BPC's Response to NTIA Initiative to Protect Youth Mental Health, Safety and Privacy Online

VIA ELECTRONIC SUBMISSION

November 16, 2023

The Honorable Gina Raimondo
Secretary
U.S. Department of Commerce
1401 Constitution Ave NW
Washington, DC 20230

RE: NTIA–2023–0008 “Initiative to Protect Youth Mental Health, Safety & Privacy Online”

Dear Secretary Raimondo:

The Bipartisan Policy Center (BPC) appreciates the opportunity to address the “Initiative to Protect Youth Mental Health, Safety & Privacy,” in response to the request for comment from the National Telecommunications and Information Administration (NTIA) within the United States Department of Commerce.

BPC is a nonprofit organization founded in 2007 to combine the best of ideas from both parties to promote health, security, and opportunity for all Americans. Through our recommendations, BPC’s Health Program strives to develop bipartisan policies across a variety of health issues that improve the nation’s health outcomes, reduce rising health care costs, improve equity in health services, and make quality health care available, affordable, and accessible for all. Amid growing concerns about the deteriorating mental health and substance use among children, BPC will launch a Youth Mental Health and Substance Use Task Force in January 2024.

This task force will spearhead the development of a national strategy to combat the current youth mental health and substance use crisis, offering recommendations around safe and secure social media use.

BPC applauds the NTIA for its efforts to prevent and mitigate adverse health effects stemming from use of online platforms by minors while preserving benefits such platforms have on minors’ health and wellbeing. The creation of the U.S. Task Force on Kids Online Health and Safety signifies a pivotal moment as the administration takes strides to develop a national approach for ensuring the online safety of children.

Our comments reflect BPC’s extensive work in behavioral health and technology policy. Our work has focused on enhancing the capacity of primary care providers to deliver behavioral health services (including in rural communities), to address the opioid crisis, promoting new types of behavioral health professionals, and building a comprehensive crisis response system. Additionally, BPC submitted an Amicus brief to the Supreme Court regarding Section 230 reform.

BPC’s key recommendations for developing federal guidance around social media use for youth include:

• establishing training courses for clinicians to detect behavioral health conditions linked with social media use;
• ensuring data from both technology companies and the federal government are publicly available and reported frequently; and,
• creating federal governance structures to oversee regulations within the technology industry.

Below, you will find BPC’s responses to Question #16 Parts A-E, which pertain to developing federal guidance. As NTIA and other members of the U.S. Task Force on Kids Online Health and Safety consider the feasibility of a national approach over a state-by-state one, BPC welcomes the opportunity to provide comments to improve provider training, data transparency, and governance.

Please do not hesitate to contact Gabriel Loud ([email protected]) to connect with BPC’s Health Program and Technology Program staff.

Sincerely,

 

Marilyn Serafini, Executive Director
Julia Harris, Associate Director
Michele Gilbert, Senior Policy Analyst
Danielle Draper, Project Manager
Hanna Vohra, Policy Analyst