BRFSS

Hi all - I have a puzzle that I'm hoping you can help with.  This is a question for other states that receive cooperative group funding for the BRFSS - Behavioral Risk Factor Surveillance System.  At least until 2016, the CDC IRB determined the BRFSS to be Human Subjects Research Exempt (from complying with the regulations at 45 CFR 46).  However, the cooperative agreement RFA for BRFSS explicitly states that the funds is not to be used for research.  Basically, BRFSS is considered research at the federal level (at least in 2016 and before) but not research at the local level.  Any clarification as to why they is the case??  Has your IRB reviewed the BRFSS and given it an IRB determination?  If yes, what was the determination made and why?

My PI/PD for the BRFSS only has official documentation from the CDC IRB as of 2016, where the continuing review for exempt studies was approved for the BRFSS.  He also has a letter from 2019 where he was informed that the exempt continuing review process at the CDC IRB changed and cooperative agreement sites would no longer be receiving a letter such as that from 2016.

Does anyone know or have documentation that the CDC IRB transitioned the BRFSS to comply with the 2018 Requirements? - and perhaps now deems the BRFSS "public health surveillance activities"?