Expand Child Lead Testing

September 23, 2022. ODH draft rules undermine child lead testing.

Today, Cleveland Lead Advocates for Safe Housing has responded to a request for comments on draft regulations related to childhood lead testing from the Ohio Department of Health. Lead safety advocates around the country were excited when the CDC lowered the Blood Reference Value from 5 micrograms/deciliter down to 3.5 mg/dl. Think of the CDC Blood Reference Value as the point at which public health officials and health providers should begin treatment and pursue preventive measures with children. 

     There's just one catch to the CDC standard: the individual states (and some municipalities) need to adopt the new CDC standard. On August 24th, the Ohio Department of Health issued a draft administrative rule that is WORSE than the current rule. Instead of following CDC's guidance and lowering the threshold for action to 3.5mg/dl, the draft administrative rule ( creates a new class of children who test between 3.5mg/dl and 10 mg/dl and then the redefines "lead poisoned" from 5mg/dl up to 10mg/dl. The net effect is that more children who are identified with lead exposure will receive no on site inspections. 

Read the CLASH comments in full.

Read the #1 Request for Comments re Lead Screening and Assessment

Possible barriers to increasing the rate of child lead testing.

• Public awareness of the need for child lead testing. CLASH will be using member and foundation funding to create a public awareness campaign to reach out to at risk families.

• Access to testing. It is not clear that there is a simple, one stop testing protocol readily accessible to families living in high risk communities.. Data from the Lead Screening and Testing Commission established by the Lead Safe Certificate Program might provide some guidance on this barrier, but it is not clear whether this commission is operating.  A recent announcement suggests that MetroHealth will be providing a one stop child testing service at neighborhood locations around Cleveland. CLASH is prepared to market these services to at risk families. 

• Hesitancy by families and providers. CLASH is gathering anecdotal information on parental and provider hesitancy around child lead testing. Hypotheses range from fear of discovery, fear of the medical establishment, fear of repercussions/stigma and more. CLASH will be partnering with Thriving Earth Exchange (TEX) to analyze the scientific studies of hesitancy and to do deep canvassing among families and child and health care providers to get more information.

CLASH recommends

1. Cleveland Department of Public Health (CDPH): Offer child lead testing at J. Glen Smith and McCafferty Health Centers, using the one-stop protocol announced by MetroHealth. Seek reimbursement from Ohio Medicaid for services delivered to Medicaid eligible children and mothers.1

2. CDPH: Place the Mobile Health Lab in service as soon as possible, providing one stop, walk-in child lead testing to families at child care and educational locations around the city. 

3. CDPH: Implement and oversee the operations of the Lead Screening and Testing Commission as authorized by the Lead Safe Certificate ordinance (747-19 pages 19). The Commission should operate in compliance with Ohio Sunshine law. 

4. CDPH: implement and oversee the Lead Safe Housing Action Board created under the Lead Safe Certificate ordinance (747-19 pages 19-20). In addition to its enumerated duties, the Lead Safe Housing Action Board should identify resources for at risk families, create procedures for addressing the needs of families with an EBLL child, and oversee a rapid response by CDPH to families with an EBLL child as authorized by §240.09(d) of the codified ordinances, even before a formal referral from the Ohio Department of Health. The Commission should operate in compliance with Ohio Sunshine law. 

5. Senior Strategist on lead: Create a Lead Outreach Team to provide reliable information to families, child and education providers.about lead hazards, the importance of timely testing, and resources to support families with an EBLL child. This team may operate in support of CDPH lead testing (stationary and mobile) and follow up services; Cleveland Water Department services to child care and education providers.

6. Senior Strategist on lead: Work with MetroHealth to assure that WIC participants receive lead tests as a part of their program.

7. Senior Strategist on lead: Work with Cuyahoga County Executive to clarify, streamline, and publicize the PRC benefits for families where a child has an elevated blood lead level (EBLL). PRC funding may be used to apply interim controls to a lead poisoned home (while the family waits for a lead risk assessment) or to relocate to a lead safe home. 

8. Senior Strategist on lead: work with Cuyahoga Metropolitan Housing Authority to set aside Housing Choice Vouchers for families with an EBLL child in the household.

9. Senior Strategist on lead: work with representatives of the Cleveland Metropolitan School District (CMSD) and the CWRU School of Nursing to expand childhood lead testing of students entering pre-K and kindergarten classes in the CMSD. 

10. Senior Strategist on lead: Explore methods for billing child lead testing services to Medicaid or private insurance providers to offset the cost of child lead testing provided by the City of Cleveland. Medicaid will pay for both capillary tests (finger prick) and venous tests (blood draw) While Medicaid requires testing at age 1 and 2 or before age 6, Ohio Medicaid will reimburse additional child lead testing. Current reimbursement rates are as follows: Blood draw (venipuncture) $2.25; Finger prick (capillary draw) –$3.63; Lead test* – $9.08 *Clinical lab rates are set at 75% of the Medicare Clinical Lab Fee Schedule.