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pre-existing public health challenges, all of which correlate with more severe COVID-19 <br />outcomes. The interim final rule also considered the disproportionate economic impacts of the <br />pandemic, citing, for example, the rate of job losses among low-income persons as compared to <br />the general population. The interim final rule then identified QCTs, a common, readily <br />accessible, and geographically granular method of identifying communities with a large <br />proportion of low-income residents, as presumed to be disproportionately impacted by the <br />pandemic. <br />In other words, the interim final rule identified disproportionately impacted populations <br />by assessing the impacts of the pandemic and finding that some populations experienced <br />meaningfully more severe impacts than the general public. Similarly, to identify <br />disproportionately impacted classes, recipients should compare the impacts experienced by that <br />class to the typical or average impacts of the pandemic in their local area, state, or nationally. <br />Recipients may identify classes of households, communities, small businesses, <br />nonprofits, or populations that have experienced a disproportionate impact based on academic <br />research or government research publications, through analysis of their own data, or through <br />analysis of other existing data sources. To augment their analysis, or when quantitative data is <br />not readily available, recipients may also consider qualitative research and sources like resident <br />interviews or feedback from relevant state and local agencies, such as public health departments <br />or social services departments. In both cases, recipients should consider the quality of the <br />research, data, and applicability of analysis to their determination. <br />In designing a program or service that responds to a disproportionately impacted class, a <br />recipient must first identify the impact and then identify an appropriate response. To assess <br />disproportionate impact, recipients should rely on data or research that measures the public <br />45 <br />