmitted disease (STD) prevention
programs and services in every community across the
country. Our vision is a nation without sexually transmitted
diseases. Thank you for this opportunity to provide feedback
on this proposal.

Date Posted:
May 3, 2018
Show More Details

Submitter Information
Submitter Name:
David Harvey

The speed at which STDs spread depends in part on the
formation of sexual partnerships and the structure of sexual
networks. The structural characteristics of a sexual network
may not be captured through routine surveillance. The
intention of NEST is to support the establishment of cohorts
of men who have sex with men (MSM) at high risk for
syphilis to help collectively address some of the knowledge
gaps in the transmission dynamics and epidemiology of
syphilis among MSM in the United States. This research will
allow an understanding of the sexual networks and hopefully
can point toward effective public health interventions to slow

https://www.regulations.gov/document?D=CDC-2018-0018-0002

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the spread of the disease.
The United States is currently experiencing a syphilis
epidemic. The national rate of reported syphilis cases
reached historic lows in 2000 and 2001 but has increased
almost every year since then. Syphilis is associated with
significant complications if left untreated and can facilitate
the transmission and acquisition of HIV infection. The most
recent data (from 2016) showed an increase of 18 percent
in syphilis between 2015 and 2016 with 58 percent of the
cases occurring among MSM. But, factors impacting syphilis
transmission within the population, such as social and
sexual network characteristics, sexual behaviors, and health
care access and utilization, are poorly understood. Little
information exists related to the barriers at-risk MSM face
when attempting to access care, whether it is due to
socioeconomic standing and/or a lack of comprehensive
health insurance. Knowing this information is critical to
understanding and addressing the needs of MSM. In order
to attempt to close these knowledge gaps and develop
solutions, data must be collected at both the individual and
network-level among this population.
Used correctly, we hope that NEST will allow for the piloting
of the use of survey instruments to collect this complex
sexual network data and determine the feasibility and
optimal approaches for serial collection of sexual network
data among a population with dynamic networks and the
data collection activities survey format. Sexual networks
refer to groups of people who are considered to be linked by
subsequent or concurrent sexual partners. While an
individual may have only one sexual partner, if that partner
is currently or was previously a part of a more risky sexual
network, the risk of contracting STDs increases within the
sexual network.
The data collection tools that NEST is designed to develop
and pilot are essential to the STD fields understanding of
sexual networks within the MSM community and therefore,
to successful intervention in addressing syphilis among
MSM overall.
Sincerely,
David C. Harvey
Executive Director

Attachments

(1)

Network Epidemiology of Syphilis
Transmission (NEST) Study (CDC2018-0018)

https://www.regulations.gov/document?D=CDC-2018-0018-0002

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View Attachment:

https://www.regulations.gov/document?D=CDC-2018-0018-0002

6/22/2018