June 22, 2022
The Honorable Xavier Becerra
Secretary, U.S. Department of Health & Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201
Rochelle P. Walensky, MD, MPH
Director, Centers for Disease Control and Prevention
1600 Clifton Road
Atlanta, GA 30329
Robert Belknap, MD
Chair, Advisory Council for the Elimination of Tuberculosis (ACET)
Chief Medical Officer, Boulder County Public Health Department
Denver, CO 80204
Re: Approval requested: ACOEM Liaison to the ACET
Dear Secretary Becerra, Director Walensky, and Dr. Belknap:
The American College of Occupational and Environmental Medicine (ACOEM) requests that the Secretary of the U.S. Department of Health and Human Services (DHHS), the Director of the Centers for Disease Control and Prevention, and Chair, Advisory Council for the Elimination of Tuberculosis, consider including the College as a liaison member of the ACET.
ACOEM’s 4,000 physician members:
- are responsible for the health and safety of 150 million U.S. workers – from grocery stores to coal mines, from oil rigs to hospitals – in both the public and private sectors;
- are corporate medical directors across all sectors of the U.S. economy including health care, manufacturing, military, grocery, internet services, transportation, oil and gas, and coal mines;
- are Board Certified in Occupational Medicine, Internal Medicine, Infectious Disease, Pulmonary and Critical Care Medicine, Emergency Medicine, Pediatrics, Family Medicine, and others;
- are experts in the regulatory (OSHA) and policy landscape of the employer-employee relationship, which by federal law is separated from the traditional provider-patient relationship;
- specialize in workforce economics, employment law and industry-specific regulations and requirements;
- collaborate to publish, define, and implement policies and practices for workplace safety, health and wellbeing including all aspects of tuberculosis prevention, education, exposures, testing, screening, funding, regulating, and treating latent and active Mycobacterium tuberculosis infections.
Inclusion of ACOEM’s expertise in the medical management of much of the U.S. population would provide ACET with insights and perspectives currently incompletely represented on the Committee.
The U.S. workforce kept the country afloat during the COVID-19 pandemic, and ACOEM’s members managed all aspects of this workforce’s health. The pandemic will cause a rise in tuberculosis worldwide over the next decade, and that will bring more TB and latent TB into the U.S. workforce and to the doorstep of our occupational health physicians.
We recognize the tremendous successes of public health in the treatment of active TB and the prevention of MDR TB in the U.S.: ACOEM feels strongly that we have unique access to and knowledge of one of the greatest reservoirs of latent TB in the US: the over 27 million foreign-born members of the workforce
, and the 2.64 million foreign-born health care professionals in particular. We have all seen the devastating consequences of reactivation TB that was identified on hire then went untreated for years before reactivating within a hospital setting. These reactivation cases cost millions of dollars in exposure investigations, but more importantly, they infect our most vulnerable citizens. ACOEM would like to help prevent this ongoing cycle of transmission by working with ACET to encourage more robust treatment opportunities in the workplaces.
Our organization would select a highly qualified physician with expertise and experience in occupational tuberculosis testing and latent tuberculosis treatment programs, support that individual in their attendance and participation at ACET meetings and applicable work groups, and strongly encourage our membership to endorse ACET recommendations. ACOEM supports the mission of DTBE and ACET to diminish the reservoir of latent disease and accelerate elimination of TB in the USA.
We appreciate your consideration and look forward to your response.
Douglas W. Martin, MD, FACOEM, FIAIME, FAAFP
President, American College of Occupational and Environmental Medicine