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Page 1 American Public Health Association Guidelines For the Preparation, Submission, Review, Revision, Consideration, And Adoption Of Proposed Policy Statements Introduction The policy statement development
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Page 1 American Public Health Association Guidelines For the Preparation, Submission, Review, Revision, Consideration, And Adoption Of Proposed Policy Statements Introduction The policy statement development process is the mechanism by which the American Public Health Association (APHA) addresses external public policy matters. It is intended solely to develop policy positions on significant public health issues for the guidance of APHA, other organizations and entities. These adopted policy statements help to inform APHA s position on legislation, regulations, guidelines, legal actions and other policy interventions related to public health. These guidelines, adopted by the Governing Council, are to give direction to the Association's policy statement development process by setting forth principles to govern and outline procedures to guide the coordinated participation of all parties. The Executive Board is charged to monitor operation of the policy statement development process, to assure adherence to the principles set forth here, and to report any procedural modifications adopted to facilitate the development of valid policy statements for APHA. Role of Association Units Constitutional and Procedural Responsibilities: Development of the policy statements of the American Public Health Association involves coordinated effort by several Association units. The bylaws define functions for specific units involved in this process as follows: Section Council: The Section Council is to consider and transmit to the Joint Policy Committee proposed policy statements (Bylaws, Article IX, Section 1(F. iv). Science Board: The Science Board s function is to coordinate the development of the scientific basis for the APHA s professional and policy statement programs (Bylaws, Article VII, Section 5 (A)). It reviews and evaluates the evidence base of proposed policy statements. Action Board: The function of the Action Board is to plan, organize and mobilize others to advance APHA s advocacy priorities. To this end, it shall assist in the development of a comprehensive body of policy statements for APHA; and review annually progress in promoting engagement of APHA members, Affiliates, and Caucuses in advocacy and participation in the policy statement development process (Bylaws, Article VII, Section 1 (A)). It does this by identifying topics in need of new policy statements or gaps in existing policy statements, as well as outdated policy statements that should be considered for archiving. Education Board: The functions of the Education Board are to stimulate and coordinate the education activities of APHA; to maintain and enhance professional knowledge; to increase technological proficiencies in facilitating the delivery of education; and to educate the public concerning public health issues (Bylaws, Article VII, Section 3 (A)). Joint Policy Committee: The Joint Policy Committee (JPC) is to receive, review, hold hearings on, and present policy statements for Governing Council action. JPC shall participate in the policy statement review, updating, and archiving process and shall make recommendations to the Governing Council for changes in the Policy Statement Process (Bylaws Article VIII, Section 5 (A)). The committee assesses all proposed policy statements, reports its initial recommendations for adoption to authors, makes recommendations for revisions to authors before submission to public hearings, reviews proposed late-breaking policy statements and recommends those that meet the criteria for hearings; organizes and coordinates the hearings; reviews the comments and Page 2 suggestions presented at the hearings and incorporates those that improve the proposed policy statements; creates a consent agenda; and reports its final recommendations for adoption to the Governing Council for its vote. The voting membership of the JPC shall consist of 12 members: four each from the Education Board, the Science Board and the Action Board. The chairs of each of these boards shall be included in the JPC membership and shall serve as co-chairs for the JPC (paraphrase of bylaws Article VIII, Section 5 (B)). The JPC shall select chairs for each public hearing to include one member of the JPC and one APHA staff member. The chairs of each hearing are responsible for presiding at the hearings, to take notes, and to prepare a report on the hearing to the JPC. The JPC also oversees the association s annual policy statement review and archiving process. In coordination with the Action Board, the JPC approves the list of policy statements to be reviewed each year and recommends the list of policy statements designated for archiving to be considered by the Governing Council at the annual meeting. Governing Council: The Governing Council is responsible for adopting policy statements that articulate APHA s position on public health issues to impact legislation and regulation (Bylaws, Article V, Section 6 A)). Executive Board: The Executive Board is authorized to adopt interim policy statements, which shall be in effect until the next meeting of the Governing Council (Bylaws, Article VI, Section 7 (H)) and may commission the development of interim policy statements. The Executive Board carries out the policies of the Governing Council between annual meetings, monitors operation of the policy statement development process and implementation of policy statements. Organizational Support: APHA's system relies heavily upon the volunteer efforts of able, interested members for the initiation and development of policy statements. All organizational constituents sections, SPIGs, forums, Student Assembly, affiliates and caucuses are urged to work cooperatively with authors in the development and revision of proposals within the scope of these guidelines. Definition of Policy Statement Each proposed policy statement should represent the statement of a substantially new, externally directed policy statement, or a major modification (revision or extension) of an existing policy statement. If the new proposal updates or supersedes an existing APHA policy statement, the new proposal should explicitly call for the archiving of the older existing policy statement. Policy statements must be consistent with APHA's goals, aims, and objectives; be relevant to current or future public health issues; and avoid conflict of interest or the appearance of conflict of interest between the author s financial or other