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Health and Human Services

### Executive Summary

#### Key Objectives

- Analyze metrics to determine the effectiveness of OSDH’s contact tracing program in limiting the spread of COVID-19.
- Examine ongoing costs of the contact tracing program.
- Examine policies, procedures, mandates, and statutes used, or which can be used, to better enhance project objectives and goals.
- Further examine OSDH’s CARES Fund expenditures to ensure compliance and transparency.

A few months into the COVID-19 pandemic, when the longevity of the situation became clear, state governments were encouraged to utilize contact tracing and case investigation as tools for developing policies to protect public health.

Contract tracing, and by extension, case investigation, has had success in managing the spread of disease since the time of Cholera, but in modern times, the practice has never been used at the scale of COVID-19.

Many states, including Oklahoma, struggled with implementing an effective contact tracing response that included three critical components for success: leadership, organization, and public trust. In conducting a comparative analysis, the Legislative Office of Fiscal Transparency (LOFT) found those states that did were able to implement a more strategic response regarding policies that affected businesses and public institutions.

As policymakers nationwide deliberated over actions that would enable economic and other activities while still protecting public health, data regarding exposure hot-spots and community behavior helped some states in developing targeted strategies or empowering communities to assess risks and adapt accordingly.

With this limited scope evaluation, LOFT sought to examine the effectiveness of the Oklahoma State Department of Health’s (OSDH) contact tracing program and identify best practices for Oklahoma to adopt moving forward.

LOFT found the limitations of Oklahoma’s contract tracing data and a lack of public buy-in were the greatest hindrances to implementing an effective contract tracing program. This was partly due to technological constraints, the evolving understanding of the disease, and changing guidance from the Centers for Disease Control (CDC).

LOFT’s analysis of OSDH’s limited coordination of contact tracing and case investigation efforts into a centralized location from June 8 to December 31, 2020. Excluded from this analysis are efforts undertaken by Oklahoma or Tulsa Counties, as they are independent health departments, and Tribal members who utilized their nation’s health departments. This report also did not examine the contact tracing efforts of the Oklahoma National Guard and others from March to June 2020, when the state was in an emergency response phase.

In addition to the limitations stated above, on December 31, 2020, OSDH changed their centralized approach to contact tracing to a regionalized approach.

#### Finding 1: Oklahoma State Department of Health (OSDH) Lacks Sufficient Contact Tracing Data to Measure the Impact on Limited Spread of COVID-19

LOFT found the State Department of Health’s contact tracing program had no measurable impact on the pandemic. Data regarding transmissions were not timely or accessible to the public or sub-governmental entities. Further, there was minimal effort into establishing public buy-in through awareness campaigns.

The data provided by OSDH was limited in nature and did not lend itself to a full comparison of performance metrics as recommended by the CDC. Often, OSDH was tracking outputs instead of outcomes. The limited data can be attributed to many factors, such as IT limitations, funding issues, or simply failure to collect data.

The lack of data is a missed opportunity for the State, its citizens, and small businesses to make more informed decisions regarding policy and assessing risks within local communities and their economies.

#### Finding 2: OSDH’s COVID-19 Reporting Fails to Align with Stakeholders’ Needs to Make Data-Driven Policy Decisions

The OSDH “Alert Map” was originally communicated as being a tool to inform the public about the risk level of spread for COVID-19 in a specific county. LOFT later learned from OSDH the “Alert Map” was instead used as an internal tool to measure how the State could handle the pandemic as a whole. This disconnect led to separate State agencies creating different “Alert Maps” based on the same data to address the needs of their stakeholders. Other decision-makers, such as municipal leaders, lacked information they deemed critical for their response to curbing the spread of COVID-19 through their communities.

#### Finding 3: Communicable Disease Reporting System was a Known Vulnerability Prior to COVID-19

Oklahoma’s communicable disease reporting system, commonly referred to as PHIDDO, was a known weakness and presented many technological challenges throughout the pandemic. LOFT inquired as to whether a comprehensive plan to replace PHIDDO was ever presented to OSDH Leadership or to the Legislature. OSDH stated they were not aware of any such plan and leadership changes create the potential for institutional loss of this type of information. LOFT further inquired as to why OSDH did not use Coronavirus Relief Funds to upgrade the system of need. LOFT was informed CARES funding had been requested and denied.

Executive Summary

Oklahoma State Department of Health’s Contact Tracing Program Report

Report

Report & Resources

### Summary of Policy and Agency Considerations

#### Policy Considerations

- To enhance public trust, enact protections for citizen privacy during disease testing, contact tracing and investigations for communicable diseases. Prohibit unlawful dissemination of contact tracing data and unlawful use of surveillance technology and require privacy measures be implemented in contact tracing applications.
- As part of the state’s pandemic response plan, make available discretionary public health funds to investigate and control the spread of communicable diseases. As an example, Colorado authorized emergency repurposing of select tobacco education program funds to investigate and control the spread of COVID, to include contact tracing.
- Require the Oklahoma State Department of Health to include school and district-level data of communicable disease exposure and outbreaks in future reports, dashboards, and other publicly accessible platforms to inform the public about the level of risk within Oklahoma schools.

#### Agency Considerations

- The Oklahoma State Department of Health should adhere to the CDC’s recommended process and outcome metrics for effective case investigation and contact tracing. 
- The Oklahoma State Department of Health should collect and incorporate the CDC’s performance metrics for case investigation and contact tracing into daily reporting. 
- The Oklahoma State Department of Health should work with surrounding regional states’ respective health departments to learn best practices for collecting and publishing transparent and accessible data for the public.
- The Oklahoma State Department of Health should adhere to the best practices set by most states and make exposure and outbreak data from communicable diseases in schools publicly accessible.
- The Oklahoma State Department of Health should include representation from the Oklahoma State Department of Education in formulating and recommending future risk levels, data thresholds, and health protocols in future public health emergencies.
- The Oklahoma State Department of Health should provide a plan to the Legislature to replace PHIDDO and transition to the CDC’s NBS, or comparable system, to leverage available technologies and ensure the State has efficient technology for future public health emergencies.

Recommendations

March 2021

Oklahoma State Department of Health’s Contact Tracing Program

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