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» LymeNet Flash » Questions and Discussion » Activism » Urgent! Use this sample letter to contact your U.S. Congressmen re: IDSA Review

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Author Topic: Urgent! Use this sample letter to contact your U.S. Congressmen re: IDSA Review
KarlaL
LymeNet Contributor
Member # 29631

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Everyone, please use the sample letters provided to write your US Representative and Senators today and ask them to contact the IDSA! Time is of the essence!

Include the attached PDF with your letters. In order to access the PDF, you are going to have to go to the yahoo web site by pressing the VISIT YOUR GROUP link at the bottom of the daily email.

Please help to spread the word by sharing this information with any Lyme groups that you belong to.

You can find both the sample letters here: http://www.empirestatelymediseaseassociation.org/

Link to the (recently updated) PDF: http://www.empirestatelymediseaseassociation.org/LYME-DISEASE-INFORMATION-3272015.pdf

KarlaL


From the New York State Coalition of Lyme and Tick-borne Diseases:

Dear fellow Lyme patient and Lyme patient advocates,

The IDSA is preparing to hand down their new guidelines for Lyme disease. As you are probably aware, a major concern is that the IDSA may not consider all the scientific evidence and all the patients' claims while in the process of revising their (previous) guidelines.

In violation of IOM Standards, the panel does not include representatives from key affected groups, including a current or former patient and a patient advocate or patient organization representative.

A second concern is that, as required by National Guidelines Clearing House, organizations are advised to review and appropriately revise their Treatment Guidelines to reflect new science every five years.

The New York State Coalition on Lyme and Tick-borne Diseases has worked very hard to craft a letter which is below that you can send to your United States Senator and Congress member in your state if you agree with our view. Important additional documentation is attached as a pdf file. We feel that it is urgent for everyone be on board in this effort to insure that the IDSA consider all relevant information for their "2015 Guidelines for Lyme and Tick-borne Diseases."

The time element is crucial, since the deadline for comments is April 9th. Please do this immediately if possible.

To find your legislators go to:
https://www.opencongress.org/people/zipcodelookup and enter your zip code.

--------------------------------------------------------------------------------

PATIENTS / ADVOCATES: The following is a sample letter (in dark blue) which you can send to your legislators
Please copy the letter below, into a different email or on paper.
Then use appropriate "I"or "We" and fill in your information to send to your Senator and Congress member and please download and save the pdf attached in this email. (LYME-DISEASE-INFORMATION-3252015.pdf) Remember to attach this pdf document with your email or include a printed copy of this pdf with snail mail letters or faxes to your US rep's.

Sample Letter

Dear Senator /Congress member:

I (or We) seek your intervention to ensure that the new treatment guidelines for Lyme disease, currently in the process of being drafted by the Infectious Diseases Society of America (IDSA), will result in guidelines that reflect a complete, fair, transparent, and trustworthy process in accordance with the Institute of Medicine's "Standards for Developing Trustworthy Clinical Practice Guidelines," and also be free of conflicts of interest and demonstrate an inclusion of the entire body of scientific evidence.

I (or We) ask for your attention to this matter because historically the IDSA treatment guidelines have been the only ones endorsed by the NIH and the CDC. Since 2002, IDSA guidelines have been limited and restrictive, resulting in the failure of patients to be informed about their treatment options and the use of such guidelines by insurance companies to deny essential medical care to patients with persistent Lyme disease symptoms, which, in many cases, leads to long term suffering and disability. To ensure the safety and well-being of your constituents, I (or We) ask you to please intervene.

I (or We) respectfully request that you:

1) Please send a letter to the IDSA Directors reminding them that their review should be unbiased and representative of all available science (sample letter is below and IDSA Directors are listed in APPENDIX E)

2) Please send a copy of your letter to the CDC, so they will be aware that biased guidelines might initiate further inquiry.

Background and resource information is attached in a pdf file, for your review.

Your immediate attention to this issue would be appreciated as the IDSA comment period closes on April 9, 2015.

Sincerely,

Patient/advocate to fill In your name and affiliation here

PS: DEAR (Senator/Congressperson), PLEASE SEE BELOW ALSO, FOR:
A PROPOSED SAMPLE LETTER CONGRESSIONAL REPRESENTATIVES MAY SEND TO THE DIRECTORS OF THE CDC, NIH, AND IDSA
* and when sending these letters, please also include a post script to indicate that you are including the attached pdf.

To: Directors of the Infectious Diseases Society of America
cc: Directors of the Center of Diseases Control
Director of the National Institutes of Health


FROM: (Senator/Congressperson)

Medical and scientific experts, patients, and advocates have requested my attention to the matter of the Treatment Guidelines for Lyme disease, now under review by the Infectious Diseases Society of America (IDSA).

Significant evidence has been offered to demonstrate that the process now underway may intend to dismiss or disregard critical scientific research, evidence, and experience that may not be in concert with the historical tenets represented by the IDSA, and that the information considered in this review may be pre-selected in order to justify and support desired outcomes.

It also appears that the IOM Standards, which call for the inclusion of all opinions and the granting of adequate hearing to all arguments by representatives of ALL key affected groups, are being disregarded. Patients with persistent symptoms following treatment, the physicians who treat them and the researchers studying these phenomena should be fully represented on this review panel.

As the stewards of the health and welfare of our constituencies, it is our expectation that a fair, trustworthy, and unbiased review will address all scientific evidence available on this topic. We would particularly like the IDSA to respond to the research listed in the attached/additional pdf file, which includes both new and prior research that may not yet have been given adequate consideration by the IDSA.

The burgeoning threat of Lyme disease requires a responsible and complete response by those charged with the health and safety of the public. Your attention to this matter is of utmost importance.

Sincerely,
Senator or Congress member ____________

*PS: Please review the attached pdf,

(You can download a copy of the PDF here): http://www.empirestatelymediseaseassociation.org/LYME-DISEASE-INFORMATION-3272015.pdf

[ 03-28-2015, 07:19 AM: Message edited by: KarlaL ]

--------------------
KarlaL

Posts: 694 | From New Lebanon, NY | Registered: Dec 2010  |  IP: Logged | Report this post to a Moderator
KarlaL
LymeNet Contributor
Member # 29631

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Include the following PDF with your letter. Please send the PDF, not the text below which I have posted for you to read.

Link to the (recently updated) PDF: http://www.empirestatelymediseaseassociation.org/LYME-DISEASE-INFORMATION-3272015.pdf

KarlaL


Text of the PDF

LYME-DISEASE-INFORMATION-3252015.pdf

LYME DISEASE INFORMATION March 25, 2015
LYME DISEASE - AN URGENT APPEAL FOR REFORM
Concerning the IDSA’s preparation of new guidelines for Lyme disease

BACKGROUND

The Lyme Disease Treatment Guidelines, authored by the Infectious Diseases Society of America (IDSA), are currently undergoing review. While there are multiple perspectives regarding the best treatment protocols for Lyme disease, and two professional medical societies that specialize in the diagnosis and treatment of Lyme disease, the CDC and the nation's insurance companies have historically selected the guidelines authored by the IDSA to be the sole voice for treatment advice for this highly complex and insufficiently understood illness. This has laid the groundwork for a lack of adequate treatment for hundreds of thousands of Lyme disease patients who have endured, and will continue to endure serious, persistent illness.

In 2013, the CDC acknowledged that more than 300,000 people each year are infected with Lyme disease in the US. A significant percentage of this population does not improve with traditional treatment. The CDC estimates a range from 10% to 20%, but researchers believe the actual percentages of patients whose symptoms persist to be much higher. Developing a well-informed and comprehensive response to this growing threat is a national imperative, and one that must be executed fairly, responsibly, and without bias.

When Lyme disease emerged on the national radar in the 1970's, some researchers and physicians were confounded by the failure of patients to recover from this infection using traditional treatments. With the passing of years and the introduction of IDSA Treatment guidelines for Lyme disease in 2000, a number of physicians found the new IDSA guidelines unsatisfactory. Some patients simply did not get better. The guidelines were too restrictive and shortsighted and if followed, proved to be deleterious to the health of a frightening number of patients.

In addition, the guideline authors were possibly influenced by special interests, as demonstrated by Senator Blumenthal in 2006 when, as Attorney General of Connecticut, he filed an anti-trust suit against the IDSA. (See APPENDIX C.) Then Attorney General Blumenthal’s investigation concluded that there was evidence of antitrust behavior in the creation of the IDSA guidelines and significant undisclosed conflicts of interest in the majority of members of the Guidelines review panel. The suit required that the IDSA create a new “review panel” to re-review the then current guidelines. Unfortunately, this new panel had only IDSA followers as members, likely influencing them, in a self-dealing manner, that there were no problems with their own guidelines. Our well founded concern is that this current IDSA panel will rely only on their own expert opinion (as the 2008 panel and prior review panels had) and will ignore the body of scientific evidence, which in effect, points to the medical necessity of more comprehensive, less restrictive treatments.

In particular, research and experience has shown that the IDSA may be incorrect in their steadfast denial of the possibility that "persistent" disease is a feature of the infection, in light of the fact that strict adherence to the IDSA guidelines has resulted in long term suffering in tens of thousands of patients -- suffering which perhaps could have been avoided with a more comprehensive treatment approach.

