The Data Coalition sent the following letter to Health and Human Services Secretary Alex Azar, along with key officials at the Office of Management and Budget (OMB) regarding the updated guidance issued on July 10th for hospitals reporting COVID-19-related administrative records.

The letter outlines the Data Coalition’s concerns regarding data quality and transparency with the new reporting process. Our letter also asked for clarification on the updated guidance and how it will align with expectations for agencies communicated in 2019 from OMB in the principles of the Federal Data Strategy.

The Data Coalition supports efforts to increase the capabilities of federal agencies to produce high quality, accessible, and useable, but in such a way that also builds transparency and public trust.

The full text of the letter follows.

July 17, 2020 

Secretary Azar, 

On July 10, the Department of Health and Human Services (HHS) issued updated guidance for hospitals reporting COVID-19-related administrative records. The guidance directs hospitals to report information about testing, capacity, and patient flows directly to HHS using a new contractor, circumventing historic practice for such data collection to occur within the Centers for Disease Control (CDC). For many stakeholders, the HHS guidance raises questions about the data quality and transparency with the new reporting process, which could have implications for accessibility and use of the data. In addition, the publication of the guidance appears to not fully align with expectations for agencies communicated in 2019 from the Director of the White House of Office of Management and Budget (OMB) in the principles for the Federal Data Strategy.

HHS’s approach for daily data collection and systems management during an ongoing pandemic must ensure relevant data will continue to be accessible for researchers and organizations supporting the response, while also remaining transparent to the American people with appropriate open data. Consistent with the Federal Data Strategy’s principle of transparency, the Data Coalition calls on HHS to provide additional details to the American public about the intent, role, and purpose of the modified approach for data collection and publication of critical COVID-19 hospital data. In particular, as Practice #30 of the strategy encourages, HHS should promote public trust with transparency in communicating how data will be used. HHS should also articulate how the Department applied the principle of responsiveness for gathering and incorporating stakeholder feedback on this shift in reporting. 

HHS’s limitations in data sharing capabilities are not new, are widely documented, and pose practical limitations for ensuring researchers have access to needed, relevant information to support COVID-19 responses. HHS’s Chief Data Officer, the Director of the National Center for Health Statistics, and other data leaders across the agency must effectively collaborate to support realistic data governance for the agency’s data, as expected in the bipartisan Foundations for Evidence-Based Policymaking Act of 2018, directed under the Federal Data Strategy, and specified in HHS’s Data Strategy.

On behalf of the Data Coalition’s members, we look forward to supporting HHS in continually strengthening the Department’s capabilities for producing high-quality, accessible, and useful data. But in this work, transparency and public trust are essential; we strongly encourage HHS to take deliberate steps to maximize the application of these principles moving forward and to address current concerns for the new guidance. 

Respectfully, 

Nick Hart, Ph.D.

CEO, Data Coalition

 

CC: 

Russell Vought, Acting OMB Director

Paul Ray, OMB/OIRA Administrator

Eric Hargan, HHS Deputy Secretary