February 6, 2017
Leroy A. Richardson
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road NE., MS-D74
Atlanta, Georgia 30329
Re: Proposed Data Collection re SEARCH for Diabetes in Youth Study (CDC-2016-0117)
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) regarding its December 8, 2016 proposed data collection on the "SEARCH for Diabetes in Youth Study (the 'Study') (CDC-2016-0117)." Representing over 100,000 registered dietitian nutritionists (RDNs),1 nutrition 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 and to providing medical nutrition therapy (MNT) and other nutrition counseling services to meet the health needs of all citizens, including those with diabetes and prediabetes.
A. Utility and Necessity of the Proposed Data Collection
The Academy recognizes that "[w]hat was once considered an adult-onset condition is being seen with increasing frequency among children and youths. Among adolescents aged 12 to 19 years, 12.7% have been reported to have metabolic syndrome, which predisposes these individuals to risk of type 2 diabetes in young adulthood and beyond."2 The Academy strongly supports the Study's purpose "to find answers about the types of diabetes, its complications, and how having diabetes affects the lives of children and young adults."3 The proposed revisions improve this long-term project and ensure its ongoing relevance and effectiveness in assessing temporal trends in diabetes diagnosed in youth. We support efforts to gather data on the progression of the disease and its complications.
The Academy strongly supports enhancing access to effective evidence based interventions for youths diagnosed with diabetes, including MNT provided by RDNs. We look forward to enhancing future interventions with data collected from this Study and other related studies, such as the SEARCH Nutrition Ancillary Study.
B. Specific Revisions Proposed
The Academy notes and agrees with the proposed revisions to discontinue spot urine collection for the in-person examination and use only collections of first morning urine, which is intended to provide more adequate data for measurement of urinary albumin-to-creatine ratio. We support other efforts to utilize effective, scientifically sound automated collection techniques and other forms of information technology to expedite and simplify data collection.
The Academy appreciates the opportunity to comment on the data collection for revisions to the SEARCH for Diabetes in Youth Study. Please contact either Jeanne Blankenship at 312/899-1730 or by email at firstname.lastname@example.org or Pepin Tuma at 202/775-8277, ext. 6001 or by email at email@example.com with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Pepin Andrew Tuma, Esq.
Government & Regulatory Affairs
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 Fitzgerald N, Morgan KT, Slawson DL. Practice paper of the academy of nutrition and Dietetics abstract: The role of nutrition in health promotion and chronic disease prevention. Journal of the Academy of Nutrition and Dietetics. 2013;113(7):983. doi:10.1016/j.jand.2013.05.007. (internal citations omitted)
3 SEARCH for Diabetes in Youth website. "Welcome to the SEARCH Study." Accessed January 29, 2016.