Over the past 30 years, a body of independent research and clinical experience has been compiled; it offers compelling evidence that challenges many of the long-held IDSA tenets and at the very least, according to the Institute of Medicine’s Standards for creating guidelines, new evidence warrants inclusion and not dismissal. Indeed, the IDSA has continued to dismiss this body of evidence. The new evidence contradicts a number of conclusions of IDSA research and therefore, should be of great concern to the US Congress. By failing to include the full scope of available science, the IDSA has not been able to develop one useful, comprehensive set of guidelines. This, according to patients across the country and around the world, has been devastating for them. Currently, as thousands will testify, there are medical professionals who bravely go outside the restrictive IDSA guideline box in order to save their patients.

Great scientific uncertainty regarding proper diagnosis and testing exists. This uncertainty further complicates the formation of one final set of treatment guidelines. Medical ethics dictate that when test results have been proven to be inaccurate and multiple treatment options exist, then, if a diagnosis is determined, patients should be informed about ALL treatment options and be given the right to choose a treatment protocol. Yet, in the case of Lyme disease, the IDSA, and by extension, the medical community at large, ignores this mandate, and only endorses the IDSA Guidelines. This "selection bias" also exists despite a CDC survey that reported persisting symptoms in patients who received a short- term course of antibiotic treatment (see APPENDIX A), can lead to long-term disability. In spite of these compelling factors, since 2000, IDSA Guidelines have been continually favored, thereby denying the medical community and the American public access to other medically recognized perspectives regarding treatment.

It is essential that the process by which all guidelines are reviewed and adopted be careful to not only follow IOM Standards, but to ensure the best result so that the best options will be available to all patients.

THE REVIEW PROCESS NOW UNDERWAY

As recommended by the Institutes of Medicine, organizations are advised to review and appropriately revise their Treatment Guidelines to reflect new science every five years.

The IDSA has notified the public that their Lyme Disease Treatment Guidelines are under review, and a 30-day comment period, that precedes the release of the Guidelines, will expire on April 9, 2015. This of course, is in the best interest of the health of American citizens.

The public and scientists and physicians who have reviewed the IDSA review process find troubling indications that the IOM’s Standard’s are not being observed. The following would indicate that this process is likely being manipulated to result in Guidelines that serve the competitive interests of the Infectious Diseases Society of America and its influential senior members, rather than the American public.

Items of specific concern include:

1. There is no one on the IDSA Review panel representing the research conducted in the past ten years that supports the theory that the causative agent of Lyme disease, Borrelia burgdorferi, can persist after antibiotic therapy, thus possibly accounting for the failure of a percentage of patients to recover. (See APPENDIX B for specific studies and references.)

2. In violation of IOM Standards, the panel does not include representatives from key affected groups, including a current or former patient and a patient advocate or patient organization representative. Indeed, the single “Consumer Representative” chosen to represent the interests of patients suffering with Lyme disease is from Nebraska, a non-endemic region and she has no familiarity with Lyme disease. Thousands of patients want to express their concerns regarding the limits of the IDSA Guidelines and it is important that their voices be heard.

3. Contrary to the Institute of Medicine "Standards for Developing Trustworthy Clinical Practice Guidelines," a number of members on the current IDSA guidelines panel have known conflicts of interest. (Please see Appendix D)

To ensure a fair process, the following research should be reviewed and properly represented during the IDSA review.

Please return confirmation of said review to the address above:
• Bradley JF,et al, The Persistence of Spirochetal Nucleic Acids in Active Lyme Arthritis. Ann Int Med 1994;487-9
• Bayer ME, Zhang L, Bayer MH. Borrelia burgdorferi DNA in the urine of treated patients with chronic Lyme Disease symptoms. A PCR study of 97 cases. Infection 1996. Sept-Oct;24(5):347-53
• Diringer MN, et al, Lyme meningoencephalitis- report of a severe, penicillin resistant case. Arthritis & Rheum, 1987;30:705-708
• Donta, ST, Tetracycline therapy in chronic Lyme disease. Chronic Infectious Diseases, 1997; 25 (Suppl 1): 552-56
• Fitzpatrick JE, et al. Chronic septic arthritis caused by Borrelia burgdorferi. Clin Ortho 1993 Dec;(297):238-41
• Georgilis K, Peacocke M, &Klempner MS. Fibroblasts protect the Lyme disease spirochete, Borrelia burgdorferi, from ceftriaxone in vitro. J Infect Dis 1992;166: 440-444
• Fallon BA, et al. Repeated antibiotic treatment in chronic Lyme disease, Journal of Spirochetal and Tick- borne Diseases, 1999; 6 (Fall/Winter):94-101
• Fraser DD, et al. Molecular detection of persistent Borrelia burgdorferi in a man with dermatomyositis. Clinical and Exper Rheum. 1992;10:387-390
• Fried MD et al, Borrelia burdorferi persists in the gastrointestinal tract of children and adolescents with Lyme Disease, JNL of Spirochetal and Tick-borne Diseases, Spring/Summer 2002; 9:11-15
• Girschick HJ, et al. Intracellular persistence of Borrelia burgdorferi in human synovial cells. RheumatolInt 1996;16(3):125-132
• Hassler D, et al. Pulsed high-dose cefotaxime therapy in refractory Lyme Borreliosis (letter). Lancet 1991;338:193
• Horowitz RI. Chronic Persistent Lyme Borreliosis: PCR evidence of chronic infection despite extended antibiotic therapy: A Retrospective Review. Abstract XIII Intl Sci Conf on Lyme Disease. Mar 24-26, 2000.
• Haupl T, et al. Persistence of Borrelia burgdorferi in ligamentous tissue from a patient with chronic Lyme
borreliosis. Arthritis Rheum 1993;36:1621-1626
• Karma A, et al. Long term follow-up of chronic Lyme neuroretinitis. Retina 1996;16:505-509
• Keller TL, et al. PCR detection of Borrelia burgdorferi DNA in cerebrospinal fluid of Lyme neuroborreliosis
patients. Neurology 1992;43:32-42
• Masters EJ, et al. Spirochetemia after continuous high-dose oral amoxicillin therapy. Infect DisClin
Practice 1994;3:207-208
• Ma Y, et al. Intracellular localization of Borrelia burgdorferi within human endothelial cells. Infect Immun
1991;59:671-678
• Meier P, et al. Pars planavitrectomy in Borrelia burgdorferiendophthalmitis. KlinMonatsblAugenheilkd
1998 Dec;213(6):351-4
• Preac-Mursic V, et al. Survival of Borrelia burgdorferi in antibiotically treated patients with Lyme
borreliosis. Infection 1989;17:355-359.
• Preac-Mursic V, et al. Persistence of Borrelia burdorferi and Histopathological Alterations in
Experimentally Infected Animals. A comparison with Histopathological Findings in Human Lyme Disease.
Infection 1990;18(6):332-341
• Straubinger RK, et al. Persistence of Borrelia burgdorferi in Experimentally Infected Dogs after Antibiotic
Treatment. J ClinMicrobiol 1997;35(1):111-116 • Embers, M. et al. Persistence of Borrelia burgdorferi in Rhesus Macaques following Antibiotic treatment
of Disseminated Infection. PLoS ONE 7(1): e29914. doi:10.1371/journal.pone Chronic persistent infection with Bb despite intensive antibiotics was also proven in two recent Xenodiagnostics studies. The first was in mice:
• Hodzic E, Barthold SW (2014) Resurgence of Persisting Non-Cultivable Borrelia burgdorferi following Antibiotic Treatment in Mice. PLoS ONE 9(1): e86907.
Results confirmed previous studies: Bb could not be cultured from tissues, but low copy numbers of Bb flaB DNA were detectable in tissues up to 8 months after completion of treatment & RNA transcription of genes was seen with visualized spirochetes. In humans, a recent NIH study by Dr Marques showed that among ten patients who had high levels of antibodies against B. burgdorferi after antibiotic treatment, two of those patients had “indeterminate results”, and one patient with Post Treatment Lyme disease syndrome (PTLDS) had a positive result, confirming evidence of ongoing Borrelia DNA in these patients:
• Marques, A. et al. Xenodiagnosis to Detect Borrelia burgdorferi Infection: A First-in-Human Study. Clinical Infectious Diseases DOI: 10.1093/cid/cit939 (2014).
• Analysis of Overall Level of Evidence Behind Infectious Diseases Society of America Practice Guidelines,DongHeun Lee, MD; Ole Vielemeyer, MD; Arch Intern Med. 2011;171(1):18-22
• (Ziska MH, Donta ST, Demarest FC. Physician preferences in the diagnosis and treatment of Lyme disease in the United States. Infection 1996 Mar-Apr;24(2):182-6).
• Hook S, Nelson C, Mead P. Self-reported Lyme disease diagnosis, treatment, and recovery: Results from 2009, 2011, & 2012 Health Styles nationwide surveys. Presented at The 13th International Conference on Lyme Borreliosis and other Tick Borne Diseases, Boston, MA Aug 19, 2013. Available from: http://archive.poughkeepsiejournal.com/assets/pdf/BK211780914.pdf.
• Marangoni, A. et al. Comparative evaluation of three different ELISA methods for the diagnosis of early culture-confirmed Lyme disease in Italy. J. Med. Microbiol. 54, 361-367 (2005);
• Ang, C.W.,et al. T. Large differences between test strategies for the detection of anti-Borrelia antibodies are revealed by comparing eight ELISAs and five immunoblots. Eur. J. Clin. Microbiol. Infect. Dis. 30, 1027-1032 (2011).
• Wojciechowska-Koszko, et al. Serodiagnosis of borreliosis; Arch. Immunol. Ther. Exp. 59, 69-77 (2011). • (Coulter,etal.,J Clin Microbiol 2005;43:5080-5084 • Aucott JN, et al. Post-treatment Lyme disease syndrome symptomatology and the impact on life
functioning: is there something here? Qual Life Res. 2013 Feb;22(1):75-84 • Centers for Disease Control Prevention MMWR56(23);573-576, June 15, 2007
http://www.cdc.gov/ncphi/disss/nndss/casedef/lyme_disease_2008.htm
• Berglund J, Stjernberg L, Ornstein K, Tykesson-Joelsson K, Walter H. 5-y Follow-up study of patients with
neuroborreliosis. Scand J Infec Dis. 2002;34(6):421-5.
• Valesová H, Mailer J, Havlík J, Hulínská D, Hercogová J. Long-term results in patients with Lyme arthritis
following treatment with ceftriaxone. Infection. 1996 Jan-Feb;24(1):98-102
• Logigian (1990) : After 6 mo’s of therapy, 10/27 patients treated with IV antibiotics relapsed or had
treatment failure.
• Pfister (1991): 33 patients with neuroborreliosis were treated with IV antibiotics, and after a mean of 8.1
months 10/27 were symptomatic and borrelia persisted in the CSF in 1 patient.
• Shadick (1994) : 10/38 pts relapsed (5 with IV) within 1 year of treatment, and had repeated antibiotic
treatment.
• Asch (1994) : 28% relapsed w/ major organ involvement 3.2 years after initial treatment • Antibiotic treatment in patients with persistent symptoms and a history of Lyme disease. The New
England journal of medicine. 2001 Jul 12:85-92 • Krupp LB, Hyman LG, Grimson R, Coyle PK, Melville P, Ahnn S, et al. Study and treatment of post Lyme
disease (STOP-LD): a randomized double masked clinical trial. Neurology. 2003 Jun 24;60(12):1923-30
• Fallon BA, Keilp JG, Corbera KM, Petkova E, Britton CB, Dwyer E, et al. A randomized, placebo-controlled trial of repeated IV antibiotic therapy for Lyme encephalopathy. Neurology. 2008 Mar 25:992-1003
• Cameron DJ, Johnson LB, Maloney EL. Evidence assessments and guideline recommendations in Lyme
disease: the clinical management of known tick bites, erythema migrans rashes and persistent disease.
Expert Review Anti-Infective Therapy. 2014 Sep;12(9):1103-35.
• Institute of Medicine. Clinical Practice Guidelines We Can Trust. Washington, DC: National Academies
Press; 2011. Available from: http://books.nap.edu/openbook.php?record_id=1305
• Fallon BA, Petkova E, Keilp J, Britton C. A reappraisal of the U.S. clinical trials of Post-Treatment Lyme
Disease Syndrome. Open Neurology Journal. 2012;6(Supp. 1-M2):79-87.
• Liegner KB. Lyme Disease: The Sensible Pursuit of Answers.(Guest Commentary). J ClinMicrobiol 1993;31:1961-1963.
• Liegner KB, Shapiro JR, Ramsay D, Halperin AJ, Hogrefe W, Kong L. Recurrent erythema migrans despite extended antibiotic treatment with minocycline in a patient with persisting Borrelia burgdorferi Infection. J AmerAcadDerm 1993;28:312-4.
• Liegner KB, Duray P, Agricola M, Rosenkilde C, Yannuzzi L, Ziska M, Tilton R, Hulinska D, Hubbard J, Fallon B. Lyme Disease and the Clinical Spectrum of Antibiotic-Responsive Chronic Meningoencephalomyelitides. J Spirochetal and Tick-borne Dis 1997;4:61-73.
• Fallon BA, Tager F, Fein L, Liegner K, Keilp J, Weiss N, Liebowitz MR. Repeated Antibiotic Treatment in Chronic Lyme Disease. J Spirochetal and Tick-borne Dis 1999;6:94-102.
• Delong et al. Antibiotic retreatment of Lyme disease in patients with persistent symptoms: A biostatistical review of randomized, placebo controlled, clinical trials. Contemporary Clinical Trials 33 (2012), 1132-1142
• Wahlberg,P. et al, Treatment of late Lyme borreliosis. J Infect, 1994. 29(3): p255-61 →31% improved w/ 14 days of Rocephin, 89% improved w/ Rocephin + 100d of Amoxicillin and Probenecid, 83% improved w/ Rocephin, then 100 days of cephadroxil
• Donta, ST., Tetracycline therapy for chronic Lyme disease. Clin Infect Dis, 1997. 25 Suppl 1: p.S52-6. →277 pts with chronic LD treated between 1-11 months: 20% cured, 70% improved, 10% failed
• Oksi, J et al., Comparison of oral cefixime and intravenous ceftriaxone followed by oral amoxicillin in disseminated Lyme borreliosis. Eur J ClinMicrobiol Infect Dis, 1998. 17(10) [Razz] 715-9→ 30 pts w/ chronic Lyme disease were treated for 100 days, and 90% had good or excellent responses
• Oksi, J., et al. Borrelia burgdorferi detected by culture and PCR in clinical relapse of disseminated Lyme borreliosis. Ann Med, 1999. 31(3) [Razz] .225-32→32/165 patients with disseminated Lyme were treated for 1 or more months of antibiotics, and showed that even more than 3 months of treatment may not eradicate the spirochete, and that longer term therapy may be necessary.

