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Sept 12 -- The National Center for Injury Prevention and Control (NCIPC), Centers for Disease Control and Prevention (CDC), invites comments to OMB by October 14, 2022 regarding the State Unintentional Drug Overdose Reporting System (SUDORS).

There has been a rapid increase in opioid overdose deaths since 2013. In the United States, more people are now dying of drug overdose than automobile crashes, although opioids—both opioid pain relievers (OPRs) and illicit forms such as heroin—are also a major factor in overdose-related automobile crashes. On October 26, 2017, the U.S. Department of Health and Human Services (HHS) declared the opioid overdose epidemic to be a national public health emergency (PHE).

In 2020, 91,799 drug overdose deaths occurred in the United States; the age-adjusted rate in 2020 was 31% higher than the rate in 2019 and provisional data indicate an estimated 105,752 drug overdose deaths occurred between November 2020 and October 2021. Approximately 75% of drug overdose deaths in 2020 involved an opioid, and opioid overdose deaths are 8.5 times the number they were in 1999. While the opioid overdose epidemic worsens in scope and magnitude, it is also becoming more complex.

CDC established the State Unintentional Drug Overdose Reporting System (SUDORS) in order to detect new trends in fatal unintentional drug overdoses, support targeting of drug overdose prevention efforts, and assess the progress of the HHS initiative to reduce opioid misuse and overdoses. Respondents are state- or jurisdiction-level health departments. The SUDORS surveillance system generates detailed, timely public health information on unintentional, fatal opioid-related drug overdoses and has been used to inform prevention and response efforts at the national, state, and local levels. SUDORS consolidates and supplements information available to health departments, including vital statistics and records created by medical examiners and coroners (ME/C). SUDORS is built on a web-based software platform and a collaborative surveillance and data integration model developed by CDC and health departments to improve understanding of homicide, suicide, undetermined deaths, and unintentional firearm deaths (National Violent Death Reporting System (NVDRS), OMB Control No. 0920-0607).

Through SUDORS, CDC currently collects information that is not provided on death certificates, such as whether the drug(s) causing the overdoses were injected or taken orally; a toxicology report on the decedent, if available; and risk factors for fatal drug overdoses including previous drug overdoses, decedent's mental health, and whether the decedent recently exited a treatment program. Without this information, efforts to prevent drug overdose deaths are often based on limited information available on the death certificate and anecdotal evidence.

The SUDORS system provides specific information on drugs contributing to an overdose as well as detailed information on risk factors for unintentional and undetermined intent (e.g., evidence equally supported or could not distinguish between two possible intents such as unintentional or suicide) drug overdose (UUDO) deaths. Risk factors include recent discharge from residential treatment or prison, recent arrest, recent return to using opioid-related drugs, no bystanders were present when the overdose occurred, mental health conditions, a surge in adulterated heroin that is especially potent, or new patterns in polysubstance drug use. These risk factors can be tracked at the regional, state, or local level (e.g., county and zip code). The following characteristics of the opioid overdose epidemic make it critical to track the specific drug(s) contributing to drug overdose deaths: 1) fentanyl now is the leading drug contributing to drug overdose deaths, 2) the proliferation of illicitly-manufactured fentanyl analogs and their involvement in outbreaks,,,,, and 3) increasing co-occurrence of opioids with stimulants (e.g., cocaine and methamphetamines), and co-occurrence of benzodiazepines and gabapentin in the post-mortem toxicology findings of overdose decedents..

Interventions that could be used by communities to address the risk factors tracked by SUDORS include distributing naloxone to first responders and community members, enhancing access and use of evidence-based substance use treatment, identifying and disrupting illegal distribution of OPRs through physician offices (i.e., often referred to “pill mills”), or implementing comprehensive efforts including prescribing guidelines and intensive education of clinicians and community members to promote safer prescribing of opioid pain relievers for chronic non-cancer pain.  
SUDORS: https://www.cdc.gov/drugoverdose/fatal/sudors.html
CDC submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202208-0920-014 Click IC List for survey instrument, View Supporting Statement for technical documentation. Submit comments through this site.
FR notice inviting comment: https://www.federalregister.gov/d/2022-19557 (While FRN was posted Sept 12, submission to OMB made Sept 14. 30 days=Oct 14)
For AEA members wishing to submit comments to OMB, the AEA Committee on Economic Statistics offers "A Primer on How to Respond to Calls for Comment on Federal Data Collections" at https://www.aeaweb.org/content/file?id=5806

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