Ethical Considerations for Public-Private Partnerships

CDC works with the private sector because public-private partnerships advance CDC’s mission of protecting Americans. Public-private partnerships allow CDC to do more, faster. For more than a half century, CDC has been a leader in scientific research committed to protect the American people and keep Americans healthy, safe and secure. Our highest priority is to save lives and protect the American people. Americans—and CDC—can accomplish more working together than separately.

The agency’s pledge to the American people includes being a diligent steward of the funds entrusted to it. Before accepting outside donations, we take a hard, close look to ensure that proper policies and guidelines are followed. Public-private partnerships help federal agencies do more with less, build on the capabilities of others, leverage collective action, improve performance, and realize cost savings.

We continually work to protect our scientific and programmatic integrity, maintain accountability, and find solutions to our nation’s most pressing problems. We recognize the value of open discussion and stay committed to improving our processes of ethical protections. CDC’s highest priority is to keep people safe. We leverage our medical and scientific expertise and our partnerships to diffuse health threats and make our country and our world a better place to live.

CDC’s conflict of interest review process:

CDC ensures that, when we engage with the private sector, we are good stewards of the funds entrusted to us and maintain our scientific integrity by participating in a conflict of interest review process that is rigorous and transparent. CDC’s gift acceptance policy requires a review for conflicts of interest (COI) prior to accepting a gift.This includes gifts from the CDC Foundation (CDCF) and gifts given directly to CDC, whether they are monetary or non-monetary.  On May 1, 2014, CDC implemented an updated process for reviewing possible COI of gifts via CDCF and documenting COI review results of each CDCF gift. In April 2015, CDC extended the process to include the review of all monetary gifts to CDC. In 2016, this process was strengthened and institutionalized in the most recent revision of the CDC’s gift policy.

Steps:

The conflict of interest review process begins when a potential donor notifies CDC of their interest in giving a gift. The CDC principal investigator completes documentation on the potential donor for each donor proposing a gift. Documentation is required for every gift even when a donor has previously been found to have no conflict associated with a different project. In other words the review is case by case – no donor can be found to be “grandfathered” in as a donor with no conflicts.

Determination of when a conflict of interest exists is the responsibility of the CDC COI Review Panel.

The panel consists of members from:

• CDC Washington — Governmental affairs
• Office of the Director/Office of the Chief of Staff — Leadership
• Office of Financial Resources (OFR) — Financial interests
• Office of the General Counsel (OGC) — Legal
• Public Health Ethics — Ethics related to public health policies and actions

In evaluating whether to accept a gift from a donor, CDC must perform a balancing test to determine whether the benefits outweigh the risk that accepting the gift would reflect unfavorably upon CDC. For example, the gift should not be accepted if any employee’s ability to carry out his or her responsibilities or official duties in a fair and objective manner is influenced; if acceptance of the gift could compromise the integrity of a government program or any official involved in that program; or if the donor has an expectation of receiving a future benefit such as a contract award.

Background:

In April 2015, CDC’s Advisory Committee to the Director (ACD) agreed to establish a workgroup of external advisors to review current practices in other organizations as well as CDC’s policies and procedures, and provide recommendations to the ACD to further improve CDC’s conflict of interest policies and procedures.

In the spring of 2016, CDC’s ACD made seven recommendations for ethical considerations with CDC’s public-private partnerships. These recommendations are focused on how CDC engages the private sector and reaffirm CDC’s commitment to the American people.

In December 2016, the most recent version of the CDC’s gift policy was published. This version of the gift policy incorporates the recommendations from the ACD, clarifies roles of CDC staff, and cements the agency’s conflict of interest review process.