Activities: 99-01

Iím pleased to convey comments of the Environment Section leadership on the above document.  People involved in our discussion and the preparation of this memo included Susan West, Chair Elect; David Wallinga, Action Board; Jerry Fagliano, former Chair, Science Board member and newly elected Governing Council member; and myself.

General Comments

Much of the document restates, in a clear and helpful manner, the process for policy development at APHA.  It will be a useful resource, especially for people unfamiliar with the process.

Overall, the improved policy process closely resembles the old policy process.   The document contains some useful ideas for educating the membership on the policy process, but doesn't substantially change the process itself.  This is not necessarily a bad thing; the existing process appears to have evolved 
from a variety of competing and contradictory pressures, and the fact that there is little change may reflect the conclusion that there is not room for improvement.  However, it would be helpful to know whether the Public Policy Committee researched the policy processes of other organizations and whether alternative models were considered. 

APHA Staff Outreach to Publicize Policies
The document should address more extensively the issue of how APHA staff will ensure that these policies have an impact.  While the Web is a useful tool, more is of course needed to promote these policies at the national level.  The document could include additional discussion about outreach by APHA staff to those likely to use APHA policies including Hill staffers, other public health groups, environmental and consumer groups, etc.  Outreach could consist of establishing linkages between the home pages of other
organizations and the APHA policy page; also, APHA staff might work more proactively to send select policies to state medical, nursing and other health professional associations.  Do APHA staff currently inform members about the range of ways in which staff use standing policies in their day-to-day work?  If not, how might this be accomplished? 

Policy Review Process
The one notable and worthwhile addition in the document is a policy review (including identification of policy gaps and a sunsetting  provision).  However, the process by which this review and sunsetting is to take place is not clearly stated.  Specifically, there are several issues:
 

Additional Questions:

1 Who is responsible for identifying cross-cutting issues and emerging issues (stated at the top of Page 2)?  Is this the role of APHA staff?

2  A Task Force is referenced.  Is it the intent to create a new committee/task force to work on this effort?  Does the new Task Force dovetail closely with what has already been done by Science Board?  Does the Task Force represent the input and views of Sections?

3 How will this effort be staffed at APHA?  This represents a tremendous amount of work and will need to be well coordinated.  Who will do that?

Specific Comments

 Author Pre-submission Stage

We applaud the development and distribution of a user-friendly policy process document, and training sessions at the Annual Meeting and chair-elect meetings (page 1). 

For new policy development, the Sections are encouraged to identify policy gaps and develop a multi-year plan to fill these gaps (page 1).  This is a useful recommendation, and some Sections (like ours) are doing or have begun to do just that. 

 Initial Review Stage

At the Initial Review Stage, someone is to "utilize expertise" in the association to verify the evidence base of proposed resolutions?  Is this the role of staff?  How would this review be used? Would a proposed resolution be screened out on this basis before consideration by the JPC?  Or is this describing the role of the Science Board?

 JPC Review Stage

In the 5th bullet under step 3 of the JPC Review Stage (page 3), the term "rejected resolutions" is used.  This should be replaced with "resolutions receiving negative and conditional assessments."

 Membership Input Stage

The term "Authority of the Reference Chairperson" is not defined (page 4). 

The plan to make clear the procedures and rules of the Public Hearings is important. How does a Reference Chairperson require and enforce disclosure of potential conflict of interest in the Public Hearings (page 5)?  While important, this provision puts the reference Chairperson in difficult position.  Perhaps all that can be asked under the circumstances is for participants to identify themselves by name and organizational affiliation.

Definition of Key Terms

On page 3 of this section, the JPC is described as having the authority to "make final decisions as to the acceptance or non-acceptance of submissions for the Hearings."  However, this is not true since the Executive Board has the authority to reverse these decisions on appeal, as described on page 1 of 
that section.

There is a need to define "positive," "conditional," and "negative" assessments by the JPC.  What are the expectations of the originators under each of these circumstances?

Flow Chart

It is critical to establish the point at which the proposed submission becomes the "property" of APHA rather than the "author" or "originator" (are these terms synonymous?).

In step 3b, the option for "negative" assessment should be listed.

In step 3d, does the JPC's  letter contain "recommendations" or are these really "requirements" for JPC approval? 

Steps 3c and 3d seem out of sequence.

Step 4a seems out of place.

The review and sunsetting process should be mentioned in the Flow Chart. Proposed Procedure for Review of Old Policies.

It is a mistake to explicitly state an intention to have the "policy's author(s)" serve on the committee to review the policy for several reasons.  To accommodate this provision, hundreds of committees would need to be formed. Who decides which authors get this privilege?  The worthy principle that "authorship" belongs to APHA, not the originator, is violated by this provision.  The policy should be able to stand up to independent scrutiny. 

The plan to present all reviewed policies with "significant revision" (a term which begs for definition) or recommended for sunsetting individually to the Governing Council is unworkable.  Our sense is that the vast majority of policies older than five or ten years old will either require substantial revision or deserve to be sunsetted.  The Governing Council could never hear them all.  As an alternative, all policies older than a certain age (10 years?) should be automatically sunsetted.  With proper notice of the sunsetting date, it would be up to the membership (individuals, Sections, etc.) to re-submit updated policy statements through the annual cycle. 

(POLLY ? DO YOU WANT TO MOVE THIS TO THE EARLIER SECTION OF POLICY REVIEW?)
 

Thank you for the opportunity to comment on this document.  We would appreciate knowing how they are addressed in further revisions.  Feel free to contact me, or Susan West.