Comment from Rural AIDS Action Network

I am submitting comments regarding CDC’s proposed revision of the National Survey of Syringe Services Programs, Docket No. CDC-2026-0859. I am the Executive Director of a non-profit that provides harm reduction services, including syringe exchange programs. We operate programs that are statewide but with over 87,000 square miles we aren't able to serve all of the people who need these crucial services. In addition, we experienced two HIV outbreaks that were attributed, in part, to IDU transmission. That being said, our overall rate of HIV transmission in all IDU categories is down significantly compared to other transmission routes. This is due, in large part, to the availabilty of SSP services. In addition, federal data suggests that opioid overdose deaths are down. Organizations like ours were a huge part of that success. I can also share that the work isn't done. We haven't seen the same decreases in overdoses, we still have large numbers. With programs like ours, we are able to keep more people alive - dead people don't recover. Many of our clients have successfully completed treatment and are living happy and productive lives. The often come back to visit and share updates because we created a safe space for them to exist. Many of our staff have lived experience which helps us develop programming that is for the people by the people who have walked a similar path. We are concerned that survey fails to provide needed information that truly gives a picture of the current landscape of drug use and how we as organizations at the front lines are responding. How we are contributing to the successes should be highlighted and not minimized but a lack of accurate information. We understand the value of the information being collected because it supports the work being done and gives a clearer picture of the actual need. We ask the CDC to measure the full range of harm reduction services that are provided including safer smoking supplies, drug checking, and secondary exchanging at a minimum. We ask the CDC to protect program confidentiality so that we can continue to operate without threats of being targeted by law enforcement and local officials, and losing funding. We ask that the survey be available to all programs operating - especially those run by peers and volunteers or that are "non-traditional" as they often reach the most unheard. The CDC must design this survey with people who operate these programs and their participants. Thank you for your time and consideration.