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  • ACOEM Comments to HHS Regarding Draft Framework for National Prevention and Health Promotion Strategy

    December 6, 2010

    Dr. Regina Benjamin
    Surgeon General

    National Prevention Council
    United State Department of Health and Human Services

    Hubert H. Humphrey Building

    200 Independence Avenue SW
    Washington, DC 20201 

    Re: National Prevention and Health Promotion Strategy 

    Dear Dr. Benjamin: 

    On behalf of the American College of Occupational and Environmental Medicine (ACOEM), I am writing to comment on the draft Framework for the National Prevention and Health Promotion Strategy. 

    We believe the Framework provides a valuable starting point for discussion by focusing on specific health improvement opportunities. As occupational physicians, we also believe that the workplace offers unique resources and infrastructure for improving health and should be an integral part of the National Strategy. 

    Draft Vision
    ACOEM applauds the statement in the Draft Vision -- moving the nation from a focus on sickness and disease to one based on wellness and prevention. We have an unprecedented opportunity to transform our current sick care system into a true health system by investing in prevention. 

    The burden of illness results in dramatically rising health care costs just at the time when the so-called “silver tsunami” is arriving in the form of millions of aging baby boomers who are exiting the workforce. This population will no longer help fund Medicare and Social Security systems through payroll taxes, and at the same time they will begin to utilize these systems heavily, due to a growing burden of illness and health conditions. 

    Chronic health conditions are on the rise across all age groups, and it is expected that in the near future, conditions such as diabetes, heart disease and cancer will cost employers heavily as they provide medical benefits for employees and absorb the costs of absenteeism and of long- and short-term disability claims. Nearly 50 percent of Americans have at least one chronic health condition and of this group, nearly half have multiple chronic conditions.  

    Everyone with a stake in health care is grappling with these trends. But employers, in particular, face them with great concern.Increasingly, they recognize that the nation’s overall health condition does not bode well for the economic health of their companies. Research shows that, on average, for every one dollar a company spends on worker medical/pharmacy costs, employers absorb two to three dollars of health-related productivity costs. These costs are manifested largely in the form of presenteeism (a condition in which employees are on the job but not fully productive), absence and disability. Research has also shown that in addition to common chronic conditions such as cancer, heart disease and diabetes, a host of other conditions – including neck/back pain, depression, fatigue, anxiety and obesity – are driving total health-related costs in the workplace. 

    Draft Goals
    We recommend that the Draft Goals specifically build on the twin pillars of the community and the workplace. Individuals do not leave the impacts of their personal health risks on the doorstep when they leave for work, just as they cannot leave the impacts of their workplace exposures when they return home. More than 130 million workers spend the majority of their productive adult lives working.  Let’s reach out to them in the workplace to help move the nation from a focus on sickness and disease to one based on wellness and prevention.

    Suggested revisions to the Draft Goals are: 

    1. Create community environments, including in the workplace, that make the healthy choice the easy and affordable choice. 
    2. Implement effective preventive practices in all communities, including in the workplace. 

    Draft Strategic Directions
    ACOEM looks forward to working with the Council as the specifics for each of the 10 Strategic Directions are being developed and refined.

    Thank you for your consideration of these comments. 


    Natalie P. Hartenbaum, MD, MPH, FACOEM