Additional Resources

APPENDIX A

Summary of HHS Special Webinar of Lyme Disease and Borrelia Persistence, May 22, 2014 Convened by Dr. Ben Beard, CDC, NCEZID, Div. of Vector-borne diseases Moderated by Dr. Joseph Breen, NIH, NIAID

Stated Purpose of Webinar: To discuss the state of the science with regard to persistence of infection by Borrelia burgdorferi (the bacterial agent that causes Lyme disease.

As expressed by Dr. Ben Beard in his opening comments of this webinar, the official position of the Centers for Disease Control with regard to the treatment of Lyme disease, a bacterial infection transmitted by ticks, is that 2 to 4 weeks of oral doxycycline results in a “symptomatic cure” for the “great majority” of Lyme disease patients. However, the results of a CDC Health Survey presented in poster session at the International Conference of Lyme Borreliosis and Other Tick-borne Diseases by Dr. Paul Mead et. al. of the CDC in August 2013 showed that approximately 1% of survey respondents (n=3503) had been diagnosed with Lyme disease in the United States in 2012, which resulted in the CDC revising estimates of the number of cases of Lyme disease upward by a factor of 10, to approximately 312,000 cases of Lyme disease annually. This CDC survey also showed that of those who had been diagnosed, 61% were treated with antibiotics for longer than the recommended 2 to 4 weeks, and that one-third of the respondents did not experience a “symptomatic cure” of their symptoms after 6 to 24 months. Patients who continue to have symptoms of Lyme disease after antibiotic treatment that may last for months to years are characterized as having “Post-treatment Lyme Disease Syndrome” by the CDC and NIH. This is also referred to as “chronic” Lyme disease, implying that symptoms do not resolve following antibiotic treatment due to the biological capacity of Borrelia burgdorferi, a spirochete bacterium, to survive the antibiotic treatment and cause persisting infection.

There are three hypotheses to explain why a significant number of people with Lyme disease do not experience a symptomatic cure of their symptoms when treated with 2 to 4 weeks of oral doxycycline. These are (1) induction of an inflammatory response by dead spirochetes or cell parts remaining after antibiotic treatment; (2) continuation of an active infection by live spirochetes that survive the antibiotic treatment; or (3) an “autoimmune” series of irreversible sequelae from a previous infection. Persistence of Borrelia spp. in animals or humans following antibiotic treatment is strong evidence that unresolved symptoms are due to continuation of an active infection.

To briefly summarize the proceedings of the HHS Special Webinar on Lyme disease and Borrelia Persistence, there is consensus that Borrelia spp. can cause persistent infection in several animal hosts and in humans. Specifically, the scientific evidence includes the findings that Borrelia DNA, RNA, proteins, and culturable spirochetes can be recovered from infected animals that have been treated with antibiotics (with the concomitant observation that DNA alone rapidly becomes undetectable when injected into host animals); that Borrelia DNA can be recovered from humans with PTLDS; and that studies with human subjects are needed. Human studies will require the development of better methods of testing for correlating infection with persistence of symptoms in humans.

Public and non-public scientists were convened for this webinar. The following is a summary of the individual presentations from the transcript of the webinar available at the CDC website.

