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Initial Comments
A. Themes and Approaches
B. General Recommendations
C. Structure and Process
D. Specific Recommendations by Item
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General Recommendations
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Education
We agree with the priority focus on education; however, the educational programs should be institutionalized and sustained. A recent APUA survey indicates that education of practitioners and medical/nursing students to increase diagnostic certainty and a public education campaign to decrease patient demand should be priorities. High school and elementary school curriculum could include more about bacteria infections and resistance. The lay media should be fully utilized to deliver the message to the general public.
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Surveillance
Antibiotic resistance surveillance is an essential tool to determine appropriate interventions. In order to be useful, resistance data needs to be complemented by antibiotic use data both for animals and humans. To provide baseline information for planning and policy, Federal authorities should require provision of use data from providers and producers and build systems to access these data on a regular basis.
The document makes frequent reference to data on antibiotic use patterns. However, the Action Plan should make explicit that data on overall quantity of antibiotic use is very important to determine the total environmental load.
To increase quality and availability of resistance and use data, government efforts should link with and support existing private surveillance activities.
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Confidentiality
Throughout the document there are references to privacy and confidentiality issues. To address the concern in a coordinated manner, there may be a need to examine all of the specific privacy and confidentiality laws and regulations now applicable to the entire Federal government. This examination may find conflicting privacy and confidentiality statutory requirements among different Federal agencies, which might require Congressional action in order to be rectified.
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Alert System
Recognizing that the intent of this plan is to avoid/decrease the growing problem of antibiotic resistance, we urge that the Final Action Plan include an alert system to combat a national or global crisis emanating from particular resistant organisms, if they appear.
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Advisory Council
Given the magnitude and complexity of antibiotic resistance and the extensive role the academic and non-profit sectors have played thus far in addressing it, we suggest that the Federal government establish an umbrella advisory committee on antibiotic resistance comprised of Federal and non-Federal experts. This committee (and other ad hoc advisory committees convened as needed) could assist the work of the Interagency Taskforce. APUA would welcome an opportunity to lend its expertise through serving on such committees.
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