Corruption and the COVID-19 Vaccine: The Looming Problem of Distribution

From the earliest days of the COVID-19 pandemic, activists and analysts have called attention to the significant corruption risks associated with the response to both the public health crisis itself and the economic disruption it has caused. Anticorruption advocates have highlighted, for example, the corruption risks associated with the distribution of relief funds and personal protective equipment, and have emphasized the need for reforms like enhancing transparency, requiring audits, and ensuring protections for whistleblowers. (For samples of the discussion of the need for anticorruption measures in coronavirus response, see here, here, here, and here.) Yet there has been surprisingly little sustained discussion or planning concerning a specific issue which, while still prospective, is of pressing global importance: the inevitable corruption risks that will be associated with the distribution of a COVID-19 vaccine, if and when such a vaccine becomes available.

This is not to say that there has been no exploration of the subject. Commentators have discussed the difficulties of ensuring that a vaccine is distributed equitably, as opposed to simply being given to the most affluent, and have called attention to the problems of black markets and price gouging that are likely to emerge once vaccines are available. There has also been some general, abstract discussion of the fact that the distribution of a COVID-19 vaccine, once one exists, has significant potential for both grand and petty corruption. Absent from the discussion, though, has been the development of concrete plans for incorporating anticorruption measures in vaccine distribution—plans that take into account the inherent logistical challenges. The World Health Organization (WHO), to its credit, has released a seventeen-page plan for fair allocation of a COVID vaccine, which discusses detailed measures to ensure that vaccines are distributed fairly. However, the WHO plan devotes little more than a page to promises of “strong accountability mechanisms” in the governing bodies to “ensure protection against undue influence.” The WHO does note that the primary role of its own Independent Allocation Validation Group is to ensure that proposals from the vaccine Allocation Taskforce remain “transparent and free from conflicts of interest,” but while this sort of internal monitoring is laudable, the WHO plan conspicuously lacks any further guidance or recommendations on appropriate anticorruption measures once the vaccines are handed over to their allocated countries.

Although the timeline for a vaccine remains uncertain—and there’s no guarantee that a vaccine will be available any time soon—it would make sense for both international organizations and national governments to identify the most likely corruption risks associated with vaccine distribution and to begin developing safeguards to mitigate those risks. While there are many possible corruption risks associated with vaccine distribution, the two most significant are diversion of vaccines and extortion. Let’s examine each in turn:

  • Diversion of vaccines: Once a vaccine becomes available, the highest priority for governments will be vaccinating front-line health care providers and the most vulnerable populations, such as the elderly and those with pre-existing conditions associated with greater risk of severe illness. But demand will likely outstrip supply, and it’s easy to imagine that politicians, government officials, or others with influence over vaccine distribution might divert vaccines to friends and family, or to those with strong political connections or the ability to pay or offer favors in exchange for early access. It’s also possible that corrupt officials could misappropriate and sell vaccines on the black market. While we of course do not yet have a COVID-19 vaccine, there’s empirical evidence from other contexts that corrupt diversion of vaccines is indeed a genuine problem. For example, a 2007 study in the Philippines found evidence that rates of local corruption were negatively correlated with vaccination rates among the most disadvantaged households, a finding that suggests that corrupt officials gave the wealthy preferential access to scarce vaccines. According to the study, “the odds of completing vaccination [in an individual] can decrease 4.2 times as a result of a one standard deviation increase in corruption.”
  • Extortion: The high demand for a COVID-19 vaccine also creates the opportunity for those who have the power to control access to the vaccine to use this power as leverage to extort favors from those who need it. Again, while we do not have direct evidence regarding this sort of corruption with respect to the as-yet-nonexistent COVID-19 vaccine, research on other vaccines suggests that this sort of extortion may be a substantial problem. For example, a 2005 study on tetanus vaccinations near Lagos, Nigeria found that health care workers extorted bribes from mothers in exchange for vaccinations for their children. Distribution of a COVID-19 vaccine would likely offer similar opportunities.

Fortunately, there are a number of familiar steps that might be taken to reduce the risks and effects of corruption in the COVID-19 vaccine distribution process. The United Nations Development Programme (UNDP) authored a report in 2011 describing tools and best practices to combat corruption in health, including specific recommendations for distributing drugs and equipment supplies. These practices include, among others, tracking shipments in real time throughout the distribution process, creating electronic systems to monitor transport vehicles and inventory, mandating separation of workforce functions, and creating health boards charged with distribution and monitoring of stocks at the facility level. The WHO would do well to commit to implementing some, if not all, of these recommendations.

