January 8, 2018
Leroy A. Richardson
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road NE., MS-D74
Atlanta, Georgia 30329
Re: Assessment of Cancer Prevention Services at Community Mental Health Centers (Docket No. CDC-2017-0076)
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 information collection, "Assessment of Cancer Prevention Services at Community Mental Health Centers," published in the November 8, 2017 issue of the Federal Register. 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 providing effective nutrition care services to all populations, particularly those at greater risk of chronic disease.
The Academy supports this information collection as highly beneficial for the work of the CDC and believes it will have significant practical utility due to its potential to facilitate distribution of effective nutrition education materials to a population likely to be simultaneously underserved and at higher cancer risk.
A. Effects of Social Determinants of Health Among People with Mental Illness
People with mental illness may be particularly vulnerable to the impact of cancer due to limits on their income, access to health insurance, cognitive function, understanding of their personal health, and difficulty navigating the health care system.2 Additionally, physicians without sufficient relevant psychiatric training may be poorly equipped to effectively meet the healthcare needs of this unique population.3 As a result, this population may experience reduced healthcare access and effectiveness,4 which may then increase certain cancer risks and alter the screening, diagnosis, and treatment processes for this population. Not surprisingly, people with mental illness may experience increased cancer-related morbidity and mortality compared to the general population.5,6
B. Effective Provision of Services
RDNs are recognized as the most qualified food and nutrition experts by the National Academies of Sciences, Engineering and Medicine's Health and Medicine Division (formerly the IOM), most physicians, and the United States Preventive Services Task Force (USPSTF) for providing nutrition care more effectively at a lower cost than physicians, nurse practitioners, and physician assistants.7 This expertise includes counseling and assessment related to nutrient-drug interactions. Assuming patients can access suitable mental health care, many people with mental illness may be taking any of a number of medications,8 each of which may be associated with nutrient interactions, alterations in oral/gastrointestinal functions and forced changes in food habits.9 Therefore, these cancer prevention services are best guided by or directly provided by RDNs, who have the training and expertise to not only provide the primary service but also recommend suitable dietary adjustments to avoid or accommodate any interactions.
C. Survey Enhancement
To enhance the effectiveness and utility of the survey tool, the CDC should plan to survey a mix of urban, rural, and suburban CMHCs. The survey should also gather information about existing collaboration between the CMHC and local health care providers and programs, whether the CMHC has mental and physical health care services co-located, and other similar criteria. The survey should also assess CMHC policies and practices (such as having a tobacco free campus) that can help reduce cancer risk.
The Academy appreciates the opportunity to comment on the proposed information collection for the "Assessment of Cancer Prevention Services at Community Mental Health Centers" docket. Please contact either Jeanne Blankenship at 312/899-1730 or by email at email@example.com or Mark Rifkin at 202/775-8277, ext. 6011 or by email at firstname.lastname@example.org with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Mark E. Rifkin, MS, RD, LDN
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 Musuuza JS, Sherman ME, et al. Analyzing excess mortality from cancer among individuals with mental illness. Cancer. 2013 Jul 1;119(13):2469-76.
5 Musuuza JS, Sherman ME, et al. Analyzing excess mortality from cancer among individuals with mental illness. Cancer. 2013 Jul 1;119(13):2469-76.
6 Weinstein LC, Stefancic A, et al. Cancer screening, prevention, and treatment in people with mental illness. CA Cancer J Clin. 2016 Mar-Apr;66(2):134-51.
7 Committee on Nutrition Services for Medicare Beneficiaries. "The Role of Nutrition in Maintaining Health in the Nation's Elderly: Evaluating Coverage of Nutrition Services for the Medicare Population." Washington, DC: Food and Nutrition Board, Institute of Medicine; January 1, 2000 (published).
8 Mojtabai R1, Olfson M. National trends in psychotropic medication polypharmacy in office-based psychiatry. Arch Gen Psychiatry. 2010 Jan;67(1):26-36.
9 Pronsky Z M, Elbe D, et al. Food-Medication Interactions, 17th ed. (Food-Medication Interactions, Birchrunville, PA), 2012.