Comment from Knox, Andrew

To:Center for Disease Control, National Survey of Syringe Services Programs, Docket No. CDC-2026-0859 From:Andrew Knox, Harm Reduction Program Manager, New Mexico I am writing in my personal capacity as a harm reduction program manager in New Mexico to respond to the CDC’s proposed revision of the National Survey of Syringe Services Programs, Docket No. CDC-2026-0859. New Mexico Department of Health, which is mandated to provide access to sterile works, prevent negative health outcomes associated with illicit substance use, prevent HIV and Hepatitis infections, prevent overdose deaths, and connect people who use substances with related social services including treatment for substance use disorder. Over time, services have changed to address changing substances and field conditions such as extremely rural residents, poverty, homelessness, and nearness to the state’s border with Mexico. Definition of Harm Reduction Services: New Mexico provides the following services •Education on safer substance use practices and overdose prevention. •Sterile syringes and works (including injection, inhalation and other routes of administration) •Overdose reversal medication – specifically 3 or 4mg naloxone but not higher dose or long-acting products. •Adulterant Checking – to monitor the supply and provide safer use information to clients. •Testing – syphilis, HIV and Hepatitis C – and other CLIA-waived testing as warranted by surveillance data. •Referral and navigation to medical services: oSTD, HIV, and HCV treatment oSubstance use disorder treatment oWound care oPrimary care •Referral and navigation to social support services: oFood resources oHousing resources oIdentification oFinancial Assistance oHealth Insurance These services have been determined by community needs, but other services are possible and the survey should be inclusive of a wide variety of services, including more controversial interventions such as safer injection or overdose prevention facilities, street medicine, services for sex workers, and experimental substance use treatments. Harm reduction programs have always been informed both by community input and rigorous academic research alongside common sense and lived experience. All interventions mentioned above have been vetted, field tested, recorded, and evaluated by the academic community. Inclusion of People with Lived Experience and Current Substance Use: Harm Reduction services have historically been led by people within a community, not governmental entities. Care should be taken to include community led services of all types, and the voices of those still being affected by their own substance use should always be a part of planning and leadership. Measurement of lived experience should treat such experience as equivalent to formal education in other fields and record what types of leadership is being provided by people with this experience. Concerns about the existing Survey: 1.Definition of OORMs: The term OORM is used nowhere except federal statements and includes long-acting and high dosage medications which have been rejected as inferior to naloxone. Care should be taken to distinguish between accepted products and those being promoted by the pharmaceutical industry, but which do not advance utility in saving lives. 2.Definition of community opposition: In measuring community opposition, clarity is requested between opinionated and ill-informed opposition generated by fear-based messaging vs. more technical barriers such as zoning restrictions, police interference, and unfavorable laws regarding homelessness. 3.Confidentiality: In measuring programs, participant confidentiality or anonymity must be maintained. This is essential given the threat of legal or social consequences under the existing prohibition legal structure. Recommendations: 1.Build Trust: Federal resources for harm reduction only began to appear in 2021. Little consultation with affected communities preceded this support and the proposed survey was constructed largely without the input of harm reduction service providers and people in the community. The current effort to gather data is a step forward, but more should be done to promote understanding of the benefits of providing this data to a federal administration which is currently threatening harm reduction services rather than supporting them. 2.Minimize data collection: Most client interactions are brief and anonymous, and so we collect the minimum amount of information required to record and analyze activities. The same principle should guide this survey. 3.Eliminate outside influences: Avoid inserting unnecessary products and recommendations from outside the community, such as unneeded high dose opioid reversal agents and expensive testing technologies, into the categories that are proposed to be measured. 4.Show benefit: The current survey promises no policy changes or future funding.