 The UNDP report also recommends coordinating with non-governmental organizations (NGOs) in monitoring drug delivery systems. This suggestion is well-founded. NGOs have long been involved in vaccine distribution and the anticorruption measures that come with the territory. Perhaps most prominently, the Gates Foundation is quite practiced in monitoring what happens to vaccines after they are delivered. “If you get corruption, your measurement system is going to show that,” Gates said in a 2014 interview. “If we pay for health improvement, we can see that that the vaccines got delivered, we can measure the coverage. In fact, there are a few diseases like measles that, if you’re not getting your vaccine coverage, you’ll see measles deaths go up.” COVID-19, with its high infection rate and rapidly developing symptoms, could be just such a disease. The Gates Foundation developed its efforts in this area in years since: as recently as October 2019, the Foundation partnered with Global Integrity to create anticorruption solutions in service-delivery sectors. The WHO’s plan already shows they are open to working with NGOs on vaccine production and distribution. Why not anticorruption monitoring as well?

While no step is likely to be 100% effective, even incremental safeguards could save money, time, and lives. These goals are achievable, should the preparation be put into them. But those plans have to be developed now, rather than once a corruption crisis is already in full swing.

10 thoughts on “Corruption and the COVID-19 Vaccine: The Looming Problem of Distribution

  1. It’s incredibly important to think about consequences from COVID vaccine distribution. Something that I worry about is the accountability of NGOs themselves. Though the Gates Foundation can afford comprehensive tracking and has a measure of legitimacy, there are literally thousands of other organizations in the field with less public scrutiny or transparency regarding funding, actions, personnel. Some important questions to consider in ensuring that unmanaged NGOs do not themselves contribute to corruption issues: (1) How will NGOs be selected? (2) How will these NGOs be monitored? (3) What corrective measures might countries or global organizations have to take?

    • Accountability within NGOs could be an entire post on its own; indeed, Roger Henke had an excellent 3-part series on this blog discussing the topic, where he advocated for collective action between NGOs and the grantmakers funding them in order to hold each other accountable (I’ve put a link to Part 3 of this series at the bottom of this comment).

      Without diving into the question of how the NGOs would be selected in the first place, I would advocate for a similar solution. Ensuring the involvement of multiple NGOs (and those who fund them) would create a network of overlapping oversight. The biggest acknowledged weakness in Mr. Henke’s argument is the lack of a coordinating force to “align[] the diverse requirements regarding reporting, auditing, etc. of all the headquarters” of the various NGOs and grantmakers. In this unique situation, this is perhaps a role that the WHO can step into. The WHO could take charge of facilitating communication between these entities for the duration of the distribution process, thus allowing NGOs and grantmakers which are above board to hold accountable those which are not.

      * * *
      Link to Part 3 of Roger Henke’s discussion of this topic: https://globalanticorruptionblog.com/2016/06/16/guest-post-corruption-among-development-ngos-part-3-the-need-for-collective-action-by-funding-agencies/

      • Zach, thanks so much for the thoughtful and timely post! I agree that both coordination among NGOs and leadership by the WHO is essential in this endeavor. That said, if the United States withdraws/pulls funding, I fear that a resource-strapped WHO may have significant challenges distributing the vaccine but also ensuring safeguards against the corruption risks you identified. Hopefully this future won’t play out!

  2. Great post, and I wholeheartedly share your view that the time to plan for this is now, rather than once a vaccine is approved and everyone is in a mad scramble to acquire and distribute it.

    One thing I wanted to ask by way of follow-up: Could the systems already in place (such as they are) to address corruption and related risk for distribution of personal protective equipment and economically relief funds be adapted/extended to vaccine distribution, or do you think that vaccine distribution poses sufficiently different risks and problems that a substantially different approach to oversight is warranted? if the latter, could you elaborate a bit on they key differences?

