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March 26, 2021 (HeartlandDailyNews) — The nation reached a significant milestone in late February, with media outlets reporting that the number of Americans who have died from COVID-19 passed the 500,000 mark.

Such a death toll is deeply disturbing.  But is it accurate?

recent study in the journal Science, Public Health Policy, and the Law published by the Institute for Pure and Applied Knowledge/Public Health Initiative raises intriguing questions.  The study, “COVID-19 Data Collection, Comorbidity & the Law,” concludes that the Centers for Disease Control and Prevention (CDC) unilaterally altered the 17-year-old process by which it calculated disease-caused fatalities, creating a special procedure for tabulating COVID-19 deaths.  This, the study says, enabled the CDC to produce inaccurate data which were widely disseminated by the media and served to justify a host of coercive measures to stem the spread of the disease.

“As a result of these changes, we allege the CDC compromised the quality, objectivity, and integrity of all COVID-19 data collected to date,” the authors write.

Puzzled by the CDC’s actions, the study’s authors ask three questions:

  • “Why would the CDC decide against the use of a system of data collection & reporting it authored, and which has been in use nationwide for 17 years without incident, in favor of an untested & unproven system exclusively for COVID-19 without discussion and peer-review?
  • “Did the CDC’s decision to abandon a known and proven system also breach several federal laws that ensure data accuracy and integrity?
  • “Did the CDC knowingly alter rules for reporting the cause of death in the presence of comorbidity exclusively for COVID-19? If so, why?”

The 25-page peer-reviewed study claims the CDC willfully violated several federal statutes, including the Data Quality Act, Paperwork Reduction Act, and the Administrative Procedures Act.

“Capricious Alteration to Data Collection”

“The CDC published guidelines on March 24, 2020, that substantially altered how death is recorded exclusively for COVID-19,” the study notes.  “This change was enacted apparently without public opportunity for comment or peer-review.  As a result, a capricious alteration to data collection has compromised the accuracy, quality, objectivity, utility, and integrity of their published data, leading to a significant increase in COVID-19 fatalities.”

Specifically, in a March 24, 2020 NVSS COVID-19 Alert, the CDC instructed coroners, medical examiners, and physicians to de-emphasize underlying causes of death, also referred to as preexisting conditions or comorbidities, by recording them in Part II rather than Part I of death certificates, the study explains.

“It’s worth noting that Part I of a death certificate is the immediate cause of death listed in sequential order from the official cause on line item (a) to the underlying causes that contributed to death in descending order of importance on line item (d), while Part II is/are the significant conditions NOT relating to the underlying cause(s) in Part I,” the study points out.

CDC’s action constituted a major rule change on reporting deaths from the agency’s 2003 Coroners’ Handbook on Death Registration and Fetal Death Reporting and Physicians’ Handbook on Medical Certification of Death, which had instructed medical professionals nationwide to list underlying conditions of death in Part I for the previous 17 years.

By law, the study notes, the CDC was required to submit such a change as a proposal to the Federal Register for public comment, which the CDC failed to do.

Moreover, on April 14, 2020, the CDC adopted a position paper that, according to the study, “dramatically altered what defines a new case exclusively for COVID-19.” The paper was authored by the Council of State and Tribal Epidemiologists (CSTE), a 501 (c)(6) non-profit organization, with the assistance of four CDC-employed subject matter experts and sanctioned by CDC Director Dr. Robert R. Redfield.  Not only does this appear to be a potential conflict of interest, the study points out, it also bypasses the Office of Management and Budget (OMB) oversight responsibilities under the Information Quality Act and Paperwork Reduction Act.  The arrangement between CDC and CSTE also contains ex parte communication which the study says are “in general violation of ethical standards.”

Published Data and Public Policy

Aside from the legal issues involved, the study suggests that the CDC’s manipulation of statistics resulted in significant inflation of reported COVID-19 fatalities, as well as the imposition of economically destructive public policies.

“As a result of state policies based on potentially compromised data published and promoted by the CDC, Americans have lost jobs and businesses in historically unprecedented numbers,” the authors conclude. “Federal agencies have the legal obligation to provide the most accurate data to the public, fellow agencies, and policymakers they are advising, and they have a responsibility to abide by every federal law … It is concerning that the CDC may have willfully failed to collect, analyze, and publish accurate data used by elected officials to develop public health policy for a nation in crisis.”

The CDC’s actions “resulted in a 1,600% inflation of current COVID-19 fatality totals,” according to an analysis of the study by the watchdog group All Concerned Citizens, which was provided to National File.

“If this analysis is correct, the CDC is guilty of gross malfeasance causing devastating losses to millions, in violation of settled federal law,” said Jane Orient, M.D, executive director of the American Association of Surgeons and Physicians and policy advisor to The Heartland Institute, which co-publishes Health Care News. “How can they be held accountable?  What kind of relief is obtainable?”

“When I conduct statistical analysis and develop models, it is of utmost importance to have the most accurate data possible,” said Kevin Dayaratna, principal statistician, data scientist, and research fellow at the Heritage Foundation’s Institute for Economic Freedom. “Regarding this pandemic, I’ve gone by the data that are available.  Incomplete data, however, can lead to incorrect statements and inferences; for example, as we noted in a recent study, case-fatality rates may be much lower than we actually observe due to incomplete COVID-19 data.”

Bonner R. Cohen, Ph.D., ([email protected]is a senior fellow at the National Center for Public Policy Research.

Internet Info:

Henry Ealy,, “COVID-19 Data Collection, Comorbidity & Federal Law:  A historical Retrospective, Science, Public Health Policy and The Law, October 12, 2020:


Published with permission from the Heartland Daily News. Article originally published on March 11.



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