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AFC Summarizes Proposed Guidelines to Help Groups Submit CDC Comments
The AIDS Foundation of Chicago (AFC) has created this guide to help HIV
prevention stakeholders understand the implications of the proposed guidelines
and assist them in developing their own comments to the Centers for Disease
Control and Prevention (CDC). View
a copy of the announcement
Background: Since 1992, the Centers for Disease Control and Prevention (CDC) has maintained rules pertaining to the review process health departments, community-based organizations (CBOs), and other funded entities must follow in order to use written and audiovisual materials on HIV prevention that they create or obtain with federal funds. The use of educational materials developed by the U.S. Department of Health and Human Services is exempt from this process. The rules apply to the “written materials, pictorials, audiovisuals, questionnaires, survey instruments, and educational sessions” of direct and indirect recipients of CDC funding. The goal of the review process has been to ensure that materials are accurate and appropriate for their target audiences. Currently, local health departments, CBOs, and other funded entities must submit their HIV prevention materials for review to a local Program Review Panel (PRP) comprised of community volunteers and health department staff. Although funded entities can establish their own PRPs, CDC encourages groups to utilize a PRP created and staffed by a health department or another CBO. Each PRP must be comprised of no less than five members who represent a cross-section of the general population of the local area. In reviewing submitted materials, PRPs must ensure that items: 1. Are understandable to the target audience and effective at reaching the intended audience(s). 2. Are unlikely to be considered obscene by the target audience(s). 3. Convey an important prevention message to the target audience(s), which outweighs any perception of obscenity among non-target audiences. 4. Do not promote or encourage intravenous drug use and sexual activity. 5. Provide information on the harmful effects of promiscuous sexual activity, intravenous drug use, and the benefits of abstaining from such activities. 6. Provide factual information on the transmission and prevention of HIV. Below
is a summary of the proposed changes and AFC's recommendations for comments:
2. Condom Effectiveness and Lack-of-Effectiveness: Information contained in educational materials specifically designed to address sexually transmitted diseases (STD) should contain medically accurate information regarding the "effectiveness or lack of effectiveness" of condoms in preventing transmission of the specific disease in question. AFC's comments:
3. Review
Panel Composition: The make-up of the Program Review Panel should
be no less than five individuals who represent a reasonable cross-section
of the "jurisdiction in which the program is based." The current guidelines
require PRPs to be comprised of no less than five individuals who "represent
a reasonable cross-section of the general population." According to CDC,
the clarification will "ensure better representation of the community
to be served."
4. Accurate
Titles: PRPs must ensure that materials submitted for review contain
titles that "reflect the content and activity or program." According to
CDC, "this revision will ensure that materials and their contents are
clearly stated to the audience."
5. Health
Department Certification: Local and state health officials will be
required to independently review materials submitted to their health department's
PRP and certify to CDC that approved educational materials cannot be viewed
as obscene to the "average person." CDC cites a 1973 judicial ruling that
defines obscenity "by looking to the average person, applying contemporary
community standards, as a way to ensure that material would be judged
by its impact on an average person, rather than a particularly susceptible
or sensitive person, or a totally insensitive one."
6. Separate
School-Based Review Panels: Health departments will be required to
establish separate PRP for school-based programs.
7. Health
Department Must Constitute Review Panels: Only health departments
will be allowed to constitute program review panels, eliminating the option
for CBOs to create and utilize review panels for their and other CBOs'
programs. Health departments must create at least one PRP to provide review
for the HIV prevention content of their jurisdiction. Health departments
may, however, create multiple PRPs to review materials developed for different
target populations. No single intended audience may dominate the composition
of the review panels, unless the group has been created specifically to
review materials for a racial and ethnic minority population, in which
case members representing the target population may constitute the majority
of the panel's members.
8. Discourage
Promiscuous Sex, Drug-Use: Reiterating federal law and standing regulations,
all programs that receive CDC funds should include information about the
harmful effects of promiscuous sexual activity and intravenous substance
abuse, and the benefits of abstaining from such activities.
9. No
Suggestive Physical Contact or Sexual Activity: As part of their review,
PRPs should ensure that no educational activities include suggestive physical
contact or sexual activity.
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Printable
document (PDF) |
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