    • I think that existing systems could certainly be extended, especially at the national level; there’s no reason to reinvent the wheel if countries have existing anticorruption measures in place. The distinction (to my admittedly incomplete understanding) is that right now each country is able to acquire (to varying degrees) PPE/relief funds and distribute them internally (whether manufactured domestically or imported from elsewhere). Because there are multiple places that PPE and relief funds can be obtained from, anticorruption can largely take place on a country-by-country basis. The situation changes when a vaccine first becomes available because (presumably) there will be only a key handful (or even just one) source for the vaccine, thus making corruption impacting that supply chain an issue with far more global impact. I believe this warrants anticorruption measures coordinated on a larger scale, in addition to those already existing domestically.

  3. This is a great and timely post Zach! I am curious about your thoughts on to what extent should the private sector have a role in helping distribution, in addition to governments and NGOs. The example I have in mind is Project Last Mile where NGOs like the Gates Foundation partner up with CoCa Cola to take advantage of Coca Cola’s extensive supply chain network and cold-maintenance technology to deliver vaccines into the most remote part of Africa, locations that would be incredibly expensive for governments or NGOs to access and transport on their own. Do you think partnering with the private sector will make it harder to keep a measurement system and will lead to more openings for corruption?

  4. Thinking about the consequences associated with the distribution of the COVID vaccine is very important seeing as though we are nearing its availability. There should be no surprise that there is an anticipation of corruption risks associated with the distribution of this vaccine when there has been corruption surrounding the whole pandemic. I agree that there has been an emphasis for the need for reform like, “enhancing transparency, requiring audits, and ensuring protections for whistleblowers,” but, I think there also needs to be reform in policy. For example, as Trump publicly downplayed the severity of the pandemic, several of his ambassadors shed their assets.“ (see https://www.cnbc.com/2020/07/02/coronavirus-update-trump-ambassadors-sold-stocks-as-president-downplayed-pandemic.html) Some of the ambassadors’ stock transactions were for companies involved with research or developing products that are linked to treating patients that have contracted the coronavirus, such as biopharmaceutical firms.”(see last link). While there was a lack of response from the White House, the ambassadors were witnessing large gains from their corrupt stock transactions. “The president’s aides appeared to be giving wealthy party donors an early warning of a potentially impactful contagion at a time when Mr. Trump was publicly insisting that the threat was nonexistent.” (see https://www.nytimes.com/2020/10/14/us/politics/stock-market-coronavirus-trump.html). Abuse of power has been extremely visible during these times and not much has been done about it due to the way our policies are written.

    I think it’s ridiculous that policies are so loosely written that Trump has yet to get into serious trouble for participating in self-dealing as it pertains to the promotion of specific COVID-19 tests and treatments. Trump’s Administration selected a firm called Oscar Health to develop a website to facilitate coronavirus testing, which happened to be a company founded by Jared Kushner’s brother and formally partially owned by Jared Kushner himself.(see https://globalanticorruptionblog.com/profiting-from-the-presidency-tracking-corruption-and-conflicts-in-the-trump-administration/). For many weeks he insistently promoted hydroxychloroquine as a COVID-19 treatment when it is produced by a French pharmaceutical company that three of his family trusts have investments in, “major Republican donor Ken Fisher owns a majority stake, and Commerce Secretary Wilbur Ross used to run a fund that invested in,” the same company. (see last link). “Rick Bright, the former head of the U.S. Government’s Biomedical Advanced Research and Development Agency, filed a whistleblower complaint alleging that he was pressured to give government contracts to political cronies, including to Aeolus Pharmaceuticals, a pharmaceutical company that produced hydroxychloroquine, because the company’s CEO was friends with President Trump’s son-in-law Jared Kushner.” (see last link). It is clear that the Trump administration and his associates will stop at very little to make sure they advance their interests. The irony is that the Trump Administration stated that the U.S. will not, participate in a global push to develop a COVID-19 vaccine, in part because the effort is led by the World Health Organization, which the White House describes as “corrupt” and has accused of initially aiding China in covering up the scope of the pandemic.” (see https://www.npr.org/sections/coronavirus-live-updates/2020/09/02/908711419/u-s-wont-join-who-led-coronavirus-vaccine-effort-white-house-says). The U.S. is ultimately refusing to join in discussions with more than 170 countries to work towards a vaccine that will provide equitable access to safe and effective vaccines. This is a red flag and seems like another path of corruption. The prominence of corruption as it deals with public health and the nature of this pandemic is grotesque but virtually unsurprising due to the history of corruption within this Administration let alone the country.

