DOH's Ron Lewis responds to GLAA on HIV reportingGOVERNMENT OF THE DISTRICT OF COLUMBIA DEPARTMENT OF HEALTH
Office of the Senior Deputy Director for Health Promotion
December 22, 2000
Gay and Lesbian Activists Alliance
P.O. Box 75265
Washington, DC 20013-5265
Dear Mr. Summersgill:
I would like to thank you for your concerns and comments as expressed in your letter to the Office of the General Counsel in the D.C. Department of Health dated December 19, 2000. Your assertions that the proposed rulemaking as printed includes the use of the full social security number as part of the "unique identifier" HIV reporting system is accurate, however, the reason for that is a mistake. The word "partial" was erroneously omitted from the final text. I have already requested that this correction be made by the Department of Health / Office of the General Counsel.
As you are aware, as a member of the HIV Surveillance Implementation Community Advisory Committee and its Algorithm Workgroup, the committee recommended using the last four digits of the social security number in the unique code. It is my understanding that the Algorithm Workgroup adopted the use of the "unique identifier" model developed by the Commonwealth of Massachusetts as the basis for the District of Columbia initiative. After discussions regarding it's use in other states such as Maryland, and extensive consultations with authorities from the State of Massachusetts, the workgroup formally endorsed the use of that model. The committee acknowledged that there are individuals who do not have a social security number. In these instances, the committee recommends using "9999" for the code. In the State of Illinois, the last four digits of the social security number are not part of the unique identifier but it is on the case report form. It is there for assisting in the surveillance process.
I would also like to address your other issues. In the past 18 months there have been discussions in our city concerning the type of my surveillance methodology that should be used and the reasoning for the choice. Some of the discussion did include traditional public health models and non-traditional public health models in addressing this entire issue. In August of 1999, Mayor Williams made a decision to use a numeric code or a "unique identifier" for my reporting and since then we have embarked to expeditiously and effectively implement that mandate. As part of that process, the Unique Identifier Community Advisory Committee addressed concerns regarding individual confidentiality. It was determined at that time that traditional public health interventions such as contact tracing would not necessarily be the most appropriate venue to follow. It was also clarified at the Committee's first meeting that the District of Columbia Department of Health would not perform this type of intervention.
The decision to use a portion of the social security number, the formula of the algorithm and other issues pertinent to the implementation of the Unique Identifier System in the District of Columbia were undertaken with direct and active participation from representatives of our diverse community. I hope we can move forward in strengthening the District of Columbia's HIV prevention systems on the common ground of commitment to defeat this epidemic, not on differences of the past.
We look forward to your participation in this process. If you have any questions or concerns on this or any other issue, please do not hesitate to call me at (202) 442-5879.
Ronald E. Lewis, M.P.P.
Senior Deputy Director for Health Promotion
Mayor Anthony Williams
Members of the City Council of the District of Columbia
Dr. Abdusalem Omer, Chief of Staff
Deputy Mayor Carolyn Graham
Dr. Ivan C. A. Walks, DOH
Office of the Corporation Counsel, DOH
Members of the HIV Surveillance Implementation Advisory Committee