º£½ÇÉçÇøapp

December 21, 2022  

Department of Health and Human Services  
Office of the Assistant Secretary for Health        
200 Independence Ave SW 
Washington, D.C. 20201            

Response to Request for Information (RFI): “National Strategy for the Prevention and Control of Vector-Borne Diseases.” 87 Federal Register 70836; Document: 2022-25241   

The º£½ÇÉçÇøapp (ASM) is one of the oldest and largest single life science societies with more than 30,000 members in the United States and around the world whose mission is to promote and advance the microbial sciences. º£½ÇÉçÇøappmembers are basic, clinical and translational researchers as well as clinical microbiologists, including many who conduct vector-borne disease research, testing, prevention and surveillance.

We support the Department of Health and Human Services’ efforts to develop a National Strategy for the Prevention and Control of Vector-Borne Diseases, especially given the fact that more Americans than ever before are affected by mosquitoes, ticks and other vectors moving into new areas of the country, increasing the number of cases and geographic ranges of vector-borne diseases.

Given the human and economic toll of these diseases, the fact that they are largely preventable and the growing concern that climate change will increase their risk and prevalence, º£½ÇÉçÇøappurges the Department to move swiftly to finalize and begin implementation of this strategy. 

º£½ÇÉçÇøappapplauds the breadth of the strategic goals, priorities and objectives, and we have selected a few to provide specific feedback on below. 

Goal 1: Better understand when, where and how people are exposed to and become sick or die from vector-borne diseases (VBDs).  

Strategic Priority 1: Better understand vectors, the pathogens they transmit and the potential effects of a changing climate. 

º£½ÇÉçÇøappsupports continued investment in basic and clinical research, which allows us to better understand vectors and the pathogens they carry, and we agree that the effects of climate change must be taken into consideration. Climate change will increase the cost and burdens of infectious diseases on global populations. We know that insect vectors respond to changing temperatures by migrating or by surviving longer in more temperate climates, lengthening exposure periods and increasing risk to other animals and humans.

Approximately 40 percent of the world’s population currently live in areas with Aedes aegypti mosquitoes, a primary transmitter of yellow fever, dengue fever and Chikungunya and Zika viruses to humans. Nearly 1 billion people could face their first exposure to viral transmission of these and other diseases by heat-tolerant Aedes aegypti mosquitoes in the next century. We must be prepared to address this risk through resources and coordinated action plans. Action plans cannot be put into place without a greater basic understanding of the pathology and changing landscape.  

Strategic Priority 2: Modernize and maintain surveillance systems for vectors, reservoirs and VBDs. 

VBD surveillance is a critical component to addressing the threat of these diseases. There is much that can be done to increase our knowledge of how and where these VBDs are emerging and circulating. Without a fundamental understanding of these facts, prevention and control methods will not be effective. Surveillance is especially important when there is a novel or emerging VBD, such as the Zika virus.

º£½ÇÉçÇøapphas called on Congress and the Administration to increase capacity and funding to detect, characterize and address VBDs through the use of next generation sequencing in public health and clinical laboratories. The CDC Advanced Molecular Detection program has provided important technology and technical assistance to state and local health departments, as well as other clinical partners, to assess both mosquito-borne and tick-borne diseases, including new threats in the past decade from VBDs never before seen in the U.S., such as chikungunya virus, Zika, Heartland virus and Bourbon virus. 

Through federal support for these surveillance systems using genomic sequencing, we can increase capacity to detect and characterize diseases in animals and humans spread by animal-human contact, including insects and other common vectors. We appreciate that the strategic framework identifies multiple agencies with accountability for this, since it will be important to promote greater cross-agency sharing and coordination of pathogen genetic and epidemiological data. 

Modernizing this work also means considering innovative new methods like xenosurveillance, which uses mosquitoes to detect a wide array of human pathogens at clinically relevant levels and provides insight into disease modeling.  

Goal 2: Develop, evaluate and improve tools and guidance for the diagnosis and detection of vector-borne diseases.  

Given that there are many º£½ÇÉçÇøappmembers who specialize in clinical microbiology and work in clinical laboratories in public health, academic and other nonprofit settings, º£½ÇÉçÇøappis especially pleased to see a goal that focuses on diagnostics for VBDs. We concur with and support the strategic priorities and objectives associated with it. While some progress has been made in improving diagnostics for VBDs, there are still opportunities to take and challenges to overcome to achieve an optimal system for accurate and timely diagnosis of VBDs.  

To achieve the objectives under diagnostic improvement, there must be increased funding for dedicated collaboration opportunities between clinical and public health laboratories for new test development.  These collaborations would foster knowledge exchange and promote training opportunities. Public health and clinical microbiology laboratory collaboration is especially important when there is an emerging VBD. 

º£½ÇÉçÇøappalso agrees with the objective to promote sharing of biospecimens. Establishing an effective system for sample sharing, perhaps through a vector-borne disease biobank, would also be useful. There also is a continued need to expand clinical outreach and education regarding VBDs and diagnostics. Many clinicians are unaware of the changing range of VBD hosts, VBDs often present clinically as flu-like symptoms, and most diagnostics are pathogen specific.

There is no “one test fits all” for VBDs and molecular testing can be insensitive to these pathogens. Other tests can be costly to conduct in only a limited number of laboratories (reference laboratories). This requires continued investment in the development of novel diagnostics and payment models that support the need for rapid and accurate testing. 

Conclusion 

Thank you for your consideration of our views. If you have questions, you may contact Mary Lee Watts, º£½ÇÉçÇøappDirector of Federal Affairs, at mwatts@asmusa.org.  

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Allen D. Segal  
º£½ÇÉçÇøappChief Advocacy Officer