personal interests and the goals and policies of the Association. Policy statements should describe and endorse a defined course of action, ranging from legislation and regulations desired to needed new policies of non-governmental organizations and private enterprises. Support for legislation or regulations should not include language with specific bill numbers, names, year or presidential administration so as not to date the policy statement. Preparation Announcement: A call to the membership for submission of proposed policy statements will be issued annually by electronic notice and in appropriate publications of the Association. Official contacts for sections, affiliates, SPIGs, caucuses, forums and the Student Assembly will be notified of the process schedule and procedures by special notice. Page 3 Origination: Any APHA individual or group constituent is eligible to submit a proposed policy statement for consideration. Individual members are encouraged to seek endorsement from an organizational unit section, SPIG, forum, or Student Assembly as well as from affiliates and caucuses. Collaboration is highly encouraged. Submission: Each year the Association calendar has a deadline date for the submission of proposed policy statements. Late proposals will not be accepted. Proposals should be submitted electronically to the Joint Policy Committee at APHA's national office at Format: Proposed policy statements should identify a public health problem and present an objective summary of the situation. Proposals should be concise, and accurately and effectively use references to justify the call for defined action. The recommended format for proposed policy statements is relatively simple, and should facilitate clear and succinct expression. APHA uses a modern, international format. Supporting evidence is presented in paragraph form, with action steps listed in clause form. Authors are encouraged to submit proposals that are no more than 10 pages in narrative text length and include 50 or fewer references. Procedures Details of schedule, format, and processing considerations are subject to periodic review and revision by the JPC. Staff will provide specific information and procedural assistance upon request. 1. Preliminary Processing Acknowledgment: Receipt of each proposed policy statement will be acknowledged by APHA staff to the person identified as its submitting originator. Classification: Upon receipt, each proposed policy statement will be classified tentatively by staff as to subject matter and assigned to one of four or more public hearings (see below). The subject areas to be handled at each hearing (e.g., personal health services, environmental health, personnel & training, social factors in health etc.) may vary from year to year, depending upon submissions. Distribution: Immediately after the proposal submission deadline, copies of all submissions which appear to meet the criteria given above, will be posted on APHA s website for review by each organizational unit, all members of the Science Board and each JPC member of the Action Board and the Education Board. 2. Review and Comment Association Constituents: Sections, SPIGS, forums, the Student Assembly, affiliates and caucuses will be notified in advance of the spring meeting of the Joint Policy Committee, that proposed policy statements are available for whatever internal review they deem desirable and feasible, and to return any comments to the Joint Policy Committee and Science Board by the deadline for consideration at the initial review of policy statement proposals during its spring meeting. The Action Board representatives will work with the organizational units, affiliates and caucuses to solicit feedback by the deadline. Individual member reviews and feedback must also adhere to the deadline. Joint Policy Committee (JPC): The Joint Policy Committee is an instrument of the Governing Council, which defines its composition and receives its reports. The JPC will consist of twelve persons; the Action Board Chair and three designees from the Action Board membership, the Science Board Chair and three designees from the Science Board membership, and the Education Board Chair and three designees from the Education Board membership, and will be co-chaired by the Chairpersons of the Action Board, Science Board and the Education Board. The Co-chairs will select members of the JPC to chair each of the public hearings. Page 4 Spring JPC Meeting: The Joint Policy Committee undertakes its first collective review of proposed policy statements at its spring meeting. At this time it: affirms initial staff classification of proposals as to type and hearing group assignment (determined by subject area); discusses the results of preliminary review by its own individual members and any other Action Board, Science Board or Education Board members who may have commented; considers all input from individuals, sections, Affiliates, and other association units; confirms the status of submission deemed to be other than proposed policy statements (e.g. internal operations items, commemorative resolutions, technical standards, etc.); and provides an initial group assessment of each proposed policy statement. Referral of Proposals Beyond the Scope of the Policy Statement Process: This policy statement development process is the mechanism by which APHA addresses external policy matters. Accordingly, submissions that are not about external policy will be deemed by the JPC to be other than proposed policy statements and will be referred as follows. a. Any items relating to internal operations of the Association (including APHA budget, staff and programs) will be referred to the Executive Director. b. Items in the nature of technical standards (e.g. program guidelines, evaluation criteria, etc.) will be referred to the Science Board. c. Non-policy based statements (such as commemoration of a significant event) will be referred to the Governing Council Secretary and Speaker for separate handling. d. Items in the nature of educational standards or professional qualifications will be referred to the Education Board. Initial Assessment Report: After its spring meeting, the JPC will inform the author/originator/contact person of each proposed policy statement of the initial JPC assessment (see below) along with any recommendations for editing. All policy statements with their corresponding JPC assessment will be put forward for Governing Council review (unless the policy statement is voluntarily withdrawn by the author or originator). (1) A positive assessment: the JPC is favorably disposed to recommend for approval essentially as submitted, and forward for a public hearing and Governing Council consideration; (2) A conditional assessment: