HHS Request for Information

JUN 7, 2021 — 

Please see below my submission to HHS Request for Information: (Deadline June 11th)

How to submit a comment:

June 6, 2021

Developing the National Public Health Strategy for the Prevention and Control of Vector-Borne Diseases in Humans

It was once believed that rifampin was curative in treating Brucellosis but when symptoms returned doxycycline was added to the mix and when that too failed a third antibiotic, streptomycin was added to the current treatment regimen. [1] [2]

In 1985 the worldwide incidence of leprosy was 6,000,000. In 2018, it was 208,619. The only thing that changed was the addition of rifampin to dapsone in the treatment of the disease. Rifampin was added to dapsone because the M leprae were becoming resistant and it was a new antibiotic at that time.

Treatments for multidrug-resistant tuberculosis have been introduced (bedaquiline and delamanid) with more in the pipeline. [3]

A new treatment for recurrent Clostridium difficile was recently studied (bezlotoxumab) for reducing the risk of a repeat infection. [4]

In contrast, oral amoxicillin or doxycycline remains the treatment of choice for treating Lyme disease for over thirty years regardless if debilitating symptoms return. Since 1977 Dr. Allen Steere knew that these antibiotics were not effective for all patients [5] but there has been no change in treatment or research to find more effective ways to eradicate the infection in all stages of disease.

To my knowledge, a “Federal Working Group” was never established for brucellosis, leprosy, tuberculosis or C. difficile but then again there was no rush to create a vaccine as there was with Lyme disease. It would appear that a chronic relapsing seronegative disease did not fit the vaccine model.

All patients in the 2018 Middelveen et al pilot study were culture positive for infection (genital secretions, skin and blood) even after multiple years on antibiotics so there was no relief from current antimicrobials. Some of these patients had taken as many as eleven different types of antibiotics. [6]

Here’s what researchers at Johns Hopkins and Northeastern are saying: [7]

“Under experimental stress conditions such as starvation or antibiotic exposure, Borrelia burgdorferi can develop round body forms, which are a type of persister bacteria that appear resistant in vitro to customary first-line antibiotics for Lyme disease.”

Dr. Brian Fallon of Columbia University recently published his findings of autopsy specimens from a patient previously treated for Lyme disease. Persistent infection with the Lyme disease spirochete was identified in the brain of the Lyme patient who died with a diagnosis of Lewy body dementia. [8]

Any published evidence identifying persistent infection after extensive antibiotic treatment has been completely ignored. Please see my letter to the editor of the BMJ published June 2020 for examples. [9] The research to find a cure for this antibiotic resistant/tolerant superbug has been denied for decades as the co-chair of the Tick-Borne Disease Working Group, Dr David Walker calls persistent infection after extensive antibiotic treatment a “religious belief” [10] This partnership to deny chronic Lyme disease has left hundreds of thousands if not millions around the globe in a debilitated state.

For three decades now patient testimony all across America (and around the globe) has been describing a disease that is destroying lives, ending careers while leaving its victim in financial ruin.

Priority # 1 for Lyme disease:

Establish a Manhattan Project to Find a Cure for this antibiotic resistant/tolerant superbug and elevate Lyme to Highest Alert at the CDC while recognizing the disabling stage of Lyme disease.

Respectfully submitted,

Carl Tuttle
Hudson, NH

Member of Governor Chris Sununu’s Lyme Disease Study Commission

Cc: All members of the New Hampshire Lyme Disease Study Commission


[1] Chronic Brucellosis and Persistence of Brucella melitensis DNA

[2] Administration of a triple versus a standard double antimicrobial regimen for human brucellosis more efficiently eliminates bacterial DNA load.

[3] Global Introduction of New Multidrug-Resistant Tuberculosis Drugs—Balancing Regulation with Urgent Patient Needs

[4] New C.diff treatment reduces recurrent infections by 40%

[5] Lyme arthritis: an epidemic of oligoarticular arthritis in children and adults in three connecticut communities. 1977


“The best treatment for this illness is not clear. Some physicians have reported that penicillin or tetracycline results in disappearance of the skin lesion (41,42), but others find antibiotics ineffective. Four of the patients with expanding skin lesions received penicillin but still developed arthritis.” 

[6] Persistent Borrelia Infection in Patients with Ongoing Symptoms of Lyme Disease

[7] A Drug Combination Screen Identifies Drugs Active against Amoxicillin-Induced Round Bodies of In Vitro Borrelia burgdorferi Persisters from an FDA Drug Library

[8] Detecting Borrelia Spirochetes: A Case Study With Validation Among Autopsy Specimens

[9] Lyme borreliosis: diagnosis and management

[10] Public comment: Does that sound like a religious belief, Dr. Walker?

Request for Information (RFI): Developing the National Public Health Strategy for the Prevention and Control of Vector-Borne Diseases in Humans
The development of a national strategy on vector-borne diseases including tickborne diseases was…
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