Comment from No, No

No NoOpposeIndividual
Summary: A violence prevention and public health professional opposes the proposal, arguing that it places an undue reporting burden on already overwhelmed programs and lacks specificity regarding data collection and security. The commenter suggests using existing CDC data or developing a more detailed, long-term evaluation plan.
Respectfully, I would like to disagree with this proposed action as someone who has done violence prevention and public health work for a decade. The CDC and federal government already collect data on RPE through the DVP Partners Portal on an annual basis and place a burden on already overwhelmed programs to report their activities. Many states have only have one full time person dedicated to RPE. Requiring further data collection would not be feasible due to capacity alone. Additionally, this proposal is incredibly vague in what data specifically will be asked of recipients and how the data will be used or analyzed. I reject the proposal, especially in this current form. If you want to do a larger-scale analysis or evaluation of RPE, use data you already have. Violence prevention is a marathon, not a sprint. If you are collecting data over three years, you will find nothing useful. That isn't even the full period of the cooperative agreement. No change is going to take place over that time period. It may also be found that an increase in violence has occurred, which often happens when violence prevention work is effective. This is because violence, especially sexual violence, is vastly underreported. This is common knowledge and the CDC is aware of this as well. When violence prevention work is effective, disclosures increase. The idea would be that those disclosures become less common over time to show a true decrease in rates, but three years is not enough to show that decline (if that is what is intended as a measure here in this proposal; as previously stated, it is incredibly vague). As a professional and a subject matter expert, this proposal is misguided at best. Not to mention there may be sensitive information collected (again, there is no listing of what data is collected or how) that could be a data security risk. Data the CDC already has should be sufficient to answer any evaluation questions proposed (which are not included in this document). My recommendation is to either a) squash this proposal, or b) come back with a more specific evaluation plan, proposed questions, what data will be collected, how data will be collected, and what measures are being taken to secure said data as well as a longer timeline for data collection. This proposal is not sufficient in the current state.

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