Dr. Stephen Barthold, University of California, Davis
• The life cycle of Borrelia spp. is complex and includes multiple reservoir hosts and three life
stages of ticks, which would not be biologically possible if persistent infection was not part of
this life cycle.
• Persisting infection has been confirmed in studies involving humans who are not treated with
antibiotics.
• Borrelia DNA and RNA transcripts of Borrelia genes, which indicates biological activity by live
bacteria, are found in infected animals (mice, rats, hamsters, guinea pigs, gerbils, dogs, and 2
species of non-human primates) after antibiotic treatment.
• DNA alone, when injected into animals (or fetal DNA in the maternal circulation) is rapidly
cleared and becomes undetectable.
• Pro-inflammatory cytokine responses are seen in persistently-infected animal models.
Dr. Linda Bockenstedt, Yale University School of Medicine
• Spirochetes are difficult to grow in culture under normal circumstance, which is why culture-
based methods to detect Borrelia or diagnose Lyme disease are not used for human diagnostics.
• Using xenodiagnostic methods, viable spirochetes (as determined by culture) and Borrelia DNA was found in infected, antibiotic-treated mice in one mouse model (B6), but not in C3H mice, in which “remnants” of spirochetes, which were not culturable but that contained DNA, were observed. These results are contradictory, and indicate that genetic variation in the host may influence the course of the disease and the extent of the disease symptomsin mice.
• Persisting symptoms may be due to either continuing active infection by live spirochetes, or may be due to inflammation triggered by Borrelia “remnants” in tissues.
• Persistence of symptoms after antibiotic treatment in humans needs to be studied in a human system, in the context of the emerging research on the human microbiome (bacteria that live in/on humans and play an active role in both health and disease).
Dr. Monica Embers, Tulane University
• Rhesus macaque monkeys (non-human primates) are a good model system for Lyme disease
because the disease course is very close to what is seen in humans.
• Numerous studies have previously shown that Borrelia may evade the human/animal immune
response, that the bacteria can survive for months to years in ticks without nutrient replenishment and without reproducing, and that they are found deep in connective tissues, which are sites not readily penetrated by most antibiotics.
• Culturable spirochetes (and Borrelia DNA) are recovered from infected monkeys following treatment with doxycycline at concentrations that far exceed human dosage.

Dr. Adriana Marques, NIAID
• Xenodiagnosis using laboratory-raised ticks is safe as a method of study in humans. • Ticks applied to humans with various forms of Lyme disease were tested for spirochetes or
Borrelia DNA by culture, PCR, and by mass spectrometry.
• Ticks that fed on the “positive control,” which was a person with known early Lyme disease and taking doxycycline at the time of the study, had DNA from two different genotypes of Borrelia
burgdorferi.
• 1 of 10 people in the PTLDS (Post-treatment Lyme Disease Syndrome) group was positive for Borrelia by mass spectrometry, and the bacterium was found to be a “novel” genotype by DNA analysis. This person was again positive for the same genotype of Borrelia in a separate xenodiagnosis procedure 8 months later.
• 2 additional people in the PTLDS group were positive for Borrelia by mass spectrometry, but the recovered DNA was similar to the DNA of a reference (laboratory) strain of Borrelia, so these were not considered “positive.”
• A “possible hypothesis” to explain the recovery of Borrelia from 1 to 3 (of 10) PTLDS patient(s) is continuing active infection by the spirochetes in the people with PTLDS.

Dr. Linden Hu, Tufts University
• There are several findings with regard to Borrelia infection that are consistent across labs (meaning, there is consensus on the following):
o Antibiotic treatment decreases the number of bacteria and/or levels of DNA.
o Antibody levels decrease in animals after antibiotic treatment.
o DNA, RNA, and proteins from Borrelia can be detected in animals after antibiotic treatment; however, spirochetes can’t be “cultured” from antibiotic-treated animals. Possible explanations for this include persistence of the DNA, RNA or protein molecules as remnants of the infection after the bacteria are dead, or that the bacteria are alive but “altered” by the antibiotics so that they are no longer culturable.
• The latter hypothesis (that antibiotics alter the bacterial phenotype) is supported by many studies on bacteria that show a “persister” state after antibiotics. Coxiellaburnetii (causative agent of Q fever) is one example of a bacterium that causes long term disease treated with long term antibiotics, for which DNA and bacterial proteins are found to persist in infected hosts. Transplanted tissues from infected hosts can transfer those bacterial antigens to a new host, but the bacteria cannot be cultured from the new host.
• Antibiotics are an agent of natural selection, and antibiotic treatment selects for the phenotype of non-replicating “persister” cells.
• “Borrelia does not break the rules (of infection), we just don’t understand the rules”

The research described in this webinar, together with the data from the Health Surveys conducted by the CDC indicating that the number of Lyme disease cases is 6 times greater than the number of cases of HIV/AIDS on an annual basis, illustrate the need for a broader review of the science pertaining to Lyme disease in the United States.

This summation was compiled by Holly Ahern, Associate Professor of Microbiology, SUNY Adirondack ([email protected])

APPENDIX B

ADDITIONAL COMMENTS AND CITATIONS

1. Physicians in the United States have a choice to follow either of these two evidence based guidelines, but there are known problems with the IDSA guidelines. A published scientific review in the Archives of Internal Medicine that analyzed the overall level of evidence behind the IDSA guidelines concluded:
“We analyzed the strength of recommendation and overall quality of evidence behind 41 IDSA guidelines released between January 1994 and May 2010...More than half of the current recommendations of the IDSA are based on level III evidence only (opinion). Until more data from well-designed controlled clinical trials become available, physicians should remain cautious when using current guidelines as the sole source guiding patient care decisions”.
Analysis of Overall Level of Evidence Behind Infectious Diseases Society of America Practice Guidelines,DongHeun Lee, MD; Ole Vielemeyer, MD; Arch Intern Med. 2011;171(1):18-22

2. The majority of physicians in the United States in fact do not follow IDSA guidelines. They treat for seronegative disease, and treat for extended periods of time. An article published in the journal Infection in 1996 by Dr. Sam Donta highlighted the discrepancy, and showed that the majority of physicians do not treat according to IDSA guidelines:
“For chronic Lyme disease, 57% of responders treat 3 months or more.”
(Ziska MH, Donta ST, Demarest FC. Physician preferences in the diagnosis and treatment of Lyme disease in the United States. Infection 1996 Mar-Apr;24(2):182-6.

3. A recent study by the CDC confirmed the same data. The CDC surveyed a representative sample of people in the US and found that only 39% of those with Lyme disease were treated in accordance with blanket short term recommendations in the IDSA guidelines. The majority were treated for longer periods.
Hook S, Nelson C, Mead P. Self-reported Lyme disease diagnosis, treatment, and recovery: Results from 2009, 2011, & 2012 Health Styles nationwide surveys. Presented at The 13th
International Conference on Lyme Borreliosis and other Tick Borne Diseases, Boston, MA Aug 19, 2013. Available from: http://archive.poughkeepsiejournal.com/assets/pdf/BK211780914.pdf.

4. The reason the majority of physicians in the United States do not follow IDSA guidelines is because more than half of their recommendations are based on poor scientific evidence (known as level III evidence) and it has been demonstrated that the two-tier testing approach recommended by the IDSA often does not work in clinical practice. According to these guidelines, a Western blot is not to be performed if the ELISA is negative, despite the poor sensitivity of ELISA tests ranging from 34% to 70.5%. The effect of using the IDSA guidelines would be to miss roughly half of those suffering with Lyme disease.
• Marangoni, A. et al. Comparative evaluation of three different ELISA methods for the diagnosis of early culture-confirmed Lyme disease in Italy. J. Med. Microbiol. 54, 361-367 (2005);
• Ang, C.W.,et al. T. Large differences between test strategies for the detection of anti-Borrelia antibodies are revealed by comparing eight ELISAs and five immunoblots. Eur. J. Clin. Microbiol. Infect. Dis. 30, 1027-1032 (2011).
• Wojciechowska-Koszko, et al. Serodiagnosis of borreliosis; Arch. Immunol. Ther. Exp. 59, 69-77 (2011.

5. John Hopkins University also found problems with the CDC two-tiered testing approach. In 2005, John’s Hopkins did a study and found that the CDC two-tiered testing missed up to 55% of positive Lyme cases.
(Coulter,etal.,J Clin Microbiol 2005;43:5080-5084.

6. A NYS DOH study done in 1996 that was reported to the CDC, found the number of patients missed by the two-tiered protocol (without an EM rash) to be even higher: 81% of Non-EM Cases were not confirmed with present two-tiered testing algorithms (CDC correspondence with NYS DOH, April 15th, 1996).
Inaccurate diagnostic tests, based on technology that is over 20 years old, creates medical uncertainty in both the diagnosis and treatment of Lyme disease

7. In 2013, the CDC acknowledged that more than 300,000 people a year will be infected with Lyme disease in the US. They estimate that 10% to 20% of this population will suffer long-term illness as a result of their Lyme infection. (Many researchers believe this estimate to be very low.) (http://www.cdc.gov/lyme/treatment/).
Other studies suggest the treatment failure rate for early Lyme disease may be as high as 36%:
Aucott JN, et al. Post-treatment Lyme disease syndrome symptomatology and the impact on life functioning: is there something here? Qual Life Res. 2013 Feb;22(1):75-84
In late Lyme disease, treatment failure rates may exceed 50%:
Cameron, D., Horowitz, R, et al: Treatment of Lyme disease: a medicolegal assessment. Expert review of anti-infective therapy. 2004 Aug;2(4):533-57

8. Lyme disease is the number one vector borne spreading infectious disease in the US, and it is first and foremost, a clinical diagnosis. Blood tests are known to be unreliable, and the two- tiered approach put forth by the IDSA is only intended to be used by health departments to epidemiologically screen large populations for the disease. This was highlighted years ago on the CDC web site. In the words of the CDC:
“This surveillance case definition was developed for national reporting of Lyme disease; it is not intended to be used in clinical diagnosis.”
Centers for Disease Control Prevention MMWR56(23);573-576, June 15, 2007 http://www.cdc.gov/ncphi/disss/nndss/casedef/lyme_disease_2008.htm

9. Prior IDSA guidelines used the CDC definition to diagnose Lyme disease, resulting in large numbers of individuals becoming chronically ill and increasing suffering and disability. Updated research on the insensitivity of testing must be included in the new guidelines, to ensure the safety of the American people.

