BCHC submits comments to CDC on DoxyPEP guidelines

November 2023

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BCHC issued comments to CDC’s Division of STD Prevention on the proposed guidelines for the use of Doxycycline Post-Exposure Prophylaxis for bacterial sexually transmitted infection (STI) prevention.

We strongly support these guidelines to offer doxycycline as sexually transmitted infection post-exposure prophylaxis (DoxyPEP), which will establish a public health intervention that will bring the nation’s STI rates down and empower individuals to take charge of their health in a new and meaningful way.

We are particularly supportive of the following:

  • The strength of recommendation and quality of evidence designation.
  • The three criteria for the intervention: (1) taken within 72 hours of oral, vaginal, or anal sex; (2) for gay, bisexual, and other men who have sex with men, and for transgender women; (3) who have a history of at least one bacterial STI in the last 12 months.
  • The specification of STI screening at anatomic sites of exposure.
  • STI screening every 3-6 months (with clarifications requested below).
  • Routine counseling on HIV preexposure prophylaxis (PrEP) for individuals not living with HIV who are not receiving HIV PrEP (with strengthened language requested below).
  • The inclusion of transgender women in the recommendation.
  • The inclusion of language instructing providers to “provide enough doses of doxy until next follow-up visit, based on individual assessment through shared decision making”.

Specific recommendations include:

  • Include additional clarity and specificity for providers;
  • Add data on race, ethnicity, gender identity, and gender of sex partners and STIs to the section on who would benefit the most from DoxyPEP;
  • Given that DoxyPEP is a new sexual health intervention for a population often burdened by discrimination and stigma, a thoughtful implementation is critical. Unfortunately, the guidelines provide no insight into the CDC’s implementation plan. The guidelines mention that “additional information about implementation and considerations for monitoring for antimicrobial resistance will be described in a separate document”, which will not be published until after the comment period closes (pg 2). In the future, we recommend that CDC publishes any supplementary materials mentioned in the guidelines for public comment simultaneously;
  • Center equity from the start, do not wait for inequities to arise before addressing them;
  • Apply lessons learned from the implementation of HIV PrEP;
  • Apply lessons learned from the 2022 mpox outbreak;
  • Integrate DoxyPEP into existing CDC initiatives and grants, beyond solely STI prevention;
  • Support workflow integration and provide education for health departments, providers, and pharmacies;
  • Monitor concerns about microbiome and antimicrobial resistance;
  • Be prepared to update the guidelines quickly if/when evidence demonstrates that this intervention is effective in cisgender women, cisgender heterosexual men, transgender men, other queer and nonbinary individuals.

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