DRAFT

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APHL’s policy work has three main components: 1) Monitor and Inform; Advocate and Educate; Respond and Plan. Below, we describe in detail the steps involved in each workflow.

1. Monitor and Inform

A. Monitor

Staying abreast of the latest policy and standards from federal agencies and standards development organizations. Few public health laboratories have the time and resources to devote to this monitoring, yet it is critical for labs to understand and prepare for draft rules that have an impact on public health informatics. APHL therefore monitors the policy work of federal agencies, including ASTP, CDC, CMS, and FDA, among others. We reach out to contacts at these agencies to understand what is in the pipeline even before a draft is released, and we follow TEFCA planning with special interest. We participate in workgroups, webinars and other public forums and read publicly available updates and newsletters to stay informed. And when new rules are released, either in draft or as final versions, we work with our subject matter experts to assess the validity of the approach and the downstream effects for public health.

We are also actively engaged with standards development organizations such as HL7, LOINC, SNOMED and NIST that develop new standards, implementation guides and value sets that are used by public health.

B. Inform

As needed, APHL informs the public health community about rules and policies that are in development. We deliver policy updates to existing forums, including ColLABorate communities, APHL eUpdates and newsletters committee calls and annual conferences. In these updates, we focus on what is important for you and what will have an impact on your informatics strategy and operations without overwhelming you with too much information.

2. Advocate and Tell

APHL tries to shape informatics policy. We have two strategies. First, we serve as an advocate for the  public health lab community.  As a national organization representing public health laboratories, we believe that APHL’s recommendations and opinions can carry weight with SDOs and federal agencies.  Second, there is also power in numbers and having multiple voices say the same thing. We have been advised by federal colleagues on multiple occasions that the agency’s leadership is more likely to respond to concerns if they see many comments from different sources that communicate the same message. Thus, our approach to shaping and changing policy applies both of these strategies.

A. Advocate early

APHL works hard to get a seat at the table as standards and rules are being developed. It is easier to shape policy at the frontend rather than being reactionary after a draft has already been released. Thus, we join working groups and meet with agency leaders earlier in the process so they know and understand PHL needs, priorities and capabilities.

B. Comment on draft rules and standards

APHL will review drafts and compose a response based on APHL SME experience. Depending on how big, we’ll broadcast to public health community, leaving time for PH collaboration. We’ll circulate information about the draft rule and our draft feedback through the same communication channels as those described in 1b.

C. Collect feedback from public health community

Got feedback on our feedback? What did we leave out? What did we get wrong? Help make APHL’s comments better and more representative of the public health community’s interests. We’ll right-size this feedback process. For USCDI V6, it’s an informal email to a point of contact. For HTI-2, it was a form and multiple hosted webinars. We’ll let you know what’s up, how big it is, and how to get involved.

D. Submit APHL Feedback

We’ll submit feedback to the agency. The form will vary. Could be a letter, a form, individual posted comments that are tagged to a specific data element.

E. Support STLT comments.

Use our comments as a starting place for something that you as the STLT submit.

F. NGO/Association comments

We also collaborate with partner organizations with CSTE so that they know what we’re going to say, and vice versa, so that we can look out for each other’s interests. And APHL is the lead, along with Bright Lights, Big City, of the JPHIT Policy workgroup. So we may submit similar yet different comments as a signatory on a JPHIT response.

3. Respond

PHL will summarize the final rule and assess impact and timeline

Inform public health community

Facilitate open discussion if there are important impacts – at home testing, e.g.

Draft response recommendations for different parties

• FAQ sheet, one-pager for STLTs

• CDC project owners

• Vendors

• AIMS updates

Existing TA projects: we’ll work with CDC project sponsors on downstream effects on TA data flows

AIMS Infrastructure: we’ll roadmap updates and enhancements to AIMS that the new requirements necessitate

If it’s big, we might write a white paper with the Informatics Committee or a subcommittee

Coordinate with issuing agency on follow-up questions and need for additional guidance

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