10. Research, including recent studies, has also shown persistence of the Lyme disease bacteria despite short courses of antibiotic therapies. Insurance companies have denied appropriate care to patients, using the IDSA guidelines as their sole source for diagnosis and treatment. In order to protect the American public from this emerging epidemic, it is important that the IDSA panel comments on this substantial and compelling body of research listed below which shows chronic persistent infection despite intensive antibiotics:
• Bradley JF ,et al, The Persistence of Spirochetal Nucleic Acids in Active Lyme Arthritis. Ann Int Med 1994;487-9
• Bayer ME, Zhang L, Bayer MH. Borrelia burgdorferi DNA in the urine of treated patients with chronic Lyme Disease symptoms. A PCR study of 97 cases. Infection 1996. Sept-Oct;24(5):347-53
• Diringer MN, et al, Lyme meningoencephalitis- report of a severe, penicillin resistant case. Arthritis & Rheum, 1987;30:705-708
• Donta, ST, Tetracycline therapy in chronic Lyme disease. Chronic Infectious Diseases, 1997; 25 (Suppl 1): 552-56
• Fitzpatrick JE, et al. Chronic septic arthritis caused by Borrelia burgdorferi. Clin Ortho 1993 Dec;(297):238-41
• Georgilis K, Peacocke M, &Klempner MS. Fibroblasts protect the Lyme disease spirochete, Borrelia burgdorferi, from ceftriaxone in vitro. J Infect Dis 1992;166: 440-444
• Fallon BA, et al. Repeated antibiotic treatment in chronic Lyme disease, Journal of Spirochetal and Tick- borne Diseases, 1999; 6 (Fall/Winter):94-101
• Fraser DD, et al. Molecular detection of persistent Borrelia burgdorferi in a man with dermatomyositis. Clinical and Exper Rheum. 1992;10:387-390
• Fried MD et al, Borrelia burdorferi persists in the gastrointestinal tract of children and adolescents with Lyme Disease, JNL of Spirochetal and Tick-borne Diseases, Spring/Summer 2002; 9:11-15
• Girschick HJ, et al. Intracellular persistence of Borrelia burgdorferi in human synovial cells. RheumatolInt 1996;16(3):125-132
• Hassler D, et al. Pulsed high-dose cefotaxime therapy in refractory Lyme Borreliosis (letter). Lancet 1991;338:193
• Horowitz RI. Chronic Persistent Lyme Borreliosis: PCR evidence of chronic infection despite extended antibiotic therapy: A Retrospective Review. Abstract XIII Intl Sci Conf on Lyme Disease. Mar 24-26, 2000.
• Haupl T, et al. Persistence of Borrelia burgdorferi in ligamentous tissue from a patient with chronic Lymeborreliosis. Arthritis Rheum 1993;36:1621-1626
• Karma A, et al. Long term follow-up of chronic Lyme neuroretinitis. Retina 1996;16:505-509 • Keller TL, et al. PCR detection of Borrelia burgdorferi DNA in cerebrospinal fluid of Lyme neuroborreliosis patients. Neurology 1992;43:32-42
• Masters EJ, et al. Spirochetemia after continuous high-dose oral amoxicillin therapy. Infect DisClin Practice 1994;3:207-208 • Ma Y, et al. Intracellular localization of Borrelia burgdorferi within human endothelial cells. Infect Immun
1991;59:671-678
• Meier P, et al. Pars planavitrectomy in Borrelia burgdorferiendophthalmitis. KlinMonatsblAugenheilkd
1998 Dec;213(6):351-4
• Preac-Mursic V, et al. Survival of Borrelia burgdorferi in antibiotically treated patients with Lyme
borreliosis. Infection 1989;17:355-359.
• Preac-Mursic V, et al. Persistence of Borrelia burdorferi and Histopathological Alterations in Experimentally Infected Animals. A comparison with Histopathological Findings in Human Lyme Disease. Infection 1990;18(6):332-341
• Straubinger RK, et al. Persistence of Borrelia burgdorferi in Experimentally Infected Dogs after Antibiotic Treatment. J ClinMicrobiol 1997;35(1):111-116
• Embers, M. et al. Persistence of Borrelia burgdorferi in Rhesus Macaques following Antibiotic treatment of Disseminated Infection. PLoS ONE 7(1): e29914. doi:10.1371/journal.pone
Chronic persistent infection with Bb despite intensive antibiotics was also proven in recent Xenodiagnosticsstudies. The first study was in mice:
• Hodzic E, Barthold SW (2014) Resurgence of Persisting Non-Cultivable Borrelia burgdorferi following Antibiotic Treatment in Mice. PLoS ONE 9(1): e86907. Results confirmed previous studies: Bb could not be cultured from tissues, but low copy numbers of Bb flaB DNA were detectable in tissues up to 8 months after completion of treatment & RNA transcription of genes was seen with visualized spirochetes. In humans, a recent NIH study by Dr. Marques showed that among ten patients who had high levels of antibodies against B. burgdorferi after antibiotic treatment, two of those patients had “indeterminate results”, and one patient with Post Treatment Lyme disease syndrome (PTLDS) had a positive result, confirming evidence of ongoing Borrelia DNA in these patients: • Marques, A. et al. Xenodiagnosis to Detect Borrelia burgdorferi Infection: A First-in-Human Study. Clinical
Infectious Diseases DOI: 10.1093/cid/cit939 (2014).
• Liegner KB. Lyme Disease: The Sensible Pursuit of Answers.(Guest Commentary). J ClinMicrobiol
1993;31:1961-1963.
• Liegner KB, Shapiro JR, Ramsay D, Halperin AJ, Hogrefe W, Kong L. Recurrent erythema migrans despite extended antibiotic treatment with minocycline in a patient with persisting Borrelia burgdorferi
infection. J AmerAcadDerm 1993;28:312-4. • Liegner KB, Duray P, Agricola M, Rosenkilde C, Yannuzzi L, Ziska M, Tilton R, Hulinska D, Hubbard J, Fallon
B. Lyme Disease and the Clinical Spectrum of Antibiotic-Responsive Chronic
Meningoencephalomyelitides. J Spirochetal and Tick-borne Dis 1997;4:61-73.
• Fallon BA, Tager F, Fein L, Liegner K, Keilp J, Weiss N, Liebowitz MR. Repeated Antibiotic Treatment in Chronic Lyme Disease. J Spirochetal and Tick-borne Dis 1999;6:94-102.

11. Some physicians feel that there is no evidence of prolonged antibiotics helping symptoms. It is known that short term antibiotics fail in 25% to 71% of patients with late stage disease:
• Berglund J, Stjernberg L, Ornstein K, Tykesson-Joelsson K, Walter H. 5-y Follow-up study of patients with neuroborreliosis. Scand J Infec Dis. 2002;34(6):421-5.
• Valesová H, Mailer J, Havlík J, Hulínská D, Hercogová J. Long-term results in patients with Lyme arthritis following treatment with ceftriaxone. Infection. 1996 Jan-Feb;24(1):98-102

12. These frequent treatment relapses and failures with short term therapy are documented by other authors:
• Logigian (1990) : After 6 mo’s of therapy, 10 of 27 patients treated with IV antibiotics relapsed or had treatment failure.
• Pfister (1991): 33 patients with neuroborreliosis were treated with IV antibiotics, and after a mean of 8.1 months 10 of 27 were symptomatic and borrelia persisted in the CSF in 1 patient.
• Shadick (1994) : 10 of 38 pts relapsed (5 with IV) within 1 year of treatment, and had repeated antibiotic treatment.
• Asch (1994) : 28% relapsed w/ major organ involvement 3.2 years after initial treatment

13. Many doctors use IDSA guidelines to base their conclusions to avoid treating sick patients with long term antibiotics. However, only three NIH-funded trials have been conducted on the treatment of chronic Lyme disease:
• Antibiotic treatment in patients with persistent symptoms and a history of Lyme disease. The New England journal of medicine. 2001 Jul 12:85-92
• Krupp LB, Hyman LG, Grimson R, Coyle PK, Melville P, Ahnn S, et al. Study and treatment of post Lyme disease (STOP-LD): a randomized double masked clinical trial. Neurology. 2003 Jun 24;60(12):1923-30
• Fallon BA, Keilp JG, Corbera KM, Petkova E, Britton CB, Dwyer E, et al. A randomized, placebo- controlled trial of repeated IV antibiotic therapy for Lyme encephalopathy. Neurology. 2008 Mar 25:992-1003

14. These were inadequate treatment trials as sample sizes were extremely small, ranging from 37 to 78 patients. Critics have pointed out that studies this small lack sufficient statistical power to measure clinically relevant improvement:
• Cameron DJ, Johnson LB, Maloney EL. Evidence assessments and guideline recommendations in Lyme disease: the clinical management of known tick bites, erythema migrans rashes and persistent disease. Expert Review Anti-Infective Therapy. 2014 Sep;12(9):1103-35.
• Institute of Medicine. Clinical Practice Guidelines We Can Trust. Washington, DC: National Academies Press; 2011. Available from: http://books.nap.edu/openbook.php?record_id=1305