the JPC will reconsider the proposal for positive assessment before forwarding for a hearing and Governing Council consideration ONLY if it is: (a) Revised addressing the specific suggestions contained in the conditional assessment report and received by the date specified in the letter from the JPC; or, (b) Combined with other, related proposals into a single, succinct, proposal jointly developed by the separate authors according to the specific suggestions contained in the conditional assessment report, and revised and received by the date specified in the letter from the JPC. (3) A negative assessment: the JPC suggests withdrawal of the proposal due to the number and scope of revisions that would be necessary for the proposed policy statement to meet policy statement review criteria as described in the author guidelines. A negative assessment is accompanied by specific reasons for JPC disapproval. Proposals voluntarily withdrawn by the author or originator proceed no further in the current process. Proposals may be re-submitted during the next annual policy statement proposal submission process. If no correspondence is received by the JPC from authors within two weeks of receipt of JPC s correspondence of the negative assessment, the proposal will automatically be removed from the process. If authors of proposals receiving a negative assessment wish to move the proposal forward to the hearings, they must respond to the JPC that they are NOT withdrawing their proposal within two weeks of receipt of this correspondence. The date will be specified in the communication from JPC. Authors of proposals with a negative assessment that notify the JPC that they are opting to move their proposal forward in the process must revise these proposals in response to JPC comments and resubmit them by Page 5 the deadline outlined in the policy statement development calendar. The JPC will review these revised proposals and reconsider their assessments before forwarding to the hearings and for Governing Council consideration. Author Involvement: APHA's system relies heavily upon the volunteer efforts of able, interested members for the initiation and development of policy statements. The JPC and authors work cooperatively to accomplish any recommended revisions of proposals. 3. Optional Steps Special Review & Comment: In addition, the Joint Policy Committee may refer proposals for special review and comment to voluntary consultants of its own choosing (i.e., Association units, public health practitioners, researchers, teachers, or others with relevant expertise and interest). Combination: The JPC may request authors of separate (but related) proposals and others to work cooperatively together in the development of a single, succinct, jointly developed proposal. Appeals: The author(s) of any proposal recommended for disapproval may appeal that JPC decision to the Executive Board. Requests for such appeal must be made in writing to the Executive Director for consideration by the Executive Board by the date specified in the letter notifying the author of the negative assessment. The fundamental purpose of appeals to the Executive Board is to ensure that no procedural irregularities occurred in the policy statement development process for a specific policy statement proposal. The purpose is not to revisit the strength or weakness of scientific findings outlined in the proposed policy statement. Such scientific review is, in fact, the purview of the JPC not the Executive Board. Only in rare instances will the Executive Board over-rule JPC science-based recommendations. Following are the steps to be followed: Appeal Submission -- An appeal to the Executive Board must include the original proposed policy statement and the following information: 1. Specific reasons why the author(s) is (are) appealing the JPC's decision; 2. Indication if the author(s) is (are) claiming that the JPC process was not followed as outlined in the APHA Policy and Procedures. If the author(s) claim(s) procedural irregularities, the author(s) need(s) to outline the specific departures from procedures. 3. Documented peer-reviewed scientific findings or other evidence refuting recommendations made by JPC. These need to have been in existence at the time of submission of the proposed policy statement to the Executive Board and to have been included as appropriate. 4. Discussion of any values-based issues that make a science-based review inappropriate, or alter the nature of evidence to be considered. 5. Justification of urgency for the APHA policy statement in this APHA policy statement cycle, if urgency is an issue. Appeal Distribution -- The Executive Director and the Chair of the Executive Board ensure that a copy of the appeal is sent to the JPC. An appeal will not be considered by the Executive Board if the author failed to follow the APHA guidelines and timelines, including the points identified above. The author of the appealed policy statement will be able to present his or her case directly to the Executive Board via an in-person meeting or conference call. If the Executive Board decides in favor of the appeal, it may request the author to work with the JPC and the Science Board to revise and improve the proposed policy statement within 30 days of the date of notification of the upheld appeal. The Executive Board will communicate the reasons for its decision in Page 6 writing to the JPC within 7 days of its decision. The revised submitted policy statement will then re-enter the policy statement development process which means it will be included in the public hearings and reviewed by the JPC during its Monday mark-up session. 4. First JPC Report Official Distribution: At least a week prior to the scheduled opening of the regular annual meeting of the Governing Council, each councilor will be provided a copy of the first JPC report, consisting of the title and text of policy statement proposals as submitted (or revised), with the JPC assessment. Membership Notice: Proposed policy statements reported out by the JPC for hearings and Governing Council consideration will be summarized in The Nation's Health and made available in full to the membership on the APHA website, or otherwise as appropriate and necessary. Other Provisions Extra-Process Adoption: Apart from the established policy statement development process defined herein, under conditions of an emergency or otherwise compelling nature, the Governing Council can vote to suspend its own rules and take up consideration of a specific proposed policy statement (e.g., one not considered by the process established herein). In such circumstances, both consideration of, and adoption of policy statemen
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