CDC Contract Tracing Rule Pushed to September

Earlier this week, Trump Administration officials tasked an interagency working group to come up with a plan for conducting contract tracing on U.S-bound air passengers in order to stem the spread of COVID-19. In doing so, the Administration temporarily halted a rule from the Centers of Disease Control that would have made airlines solely responsible for doing so.

Contract tracing is a critically important strategy to prevent the spread of infectious diseases. Identifying individuals who may have come in contact with another infected person — such as workers or travelers on an airplane — is a vitally important approach in containing COVID-19. The issue is not whether contact tracing is important but, rather, who should be in charge of gathering, validating, storing, and disseminating travelers’ contact information.

As Paul Lewis and I argued in an opinion piece in The Hill recently: there are at least three key reasons why the task of collecting and maintaining critical data on passengers with the explicit goal of stopping the spread of this specific disease should be assigned to the federal government, not to the airlines.

1. Air travelers are hardly the primary source of international arrivals

In 2017, foreign and domestic airlines carried 102.5 million passengers to the United States. But more than 240 million arrived by car, train and bus. Five million more passengers arrived by cruise ship. Transportation itself is a vehicle for spread and a contact tracing database needs to account for the different ways international travelers arrive in the United States.

2. Validation and verification cannot be the job of the airlines

Certain information like the name and a permanent address for international travelers is relatively easy to verify through an identification or passport check. But what about an email address, or the street address and phone number of a hotel? What if a passenger does not have a secondary phone number? For homeland security purposes, federal law already requires airlines to provide passenger name record (PNR) data, but experts at a recent Senate hearing noted that only 75 percent of PNRs have flyers’ telephone numbers and just 56 percent contain emails. The incompleteness undermines its usefulness. Garbage in, garbage out.

3. Time is of the essence

In the Federal Register notice, the CDC notes that although the development of an airline-led passenger information system would be challenging, the agency would work “with airlines on an individual basis” to ensure they are able to meet the requirements of the new rule. However, with more than 200 carriers flying international passengers to the United States, creating a coordinated system among those airlines will take time.

A national response is clearly needed but it is up to the federal government to build a comprehensive, multi-modal, system of information. The interagency task force has until the end of June to come up with an interim solution with a final plan in place by September. Eno will closely monitor its progress.

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