15. Nevertheless, two of the three clinical trials demonstrated that retreatment improved some patients’ measures, such as fatigue and pain (Krupp, Fallon). Others have shown improvement in cognitive function, in those with Lyme encephalopathy (Fallon).
• Fallon BA, Petkova E, Keilp J, Britton C. A reappraisal of the U.S. clinical trials of Post-Treatment Lyme Disease Syndrome. Open Neurology Journal. 2012;6(Supp. 1-M2):79-87.
• Delong et al. Antibiotic retreatment of Lyme disease in patients with persistent symptoms: A biostatistical review of randomized, placebo controlled, clinical trials. Contemporary Clinical Trials 33 (2012), 1132-1142
The medical literature does, in fact, show a benefit to using longer treatment
regimens for disseminated Lyme disease:
• Wahlberg,P. et al, Treatment of late Lyme borreliosis. J Infect, 1994. 29(3): p255-61 →31% improved w/ 14 days of Rocephin, 89% improved w/ Rocephin + 100d of Amoxicillin and Probenecid, 83% improved w/ Rocephin, then 100 days of cephadroxil
• Donta, ST., Tetracycline therapy for chronic Lyme disease. Clin Infect Dis, 1997. 25 Suppl 1: p.S52-6. →277 pts with chronic LD treated between 1-11 months: 20% cured, 70% improved, 10% failed • Oksi, J et al., Comparison of oral cefixime and intravenous ceftriaxone followed by oral amoxicillin
in disseminated Lyme borreliosis. Eur J ClinMicrobiol Infect Dis, 1998. 17(10) [Razz] 715-9→ 30 pts w/chronic Lyme disease were treated for 100 days, and 90% had good or excellent responses
• Oksi, J., et al. Borrelia burgdorferi detected by culture and PCR in clinical relapse of disseminated Lyme borreliosis. Ann Med, 1999. 31(3) [Razz] .225-32→32/165 patients with disseminated Lyme were treated for 1 or more months of antibiotics, and showed that even more than 3 months of treatment may not eradicate the spirochete, and that longer term therapy may be necessary. *This last study detected chronic persistent Lyme by both PCR and culture, the “gold standard” for proving chronic infection.

16. (See APPENDIX A)
In conclusion, the scientific literature shows: 􏰀 unreliable blood tests, 􏰀 persistence of Borreila despite short term treatment, 􏰀 and peer reviewed clinical trials showing benefit of longer term antibiotic therapies.
"HHS/CDC/NIH/FDA SPECIAL WEBINAR - LYME DISEASE AND BORRELIA PERSISTENCE. MAY 22, 2014"

It is therefore incumbent on physicians to use their best clinical judgment in treating their patients and this substantial body evidence should be included in the IDSA review.

APPENDIX C
Connecticut Attorney General's Office Press Release

Attorney General's Investigation Reveals Flawed Lyme Disease Guideline Process, IDSA Agrees To Reassess Guidelines, Install Independent Arbiter

May 1, 2008

Attorney General Richard Blumenthal today announced that his antitrust investigation has uncovered serious flaws in the Infectious Diseases Society of America's (IDSA) process for writing its 2006 Lyme disease guidelines and the IDSA has agreed to reassess them with the assistance of an outside arbiter.

The IDSA guidelines have sweeping and significant impacts on Lyme disease medical care. They are
commonly applied by insurance companies in restricting coverage for long-term antibiotic treatment or other medical care and also strongly influence physician treatment decisions.

Insurance companies have denied coverage for long-term antibiotic treatment relying on these
guidelines as justification. The guidelines are also widely cited for conclusions that chronic Lyme disease is nonexistent.

"This agreement vindicates my investigation -- finding undisclosed financial interests and forcing a reassessment of IDSA guidelines," Blumenthal said. "My office uncovered undisclosed financial interests held by several of the most powerful IDSA panelists.

The IDSA's guideline panel improperly ignored or
minimized consideration of alternative medical opinion and evidence regarding chronic Lyme disease, potentially raising serious questions about whether the recommendations reflected all relevant science.

"The IDSA's Lyme guideline process lacked important procedural safeguards requiring complete
reevaluation of the 2006 Lyme disease guidelines -- in effect a comprehensive reassessment through a new panel. The new panel will accept and analyze all evidence, including divergent opinion. An independent neutral ombudsman -- expert in medical ethics and conflicts of interest, selected by both the IDSA and my office -- will assess the new panel for conflicts of interests and ensure its integrity."

Blumenthal's findings include the following:

• The IDSA failed to conduct a conflicts of interest review for any of the panelists prior to their
appointment to the 2006 Lyme disease guideline panel;
• Subsequent disclosures demonstrate that several of the 2006 Lyme disease panelists had
conflicts of interest;
• The IDSA failed to follow its own procedures for appointing the 2006 panel chairman and
members, enabling the chairman, who held a bias regarding the existence of chronic Lyme, to
handpick a likeminded panel without scrutiny by or formal approval of the IDSA's oversight
committee;
• The IDSA's 2000 and 2006 Lyme disease panels refused to accept or meaningfully consider
information regarding the existence of chronic Lyme disease, once removing a panelist from the
2000 panel who dissented from the group's position on chronic Lyme disease to achieve
"consensus";
• The IDSA blocked appointment of scientists and physicians with divergent views on chronic
Lyme who sought to serve on the 2006 guidelines panel by informing them that the panel was
fully staffed, even though it was later expanded;
• The IDSA portrayed another medical association's Lyme disease guidelines as corroborating its
own when it knew that the two panels shared several authors, including the chairmen of both
groups, and were working on guidelines at the same time. In allowing its panelists to serve on
both groups at the same time, IDSA violated its own conflicts of interest policy.

IDSA has reached an agreement with Blumenthal's office calling for creation of a review panel to
thoroughly scrutinize the 2006 Lyme disease guidelines and update or revise them if necessary. The panel -- comprised of individuals without conflicts of interest -- will comprehensively review medical and scientific evidence and hold a scientific hearing to provide a forum for additional evidence. It will then
determine whether each recommendation in the 2006 Lyme disease guidelines is justified by the
evidence or needs revision or updating.

Blumenthal added, "The IDSA's 2006 Lyme disease guideline panel undercut its credibility by allowing individuals with financial interests -- in drug companies, Lyme disease diagnostic tests, patents and consulting arrangements with insurance companies -- to exclude divergent medical evidence and opinion. In today's healthcare system, clinical practice guidelines have tremendous influence on the marketing of medical services and products, insurance reimbursements and treatment decisions. As a
result, medical societies that publish such guidelines have a legal and moral duty to use exacting safeguards and scientific standards.

"Our investigation was always about the IDSA's guidelines process -- not the science. IDSA should be recognized for its cooperation and agreement to address the serious concerns raised by my office. Our agreement with IDSA ensures that a new, conflicts-free panel will collect and review all pertinent information, reassess each recommendation and make necessary changes.

"This Action Plan -- incorporating a conflicts screen by an independent neutral expert and a public hearing to receive additional evidence -- can serve as a model for all medical organizations and societies that publish medical guidelines. This review should strengthen the public's confidence in such critical
standards."

THE GUIDELINE REVIEW PROCESS

Under its agreement with the Attorney General's Office, the IDSA will create a review panel of eight to 12 members, none of whom served on the 2006 IDSA guideline panel. The IDSA must conduct an open application process and consider all applicants.

The agreement calls for the ombudsman selected by Blumenthal's office and the IDSA to ensure that the review panel and its chairperson are free of conflicts of interest.

Blumenthal and IDSA agreed to appoint Dr. Howard A. Brody as the ombudsman. Dr. Brody is a
recognized expert and author on medical ethics and conflicts of interest and the director of the Institute for Medical Humanities at the University of Texas Medical Branch. Brody authored the book, "Hooked: Ethics, the Medical Profession and the Pharmaceutical Industry."

To assure that the review panel obtains divergent information, the panel will conduct an open scientific hearing at which it will hear scientific and medical presentations from interested parties. The agreement
requires the hearing to be broadcast live to the public on the Internet via the IDSA's website. The
Attorney General's Office, Dr. Brody and the review panel will together finalize the list of presenters at the hearing.

Once it has collected information from its review and open hearing, the panel will assess the
information and determine whether the data and evidence supports each of the recommendations in
the 2006 Lyme disease guidelines.

The panel will then vote on each recommendation in the IDSA's 2006 Lyme disease guidelines on
whether it is supported by the scientific evidence. At least 75 percent of panel members must vote to sustain each recommendation or it will be revised.

Once the panel has acted on each recommendation, it will have three options: make no changes, modify the guidelines in part or replace them entirely.

The panel's final report will be published on the IDSA's website.

ADDITIONAL FINDINGS OF BLUMENTHAL'S INVESTIGATION

IDSA convened panels in 2000 and 2006 to research and publish guidelines for the diagnosis and
treatment of Lyme disease. Blumenthal's office found that the IDSA disregarded a 2000 panel member who argued that chronic and persistent Lyme disease exists. The 2000 panel pressured the panelist to conform to the group consensus and removed him as an author when he refused.

IDSA sought to portray a second set of Lyme disease guidelines issued by the American Academy of Neurology (AAN) as independently corroborating its findings. In fact, IDSA knew that the two panels shared key members, including the respective panel chairmen and were working on both sets of guidelines at the same time -- a violation of IDSA's conflicts of interest policy.

The resulting IDSA and AAN guidelines not only reached the same conclusions regarding the non-
existence of chronic Lyme disease, their reasoning at times used strikingly similar language. Both entities, for example, dubbed symptoms persisting after treatment "Post-Lyme Syndrome" and defined it the same way.

