The Cost-Effectiveness of CDC Form 75.37 Notice to Owners and Importers of Dogs Open Access

Zaganjor, Ibrahim (2014)

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To prevent the risk of rabies infection, the United States federal government regulates that all importers of dogs from rabies-enzootic countries provide a rabies vaccination certificate upon entry into the country. Owners and importers of dogs that have not been adequately immunized are issued a signed confinement agreement, which mandates that the animal be confined and vaccinated according to federal regulations (42 CFR 71.51). These regulations were developed in the 1950s: the goal of this evaluation is to determine if the form is a cost-effective method of preventing the importation of rabid or unvaccinated dogs given the high rates of travel and trade in today's society. The operational costs of the program were compared to the number of canine rabies cases potentially prevented by the 2,130 forms issued during the 2012 calendar year. It was estimated that federal government spent approximately $1,050,000 to prevent less than one case of rabies that year (0.039 - 0.622 cases). Information gathered from state and local partners highlighted that there are also many issues associated with the form affecting its function, such as a lack of clear duties for state and local offices and ill-defined consequences for noncompliant importers. Findings from this study suggest that the federal government should eliminate the dog confinement agreement process and develop a more stringent dog importation policy that will be a better use of resources and directly prevent the importation of rabid and unvaccinated dogs.

Table of Contents

Table of Contents

I. Chapter 1 - Introduction 1

1.1 U.S. Quarantine History & CDC/DGMQ/QBHSB Background 1

1.2 Rabies Virus 3

1.3 Rabies Treatment - Post-Exposure Prophylaxis (PEP) 4

1.4 Federal Regulations (42 CFR 71.51) and Confinement Agreements 5

1.5 Quarantine Activity Reporting System (QARS) 6

1.6 "Rabies-Free" List 7

1.7 Rabid Dog Importation Cases in the United States (2003-Present) 7

1.8 Project Purpose, Aims, and Significance 8

II. Chapter 2 - Literature Review 11

2.1 Current United States Dog Importation Trends and Issues 11

2.2 Current Status of Rabies among Domestic Dogs 12

2.3 Imported Canine Rabies Cases- United States 16

2.4 Costs of Rabies Exposure 18

2.5 Trends in Rabies Post-Exposure Prophylaxis 19

III. Chapter 3 - Methods 21

3.1 Number of Cases of Imported Canine Rabies Potentially Prevented 21

3.2 Costs of CDC Form 75.37 23

3.3 State and Local Health Department Evaluation Survey 26

IV. Chapter 4 - Results 27

4.1 Number of Cases of Imported Canine Rabies Potentially Prevented 27

4.2 Costs Associated with CDC From 75.37 30

4.3 Cost-Effectiveness of CDC Form 75.37 31

4.4 State and Local Health Department Evaluation Survey 31

V. Chapter 5 - Discussion and Public Health Recommendations 34

5.1 Discussion 34

5.2 Study Limitations 36

5.3 Public Health Recommendations 37

VI. References 39

VII. Appendices 43

A. Standard Operating Procedures, Dog and Cat Importation 43

B. Confinement Agreement Form 44

C. Rabies-Free List 45

D. State and Local Partner Survey Instrument 46

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