It's absolutely maddening. CFSAC says go talk to Congress, and Congress says we can't tell NIH what to do. The idea of charging the CFSAC to come up with a strategic plan, though, might be the work around. If the CFSAC has to come up with a plan including budgetary recommendations, it will be harder for NIH to ignore and easier to sell to Congress. Hopefully.
Inspired by Jennie's post a few days ago, here is an excerpt from my written testimony to CFSAC that I submitted on the 26th. Hopefully indeed!
(ETA - I now see that the point made it into the CAA's submission. Yeah!)
2. The CFSAC charter should require a more specific scope of activities in order to improve the implementation rate of the Committee’s recommendations. The CFSAC charter states that the Purpose of CFSAC is to “provide science-based advice and recommendations to the Secretary of Health and Human Services and to the Assistant Secretary for Health on a broad range of issues and topics pertaining to [ME/CFS].”
While the purpose of any federal advisory committee may be to provide “advice and recommendations” to relevant government agencies, the best science-based advice and carefully considered recommendations in the world amount to nothing unless the Committee’s recommendations are ultimately acted upon and implemented by the appropriate government agencies.
To this end, the CFSAC charter should incorporate a more specific scope of activities (either under the Function section or in a new Scope of Activities section) and require the Committee to present its recommendations to the government in a more formal and comprehensive format (specifically, in a single strategic plan to be periodically updated, as discussed below) and require the Committee to more closely monitor of the federal response to ME/CFS.
As an example, the charter of another federal advisory committee governed by the Federal Advisory Committee Act (the same statute that governs the CFSAC), the Interagency Autism Coordinating Committee (“IACC”), sets out the type of more specific scope of activities and mechanisms that would provide more “teeth” to the Committee’s recommendations and which is likely to result in a higher implementation rate by the government of the Committee’s recommendations.
Specifically, the IACC charter states that that Committee “shall” engage in a very specific list of activities, including the development and annual updating of a single strategic plan for autism research including proposed budgetary requirements, and the submitting of the strategic plan to Congress; the development and annual updating of a summary of advances in autism research related to among other issues, the causes, treatment and access to services for autism patients; and the monitoring federal activities with respect to autism and making recommendations to DHHS regarding any appropriate changes to such federal activities. (See IACC charter.)
The CFSAC charter should adopt a similarly concrete scope of activities with respect to ME/CFS, such as requiring the development of a single, periodically updated strategic plan that encompasses the Committee’s advice and recommendations regarding ME/CFS research including proposed budgetary recommendations that would be submitted to Congress, the development and updating of a summary of advances in all aspects of ME/CFS research, and the requiring of more formal monitoring of federal activities with respect to ME/CFS and a mechanism for feedback concerning such federal activities (or lack thereof).