Academy Comments to CDC re National Health Interview Survey Revision

September 26, 2016

Leroy A. Richardson
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road NE., MS-D74
Atlanta, Georgia 30329

Re: National Health Interview Survey (NHIS) Revision (OMB No. 0920-0214)

Dear Mr. Richardson,

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Centers for Disease Control and Prevention (CDC) related to its July 26, 2016 information collection, "National Health Interview Survey (NHIS) Revision." Representing more than 100,000 registered dietitian nutritionists (RDNs),1 nutrition and dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to improving the nation’s health through food and nutrition across the lifecycle.

The Academy supports the NHIS as necessary for the proper performance of the functions of the CDC and will have significant practical utility. We agree with the CDC that the NHIS is "instrumental in providing data to track health status, health care access, and progress toward achieving national health objectives."2 As the information collection notes, the NHIS is "the single most important source of statistics to track progress toward the National Health Promotion and Disease Prevention Objectives [and] 'Healthy People 2020,'" two vitally important government initiatives.

The Academy supports the inclusion of the proposed supplemental questions for 2017 and the continued and enhanced supplemental topics from 2016. Specifically, we applaud the focus on topics in which nutrition plays a fundamental role in preventing and treating. Many of these topics have been included: alternative and integrative medicine, cognitive disability, and receipt of culturally and linguistically appropriate health care services, epilepsy, Crohn's disease and colitis, diabetes, disability and functioning, family food security, heart disease and stroke treatment and prevention, and children's mental health. These are critical topics and the importance of good nutrition in their prevention and amelioration cannot be overstated.

We offer the below suggestions for improvement and clarification as the final survey is developed:

  • Family Questionnaire
    • Module 4, Section Name "Health Status and Limitation of Activities:"
      • Question ID "FHS.270," Page 39: Include answer code related to swallowing or chewing difficulty.3
      • Question ID "FHS.350," Page 73: Include answer code related to swallowing or chewing difficulty.4
  • Child Questionnaire
    • Module 11, Section Name "Child Conditions, Limitation, Health Status:"
      • Question ID "CHS.115_10.000," Page 70: The question text may be made more clear if were to read "During the past 12 months, has [fill: S.C. name] had any difficulty speaking, such as the following conditions…"
      • Question ID "CHS.270_00.000," Page 77: By revising the question to ascertain whether there is difficulty (or not) seeing at certain times of the day, the question could help capture conditions such as severe vitamin A deficiency.5
  • In questions related to family food security, the Academy understands that the tool has been validated by the USDA ERS without the incorporation of religious or cultural reasons, but we encourage an option to clarify that a limitation of meals or restriction of consumption may be for religious or cultural reasons (e.g., Ramadan).
  • Recognizing the efforts to develop the questionnaire in multiple languages, the Academy encourages the CDC to ensure the design of the NHIS accounts for differences in health literacy and clarity among multicultural respondents.
  • Although it is difficult to ascertain the extent to which new technologies will be utilized in the NHIS, the Academy suggests the burden of collection could be minimized through the use of computer kiosks, handheld devices, and the use of pictorial formats.

The Academy sincerely appreciates the opportunity to offer comments regarding the NHIS and is grateful for the important work the CDC is undertaking. Please contact either Jeanne Blankenship by telephone at 312-899-1730 or by email at [email protected] or Pepin Tuma by telephone at 202-775-8277 ext. 6001 or by email at [email protected] with any questions or requests for additional information.

Sincerely,

Jeanne Blankenship, MS, RDN
Vice President
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Pepin Andrew Tuma, Esq.
Senior Director
Government & Regulatory Affairs
Academy of Nutrition and Dietetics


1 The Academy recently approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation's food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.

2 National Health Interview Survey. National Center for Health Statistics website, updated September 13, 2016. Accessed September 22, 2016.

3 See, Heiss CJ, Goldberg L, Dzarnoski M. Registered dietitians and speech-language pathologists: an important partnership in Dysphagia management. J Am Diet Assoc. 2010;110(9):1290, 1292-3.

4 Ibid.

5 See, Nordin SM, Boyle M, Kemmer TM. Position of the academy of nutrition and dietetics: nutrition security in developing nations: sustainable food, water, and health. J Acad Nutr Diet. 2013;113(4):581-95.