When IDSA learned of the improper links between its panel and the AAN's panel, instead of enforcing its conflict of interest policy, it aggressively sought the AAN's endorsement to "strengthen" its guidelines'impact. The AAN panel -- particularly members who also served on the IDSA panel -- worked equally hard to win AAN's backing of IDSA's conclusions.

The two entities sought to portray each other's guidelines as separate and independent when the facts call into question that contention.

The IDSA subsequently cited AAN's supposed independent corroboration of its findings as part of its attempts to defeat federal legislation to create a Lyme disease advisory committee and state legislation supporting antibiotic therapy for chronic Lyme disease.

In a step that the British Medical Journal deemed "unusual," the IDSA included in its Lyme guidelines a statement calling them "voluntary" with "the ultimate determination of their application to be made by the physician in light of each patient's individual circumstances." In fact, United Healthcare, Health Net,
Blue Cross of California, Kaiser Foundation Health Plan and other insurers have used the guidelines as justification to deny reimbursement for long-term antibiotic treatment.

Blumenthal thanked members his office who worked on the investigation: Assistant AG Thomas Ryan,
former Assistant Attorney General Steven Rutstein and Paralegal Lorraine Measer under the direction of Assistant Attorney General Michael Cole, Chief of the Attorney General's Antitrust Departmen.

APPENDIX D

Whereas the IOM urges that persons with significant conflicts of interest be excluded from guidelines development processes, we note with alarm that several individuals identified in then Attorney General Blumenthal's investigation (2006-2008) who have patents giving them a proprietary interest in the selection of testing methods for Lyme disease, stood to gain financially from the outcome of vaccine development efforts, were involved in consulting with insurance companies drafting restrictions on reimbursements to patients for treatments they and their physicians deemed appropriate and necessary and they have been involved as expert witnesses, testifying against patient plaintiffs claiming harm inflicted by insurers and practitioners. Furthermore, they have been involved as expert witnesses before medical boards seeking to sanction physicians whose practices digress from IDSA guideline-recommended practices, even though the 2006 IDSA guidelines includes a caveat that they are not mandatory. Although some of these activities are disclosed by participants in the latest IDSA Lyme guidelines development process, such disclosure in and of itself, does not assure a fair and unbiased result. Indeed, many of the participants and their institutions have clear proprietary interests in the outcome of the guidelines they are involved in crafting.

APPENDIX E

Directors, Infectious Diseases Society of America

Stephen B. Calderwood, MD Infectious Disease Associates 55 Fruit Street Boston, Massachusetts 02114-2696

Johan S. Bakken, MD St. Luke’s ID Associates 1001 East Superior Street, Suite L201 Duluth, Minnesota 55802-2207

William G. Powderly, MD Washington University School of Medicine Campus Box 8051 1 Brookings Drive St. Louis, Missouri 63130-4862
Penelope H. Dennehy, MD Hasbro Children’s Hospital/Brown University 593 Eddy Street Providence, Rhode Island 02903-4923

Cynthia L. Sears, MD Johns Hopkins University School of Medicine 600 N. Wolfe Street Sheikh Zayed Tower Baltimore, Maryland 21287-0005
Barbara E. Murray, MD University of Texas Health Science Center 6431 Fannin St, MSB 1.150 Houston, Texas 77030-1501

Judith A. Aberg, MD Icahn School of Medicine at Mount Sinai 1468 Madison Ave New York, New York 10029-6508

Barbara D. Alexander, MD, MHS Duke University Medical Center 40 Duke Medicine Circle Durham, North Carolina 27710-4000

R. Michael Buckley, MD Perelman School of Medicine 800 Spruce St Philadelphia, Pennsylvania 19107-6130

Deborah Cotton, MD, MPH Boston University School of Medicine 771 Albany St Boston, Massachusetts 02118-2525

Janet A. Englund, MD Seattle Children's Hospital MA.7.226 - Infectious Disease Clinic 4800 Sand Point Way NE Seattle, Washington 98105-3901

Thomas Fekete, MD Temple University Medical School 3401 N Broad St # 501 Philadelphia, Pennsylvania

Lawrence P. Martinelli, MD Covenant Health 4404-C 19th St. Lubbock, Texas 79407-2424
19140-5103

Louis B. Rice, MD Warren Alpert Medical School of Brown University 222 Richmond St Providence, Rhode Island

Steven K. Schmitt, MD Cleveland Clinic Main Campus Mail Code G21 9500 Euclid Avenue Cleveland, Ohio 44195-0001

Mark A. Leasure, Chief Executive Officer Infectious Diseases Society of America 1300 Wilson Blvd. Suite 300 Arlington, Virginia

APPENDIX F

Presented by The New York State Coalition on Lyme and Tick-borne Diseases.


Holly Ahern Dept. of Microbiology, SUNY Adirondack Lyme Action Network

Ira Auerbach Hudson Valley Lyme Disease Association

Jill Auerbach Hudson Valley Lyme Disease Association

Christina Fisk
Lyme Action Network

Karla Lehtonen
Lyme Alliance of the Berkshires

Ellen Lubarsky
New York City Lyme Support

David Roth
Tick-borne Disease Alliance
02903-4228

[ 03-28-2015, 08:55 AM: Message edited by: KarlaL ]

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KarlaL

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dbpei
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Karla, thank you for trying to help us all with this important task.

I have been trying to follow instructions to modify the sample letter to send my legislators - along with understandable instructions and information for them and I am finding this to be a very complex task. I would imagine it probably is difficult for most of us here.

I want to outline below what I think I am supposed to be doing and please correct me if I am wrong in any of this.

1. I am going to email my US Senator and Congressman with the sample letter provided explaining the urgency of them writing to the IDSA directors with regard to new guidelines for Lyme Disease that are about to be revised.

2. In that email, I am going to include a sample letter for my legislators to use when sending out their letters to all of the directors of the IDSA, CDC, and NIH.

3. With that email to both of my legislators, I am going to include the large pdf file created by the Empire State Lyme Disease Association explaining all of the problems with the current guidelines and bias in studies. That PDF file also includes Appendix E with contact info for all directors of IDSA.


I have some questions:

1. In that sample letter I am providing my legislators, am I also supposed to be asking them to send this large pdf file to each and every director of IDSA, CDC and NIH? This would involve a lot of paper and postage if not done via email!

2. The IDSA directors' contact info is found in Appendix E. But how is contact info of those that are supposed to be cc'd in CDC and NIH found? (It seems so unrealistic to me that they will take the time to find this information and do what we are asking...)


I am just feeling like this is so much to ask and expect the kind of response we need. If it could all be done via email, perhaps we could expect it to actually be carried out.

Maybe I am missing something or misunderstanding what we need to do. But if I am not, what can we do to make this task more achievable?

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KarlaL
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Answers

Yes your simplified outline of the directions is correct. Thank you! If you can, you should also follow-up your message with a phone call.

The New York State Coalition for Lyme and Tick-borne Diseases, of which the Empire State LDA is a member created the PDF.

1. We are asking the members of Congress to send the research citations listed in the PDF to the IDSA leadership.

2. We did not include the email addresses of the Directors of the NIH and the CDC in the letter, but again the Congressional staff who receive this are professionals and should be able to access this information.

I admit that our letter isn't perfect and could use more refining, but since time is of the essence we decided that we needed to bring this to the Lyme community while we still had time to act.

[ 03-29-2015, 06:51 AM: Message edited by: KarlaL ]

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KarlaL

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dbpei
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OK, Karla. Thanks for clarifying. I will do my best!
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KarlaL
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Dear dbpei,

I have slightly refined my answer to your previous question regarding asking members of Congress to send the entire PDF to the IDSA.

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KarlaL

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dbpei
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Karla,
At first, I thought you meant we should ask our legislators to include the entire PDF when they send their letters to IDSA. Should we NOT ask our legislators to send the PDF file with their letters to the IDSA directors?

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KarlaL
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You should ask your legislators to send the research citations contained within the PDF rather than the entire PDF.

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KarlaL

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KarlaL
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In the course of extensive conversations with one of the leading Lyme advocacy groups, the New York State Coalition was encouraged to contact legislators regarding the IDSA guidelines review as an effective method of influencing the IDSA. We have shared our letters and documentation with the Lyme community as a way of encouraging others to do the same.

I would like to encourage the Lyme advocacy groups in each state to organize their own constituency to write letters and utilize their own personal contacts with legislators as we are doing in New York. Feel free to use our materials or to write your own. It will probably be most effective to focus your efforts on members of Congress who are known to be supporters of the Lyme community such as the past and current sponsors of the House and Senate bills.

One of the problems in organizing a national campaign is the purposely short time constraints for comment that have imposed by the IDSA.

[ 03-30-2015, 09:46 AM: Message edited by: KarlaL ]

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KarlaL

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KarlaL
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If you are not able to attach the PDF to your email you can paste the link to the PDF instead: http://www.empirestatelymediseaseassociation.org/LYME-DISEASE-INFORMATION-3272015.pdf

We are working to get this up on Voter Voice to make it easier for everyone to email their Congressmen.

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KarlaL

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KarlaL
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The IDSA is revising its guidelines for Lyme disease. The panel has no Lyme patients and no physicians who treat chronic Lyme disease. Patients need a voice. Contact your Congressional representatives to ask for their intervention before more people get terribly sick. The Lyme Action Network and other Lyme disease advocates across the state have united under the banner of The New York Coalition of Lyme and Tick-borne Diseases to call for reform at the highest levels.


