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Editor’s Note: Source to the following Call to Action is inside Stand for Health Freedom’s Act Now America: Ask Key Congressmen To Formally Investigate the CDC’s s Conduct During COVID-19 - Your voice matters; stand with us to demand transparency.
This summarizes data and analysis contained within: Ealy, H, et al. COVID-19: Restoring Public Trust During A Global Health Crisis - An Evidence-Based Position Paper to Ensure Ethical Conduct, 23 Mar 2021 (pp. 444), referred to below as C19RPT.
March 2020: CDC Changed the Rules for Death Certificates
Why did the CDC in private, without open discussion among qualified professionals that are free from conflicts of interest, change the rules in March 2020 about counting deaths as Covid despite the existence of effective rules for data collection and reporting, successfully used by all hospitals, medical examiners, coroners, and physicians for more than 17 years?

Call to Action

There is nothing more important to effective public health policy than having accurate and verifiable data.

It appears, however, that the CDC irreparably compromised COVID-19 data quality during a time of public crisis by 1) abruptly implementing new procedures for capturing COVID-19 mortality data via a March 24, 2020 document from the CDC’s National Vital Statistics System, thereby significantly altering death certificate reporting and 2) adopting the Council of State and Territorial Epidemiologists’ April 15, 2020 position paper for defining what constitutes a COVID case – without implementing safeguards to ensure that single individuals would not be counted multiple times, thus altering case counts and subsequent data.
See C19RPT, 95 ff:
Summary – Early into this crisis, the CDC outsourced the definitions for diagnostic criteria to a little-known non-profit organization outside of federal government regulation known as the Council of State and Territorial Epidemiologists (CSTE). On April 14, 2020, the CDC adopted this position paper for which the CDC provided subject matter experts but technically did not author. Therefore, a question arises. Why would a federal agency like the CDC, with many respected PhDs, need to outsource the development of diagnostic criteria to a non-profit organization outside of federal jurisdiction?
That does not immediately make sense unless in doing so, the CDC was attempting to bypass federal laws (APA and PRA) to avoiding oversight and public comment. Even if other reasons arise, the CDC compromised the quality of the data collected, analyzed, and published in alleged violation of the IQA.
Below are the major flaws with the CSTE position paper that could have been unearthed if federal oversight and opportunity for public comment had been legally honored ...

More than 15,000 hours of investigative research shows that these practices have significantly affected COVID-19 data aggregation and interpretation. Moreover, the CDC’s actions appear to be in violation of three federal laws: the Administrative Procedures Act (APA), the Paperwork Reduction Act (PRA), and the Information Quality Act (IQA) – laws that were specifically put into place to protect the welfare of the millions of Americans whose affairs are regulated by federal government agencies.

Death Certificates – Now and Then

From 2003 to March of 2020, pre-existing/comorbid conditions were reported in Part I, not Part II, of death certificates. This can impact statistical aggregation, according to certified death-reporting clerks that were interviewed. The sudden change in death recording protocols is significant in that it not only altered data, but it was made without official notification in the Federal Register to initiate federal oversight and allow for mandatory public comment.

Prior to 2020, pre-existing/comorbid conditions were reported in Part I.

With the CDC’s change, pre-existing/comorbid conditions are no longer reported in Part I.

The above illustrates how death certificates were recorded prior to March 2020 and how they’re recorded now. The CDC’s data collection and reporting changes come after 17 years of use without incident and significantly alter COVID-19 mortality metrics.

When it comes to fatalities, labs conducting PCR tests are required to keep records of the dates of the test and the cycle threshold value that determined the positive lab result. If we had access to certain criteria – the date of the death certificate, the date of the positive PCR test, the cycle threshold used on the PCR test, and a basic knowledge of pre-existing/comorbid conditions from medical records – we could correct the COVID death count and have a much clearer understanding of COVID-19 mortality. This includes 1) how many people died due to COVID 2) how many died with COVID and 3) how many died but were miscategorized as COVID fatalities.

The correction of death count numbers is anticipated to be significant:

Note: the data in the above graph is current through 2/1/21.

As reported in the October 12, 2020 public health policy paper, “COVID-19 Data Collection, Comorbidity & Federal Law: A Historical Retrospective”:

Supportive data comparisons suggest the existing COVID-19 fatality data, which has been so influential upon public policy, may be substantially compromised regarding accuracy and integrity, and illegal under existing federal laws.

The key to initiating legal regulatory oversight of all proposed changes to data collection, publication, and an analysis is the Federal Register.

This decision was made despite pre-existing rules, approved by the OMB, issued by the CDC, and in use nationwide for at least 17 years without incident. These rules are published as, 2003 CDC’s Medical Examiners’ & Coroners’ Handbook on Death Registration and Fetal Death Reporting and the CDC’s Physicians’ Handbook on Medical Certification of Death.

Considering these handbooks have been approved by the OMB and in use without incident for 17 years, there was no justifiable reason for the CDC to implement these changes, bypass the oversight of the OMB, and fail to provide 60-days for public comment, as they are legally obligated to do.

By failing to act in accordance with Congress’ clear intent as to how an agency may propose changes to data collection as codified in 44 USC 3506 (c)(2)(A), there is no record of information the CDC relied upon to make its decision to change how deaths are reported.

Previous reports detailed the substantial changes on how causes of death were forcibly modified by the CDC through the National Vital Statistics System (NVSS), and how together, both federal agencies inflated the actual number of COVID-19 fatalities by approximately 90.2% through July 12th, 2020.

Download the Research

Compromised Data Is Far More Than Numbers; It Affects Each and Every American

The CDC’s apparent failure to follow established laws comes with great costs to society. Had the CDC not changed course and compromised COVID-19 data, our state of emergency conditions and responses would have likely been vastly different – with considerably fewer negative consequences to the American public.

Over the past year, countless loved ones have been forced to die all alone, inflicting significant trauma on them and their family members. Pregnant women have been forced to birth all alone and subjected to other CDC policies that are not evidence-based. Businesses that individuals spent their lifetime’s building have been forced to close. Children have been unable to attend school. Adults and children have been separated from their peers and their systems of support. Some individuals have been unable to get needed medical assistance; others are stuck at home with their abusers.

In short, the COVID-19 crisis has caused unprecedented upheaval across the globe, fueling an increase in poverty, food insecurity, financial insecurity, depression, mental illness, suicides, child abuse, domestic violence, substance and alcohol abuse, and more.

It’s Time To Take Back Public Health and Reclaim Our Lives

With your help, Stand for Health Freedom wants to make sure that such grim occurrences in history never happen again. Recently, we sent letters requesting a formal hearing and investigation into the CDC’s conduct during COVID-19 to the leadership of key congressional committee members in the Senate and House. Now we need you to do the same.

Taking action is easy. With the click of a button, you can let our federal officials know that the CDC’s actions are unacceptable; there’s no room for compromising accuracy and transparency in data, especially in a time of crisis when the population is vulnerable to government overreach and abuse of power. Your participation in this request is significant. Please take action now.

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