Comment from Persistence Analytics Group LLC

Comments of Persistence Analytics Group LLC Regarding Control of Communicable Diseases; Foreign Quarantine Docket No. CDC-2026-0991 Persistence Analytics Group LLC submits these comments regarding the Centers for Disease Control and Prevention’s proposed rule on Control of Communicable Diseases; Foreign Quarantine. PAG supports a public-health framework that protects the United States from communicable-disease risk while preserving operational clarity, evidence discipline, interagency coordination, and public trust. Foreign quarantine authority should not be evaluated only as a legal power. It should be evaluated as an implementation system. The core questions are: What risk is being identified? What evidence supports action? Who verifies the risk? Who owns the decision? How are federal, state, local, port, airport, carrier, and healthcare responsibilities coordinated? What happens when information is incomplete, conflicting, or changing quickly? How is public confidence preserved while urgent action is taken? PAG recommends that CDC ensure the final rule supports five implementation principles. 1. Evidence-based triggers Quarantine, isolation, screening, reporting, or related measures should be tied to clear evidence standards. The rule should distinguish among suspected exposure, confirmed exposure, symptomatic illness, confirmed infection, and broader public-health risk. 2. Operational readiness Authority alone does not protect public health. The rule should support practical execution at airports, seaports, land crossings, transportation nodes, and healthcare interfaces. CDC should ensure that implementation expectations are clear for carriers, public-health officials, and affected individuals. 3. Interagency accountability Foreign quarantine decisions often involve CDC, DHS, CBP, TSA, state and local health departments, transportation operators, healthcare providers, and emergency-management partners. The rule should make clear how decisions are coordinated, who has authority, and how information flows during a fast-moving event. 4. Public trust and communication Compliance depends on credibility. Public-health measures should be communicated in plain language, with clear explanation of the risk, the basis for action, expected duration, available process, and responsibilities of affected parties. 5. After-action verification CDC should ensure that major uses of foreign quarantine authority can be reviewed after the fact. The relevant questions should include: Was the risk correctly identified? Was the evidence sufficient? Was action timely? Were roles clear? Were public-health outcomes improved? Were unnecessary burdens minimized? What should change before the next event? The broader principle is simple: Public-health authority is only as strong as the implementation architecture beneath it. PAG supports a final rule that strengthens CDC’s ability to respond to communicable-disease threats while ensuring that operational decisions are evidence-based, accountable, coordinated, and reviewable. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC | United Grid National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity neil@persistenceanalyticsgroup.com 609-464-9055 https://persistenceanalyticsgroup.com/ SAM.gov Registered Vendor UEI: D3VYU39H6DX9 | CAGE: 19T34 D-U-N-S: 142849930