Comment from Anonymous

I am submitting comments regarding CDC’s proposed revision of the National Survey of Syringe Services Programs, Docket No. CDC-2026-0859. I actively work in harm reduction, public health and have lived experience as a Person Who Uses Drugs. The CDC needs to publish the complete proposed survey instrument, supporting statements and a clear side-by-side comparison of proposed revisions on the public notice page. -Define what counts as a program Distinguish between an organization, a single program, a fixed site, a mobile unit, a delivery operation and a volunteer collective. Counting an underground network and a massive county health clinic as the same unit produces misleading national data. It doesn't show case the amazing work that is being done in grassroots organizations who generally have much better relationships to the community members they are directly serving and need to uplift the hard work that is being done there. -Honest overdose reversal definitions Separately measure kits distributed, unique recipients, reported administrations and witnessed reversals. -Distinguish direct services from passive referrals Initiating buprenorphine onsite or providing wound care through a nurse is entirely different from handing someone a flyer with a clinic’s phone number. The survey must track the mechanism of delivery. -Measure the full range of modern harm reduction The survey must explicitly measure safer smoking supplies, drug checking, secondary distribution and peer support. A survey built solely around injection access completely erases how programs are responding to a changing drug supply and how stigmatized accessing safer smoking kits is right now. Due to systemic racism over stimulant use, even though we see benefits as safer use strategies to smoking over injecting. -Categorize legal and political barriers precisely “Community opposition” is a useless phrase. CDC needs to separately measure local zoning restrictions, police interference, supply confiscation, funding restrictions and threatened closure orders and the ways in which that is directly impacting the OVERDOSE NUMBERS and working actively in opposition to supporting people's ability to stay safe and ALIVE. -Protect program confidentiality CDC must explicitly detail how nonpublic programs will be protected from re-identification and law enforcement discovery. -Measure lived experience as authority, not decoration Do not just ask if people with lived or living experience are present on the payroll. Ask if they hold power. The survey must track whether people who use drugs serve on governing boards, hold executive positions, design program policies and control budget decisions. CDC must design this survey with people who operate and use syringe services programs, not merely about them! Otherwise WHAT IS THE POINT.