If you are not able to attach the PDF to your email you can paste the link to the PDF instead: http://empirestatelymediseaseassociation.org/LYME-DISEASE-INFORMATION-3272015.pdf

If you can, follow up your letters with a phone call.

KarlaL


Lyme Action Network: LYME COMMUNITY MUST UNITE TO DEMAND FAIR AND UNBIASED REVIEW OF IDSA TREATMENT GUIDELINES

http://www.lymeactionnetwork.org/index.html


The Infectious Diseases Society of America (IDSA) is beginning the process of reviewing its official treatment guidelines for Lyme disease. The IDSA guidelines currently in place, adopted by the CDC as the sole "standard of care" for Lyme disease, were founded upon limited and selected opinions, research, and preferences, failing to represent the full spectrum of research and experience in this complex field. These guidelines have been responsible for denying hundreds of thousands of people access to proper and informed diagnoses, adequate and aggressive treatment, and an opportunity for good health.

The Lyme Action Network and other Lyme disease advocates across the state have united under the banner of The New York Coalition of Lyme and Tick-borne Diseases to call for reform at the highest levels.

YOUR PARTICIPATION IS REQUESTED. PLEASE JOIN US IN A CALL FOR REFORM:

1) Please review the following sample letter and send to your elected members of Congress - Senators and Congressmen/women. Add your own comments concerning your personal situation if you wish. Be sure to include the "SAMPLE LETTER FOR CONGRESSIONAL REPRESENTATIVE TO SEND TO THE IDSA" with your letter.

2) ALSO send the "BACKGROUND" information, a report that details the history and the breadth of research that needs to be considered, so that your representative will know exactly what the issues are and what we want them to do about it. You will need to download this pdf document and attach it to your letter. http://empirestatelymediseaseassociation.org/LYME-DISEASE-INFORMATION-3272015.pdf


(When you send the letter, please remember to go through and delete the instructions that we've added in parentheses.)

Thank you for your participation in this effort.

********************************************************************************************

SAMPLE LETTER TO YOUR CONGRESSIONAL REPRESENTATIVES

(DATE)

Dear (Senator or Congressmember):

I (We) seek your intervention to ensure that the new treatment guidelines for Lyme disease, currently in the process of being drafted by the Infectious Diseases Society of America (IDSA), will reflect a complete, fair, transparent, and trustworthy process in accordance with the Institute of Medicine's "Standards for Developing Trustworthy Clinical Practice Guidelines"; be free of bias and conflicts of interest; and reflect the entire body of scientific evidence pertaining to this complex and poorly understood disease.

Historically, the IDSA treatment guidelines have been founded upon "selected" research and clinical experiences, ignoring a body of research and clinical observation that challenge the IDSA's long-held beliefs about the disease. Because the IDSA's guidelines have been the only ones endorsed by the NIH and the CDC since 2002, these limited and restrictive guidelines have resulted in the failure of patients to be informed about their treatment options; the failure of doctors to be fully informed about all professional perspectives pertaining to the the nature of the disease and the variety of treatment options; and the refusal of insurance companies to provide essential medical care to patients with persistent Lyme disease symptoms, which, in many cases, leads to long term suffering and disability.

Your intervention is critical to protect the health and well-being of your constituents.

I (We) respectfully request that you:

1. Please send a letter to the IDSA Directors reminding them that their review should be unbiased and representative of all available science (a sample letter is included below, and IDSA Directors are listed in APPENDIX E of the "BACKGROUND" document, attached).

2. Please send a copy of your letter to the CDC, so they will be aware that biased guidelines are unacceptable and could initiate further inquiry.

Background and resource information is attached in a pdf file, for your review.

Your attention to this matter is greatly appreciated.

Sincerely,
(Type your name)


(Include this next section with your letter to your representatives...)
SAMPLE LETTER FOR CONGRESSIONAL REPRESENTATIVE TO SEND TO THE IDSA:

TO: Directors of the Infectious Diseases Society of America

cc: Directors of the Center of Diseases Control
Director of the National Institutes of Health

FROM: (Senator/Congressperson)

Medical and scientific experts, patients, and advocates have requested my attention to the matter of the Treatment Guidelines for Lyme disease, now under review by the Infectious Diseases Society of America (IDSA).

Significant evidence has been offered to demonstrate that the process now underway may intend to dismiss or disregard critical scientific research, evidence, and experience that may not be in concert with the historical tenets represented by the IDSA, and that the information considered in this review may be pre-selected in order to justify and support desired outcomes.

It also appears that the IOM Standards, which call for the inclusion of all opinions and the granting of adequate hearing to all arguments by representatives of ALL key affected groups, are being disregarded. Patients with persistent symptoms following treatment, the physicians who treat them, and the researchers studying these phenomena should be fully represented on this review panel.

As the stewards of the health and welfare of our constituencies, it is our expectation that a fair, trustworthy, and unbiased review will address all scientific evidence available on this topic. We would particularly like the IDSA to respond to the research listed in the attached/additional pdf file, which includes both new and prior research that may not yet have been given adequate consideration by the IDSA.

The burgeoning threat of Lyme disease requires a responsible and complete response by those charged with the health and safety of the public.


Your attention to this matter is of utmost importance. Thank you.


*****************************************************************************************
[Don't forget to delete our instructions to you (in parentheses), and remember to attach the "BACKGROUND" material to your letter to your elected officials. Download it here: http://empirestatelymediseaseassociation.org/LYME-DISEASE-INFORMATION-3272015.pdf

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KarlaL

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KarlaL
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Good News on Letters to Congress Initiative!

Members of the New York State Coalition have received a very positive response from members of the Bipartisian Congressional Lyme Caucus and they want to help us. Please keep your letters coming. This action is not constrained by the April 9th deadline imposed by the IDSA.

We are still working on Voter Voice and it will be up soon, but if you can send your letters via email, please don’t wait for it.

Note for Residents of New York State: Due to the fact that people have not been able to attach the PDF to their emails via the official contact forms, the email addresses for Senators Schumer and Gillibrand are pasted below:

Senator@ Gillibrand.senate.gov
Senator@ Schumer.senate.gov

If you are not able to attach the PDF to your email you can paste the link to the PDF instead: http://empirestatelymediseaseassociation.org/LYME-DISEASE-INFORMATION-3272015.pdf

If you can, follow up your letters with a phone call.

--------------------
KarlaL

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KarlaL
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More good news regarding efforts to ask for Congressional Intervention in the IDSA Review Process!

The Lyme community has united with the LDA and LymeDisease.org to send letters to the US House of Representatives Lyme Disease Caucus, the US House of Representatives Energy & Commerce Committee, and the IDSA itself. Each letter requests specific actions to be taken by each recipient in regards to the IDSA Lyme guidelines development process. The letters asked the House Lyme Caucus to intervene in the IDSA Review process and the House Energy & Commerce Committee to hold a hearing.

This action complements the efforts of the New York State Coalition to send their own letter as well as to encourage constituents to write letters to their own Senators and Representatives to request intervention in the IDSA Lyme Review Process.

I spoke with Representative Chris Gibson’s office yesterday and I was told that in response to both these efforts, members of the House Bipartisian Lyme Caucus have mailed a letter with questions to the IDSA and attached both the LDA/Lymedisease.org/Community letter and the New York State Coalition letter.

The IDSA has promised to send a formal response.

The IDSA has also agreed to extend their Lyme Guidelines Process Comments until April 24th. Anyone who has not replied to the IDSA directly can go to their website and register their comments.

KarlaL

From the LDA website: Lyme Community Unites: Protect Patient Rights

For the complete article and links to the Lyme Community letters, go to:
http://lymediseaseassociation.org/index.php/lda-news-a-updates/1371-lyme-community-unites-to-protect-patient-rights

In a move designed to spotlight concerns about the Infectious Diseases Society of America (IDSA) guidelines' development process, groups in the Lyme community nationwide have come together to make their voices heard. The effort to date consists of three different letters which were signed on by multiple groups representing dozens of states across the U.S. and were then sent to the US House of Representatives Lyme Disease Caucus, the US House of Representatives Energy & Commerce Committee, and the IDSA itself, which requested input into its newly structured guidelines development process. . .

For the complete article and links to the Lyme Community letters, go to:
http://lymediseaseassociation.org/index.php/lda-news-a-updates/1371-lyme-community-unites-to-protect-patient-rights

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KarlaL

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dbpei
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This is wonderful news, Karla! Thank you!!
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DITTO
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KarlaL
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The IDSA has agreed to extend their Lyme Guidelines Process Comments until April 24th. Anyone who has not replied to the IDSA directly can go to their website and register their comments.

LymeDisease.org has also extended the deadline for their survey.

The Lyme Community has asked members of Congress to intervene in the IDSA guidelines process, including holding hearings. Please use the links above write to your Congressmen today.

--------------------
KarlaL

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KarlaL
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Letter from House Bipartisan Lyme Caucus to the IDSA

Many thanks to the members of the House Lyme Caucus, including Representatives Christopher Smith, Sean Maloney, Chris Gibson, Barbara Comstock, and Collin Peterson for representing the concerns of your constituents regarding the IDSA Lyme Disease Guidelines review process in the attached letter!

The IDSA has promised to send a formal response and has also agreed to extend their Lyme Guidelines Process Comments until April 24th. Anyone who has not replied to the IDSA directly can go to their website and register their comments.

Link to the letter:
http://www.lymediseaseassociation.org/images/NewDirectory/GuidelinesControversy/2015_LymeCaucusIDSASigned15.pdf

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KarlaL

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