Academy Comments to CDC re National Health Interview Survey

December 29, 2017

CDC Desk Officer
Office of Management and Budget
725 17th Street NW
Washington, DC 20503

Re: National Health Interview Survey (NHIS)---Revision

Dear Desk Officer,

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 November 29, 2017 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 supporting long-term research documenting changes in Americans' access and utilization of health care, their health status, other related demographic characteristics, and how these data may change over time.

The Academy supports the NHIS as necessary for the proper performance of the functions of the CDC and believes it will have significant practical utility due to its prime role in providing key data for critical research on important health care and policy issues.

A. Significance of NHIS in Research

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 Federal Register entry notes, the NHIS is "the single most important source of statistics to track progress toward Departmental health objectives," such as the National Health Promotion and Disease Prevention Objectives and Healthy People 2020, two vitally important government initiatives. The NHIS also continues to serve as a vital resource for the advancement of the science of human nutrition. In the past year or so, NHIS data has served as the primary source for the investigation of the relationship of sociodemographic and behavioral factors to added sugar intake3 and the intersectional influence of gender, age, and socioeconomic status on overweight and obesity4. Other recent research sourced NHIS data to examine regional differences in sugar-sweetened beverage intake among adults5 and characteristics associated with sports and energy drink consumption.6 Each of these research topics are highly relevant in current discussions about obesity, health care and public policy across the country.

The Academy supports the continuation of the supplemental questions from 2017. We applaud the focus on topics in which nutrition plays a fundamental role in prevention and treatment, specifically the inclusion of themes such as: diabetes, disability and functioning, family food security, heart disease and stroke prevention, and children's mental health. These are critical topics and the importance of good nutrition in their prevention and amelioration cannot be overstated.

B. Survey Enhancement

We reiterate7 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.8
      • Question ID "FHS.350," Page 73: Include answer code related to swallowing or chewing difficulty.9
  • Child Questionnaire
    • Module 11, Section Name "Child Conditions, Limitation, Health Status:"
      • 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.10
  • 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.

C. Conclusion

The Academy appreciates the opportunity to comment on the proposed information collection for the "National Health Interview Survey (NHIS)—Revision" docket. Please contact either Jeanne Blankenship at 312-899-1730 or by email at jblankenship@eatright.org or Mark Rifkin at 202-775-8277 ext. 6011 or by email at mrifkin@eatright.org with any questions or requests for additional information.

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

Mark E. Rifkin, MS, RD, LDN
Manager
Consumer Protection and Regulation
Academy of Nutrition and Dietetics


1 The Academy 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 Center for Health Statistics website. National Health Interview Survey. Last updated September 21, 2017. Accessed October 17, 2017.

3 Park S, Thompson FE, McGuire LC, Pan L, Galuska DA, Blanck HM. Sociodemographic and Behavioral Factors Associated with Added Sugars Intake among US Adults. Journal of the Academy of Nutrition and Dietetics. 2016 Oct; 116:1589-1598.

4 Hernandez DC, Reesor L, Murillo R. Gender Disparities in the Food Insecurity-Overweight and Food Insecurity-Obesity Paradox among Low-Income Older Adults. Journal of the Academy of Nutrition and Dietetics. 2017 Jul; 117:1087-1096.

5 Park S, McGuire LC, Galuska DA. Regional Differences in Sugar-Sweetened Beverage Intake among US Adults. Journal of the Academy of Nutrition and Dietetics. 2015 Dec;115(12):1996-2002.

6 Park S, Onufrak S, Blanck HM, Sherry B. Characteristics associated with consumption of sports and energy drinks among US adults: National Health Interview Survey, 2010. Journal of the Academy of Nutrition and Dietetics. 2013 Jan;113(1):112-9.

7 Blankenship J, Tuma P. Academy Comments to CDC re National Health Interview Survey Revision. eatirghtPRO.org, website of the Academy of Nutrition and Dietetics. Last updated Accessed October 17, 2017.

8 Heiss CJ, Goldberg L, Dzarnoski M. Registered Dietitians and Speech-Language Pathologists: An Important Partnership in Dysphagia Management. Journal of the American Dietetic Association.110:1290.

9 Ibid

10 Nordin SM, Boyle M, Kemmer TM. Position of the Academy of Nutrition and Dietetics: Nutrition Security in Developing Nations: Sustainable Food, Water, and Health. Journal of the Academy of Nutrition and Dietetics. 2013;113:581-595.