    I agree with your thinking that the time is now for both international organizations and national governments to identify the potential risks for corruption associated with vaccine distribution. It’s evident that certain groups will be given preferential treatment and others will find getting the vaccine extremely challenging. These are the basic principles of classism/ class discrimination that seem to be fundamental practices in our country. There have been recent reports of distribution of an experimental Coronavirus vaccine in Yiwu, China. (see https://www.transparency.org.uk/coronavirus-covid-vaccine-distribution-corruption-risk-china). It has been reported that people have flown over two hours across the county to be vaccinated which suggests that the demand is high. The desperation and willingness to pay for “immunity” raises concerns. “Not only does it raise questions about equity in terms of who can pay, but it also opens the door to corruption in the unprecedented rush to create and deliver a vaccine.” (see last link). Corruption affects access to healthcare by way of informal payments or bribes, favoritism and manipulation of data, theft and embezzlement, etc. (see last link). “Corruption is an insidious, obstacle to the most disadvantaged population groups preventing them from accessing the healthcare they urgently need.” (see last link). Before looking at how we can combat corruption when it comes to the distribution of the vaccine, we need to make sure there is no corruption associated with the production of the vaccine. It’s no secret that production of the vaccine has been a tool used by the Trump Administration to gain a second term in the White House. A rushed vaccine can also be a tool used by President Trump, his family, and his close associates by way of exploiting their public power for private gain in the form of financial enrichment. I fear that we may get a rushed vaccine that can be a threat to public health. The government is prioritizing speed ahead of safety. We need to work on ensuring a safe an effective vaccine while also ensuring a fair system of distribution to citizens.

    One of the key things mentioned to help combat this vaccine related corruption is transparency. “Members of Congress and civil society groups have complained about the lack of transparency in the effort to develop a vaccine. The administration has not explained its process for choosing candidates or how many contracts it has awarded.” (see https://billmoyers.com/story/corrupted-the-covid-19-response/). Pushing for maximum transparency in clinical data and delivery reports can make a significant difference in the prevention of corruption. Limited visibility has greatly aided the administration’s ability to make decisions without scrutiny. With the limited information presented to us we do know that, “the government has given millions of taxpayer dollars to inexperienced, untested firms, and considerable leeway to the already powerful pharmaceutical industry.” (see last link). This lets us know that the potential for corruption in vaccine distribution relating to Trump’s administration is almost definite. “Three of the companies that received government funding have never brought a vaccine to market. Let us repeat that: never.” (see last link). Forcing transparency and using NGOs to monitor the movement and delivery of the vaccine would in fact save money, time, and lives as you mentioned.

    I get extremely weary putting trust in anyone who has ties to the Trump administration in any capacity. I believe that this term has showed me that the level of corruption happening within our country is unimaginable. Many documentaries have come up within the last few years tying Trump as well as other people in power to insidious and indefensible crimes. I say this to say that I don’t even know who we should trust at this point as it pertains to anti-corruption monitoring. The same people monitoring could potentially be benefitting from the very corruption in question. The sense of paranoia I am exhibiting is valid considering the type of information that’s constantly being uncovered. My feelings don’t negate the fact that I support the idea of being proactive when it comes to the issue of corruption instead of being reactive. I just don’t have a clear idea on what it’s going to take to combat this. I believe it’s sad that we are reliant on whistleblowers to obtain material information about things that directly affect us or decisions that are being made with our tax dollars. We should already have access to a lot of this information but realistically we have to understand that the discreetness is intentional and even though it’s constantly being challenged or coming into question, nothing is being done about it.

  5. With the current excitement surrounding the Pfitzer and BioNTech Vaccine announcement, your post rings true than ever before. You mentioned some incredibly important steps that could be taken to ensure that the risks and effects of corruption in the COVID-19 vaccine distribution process will be mitigated. However, I fear that these steps may help reduce the effects of corruption when distributing COVID-19 vaccines in developed countries. I still worry about the COVID-19 vaccine corruption effects in countries like Nigeria where there exist limited technologies and deep systemic corruption issues. Although the WHO may adopt practices similar to your recommendations, I wonder how they would be able to ensure that less developed countries adhere to such. In addition, using electronic monitoring systems would most likely not be implemented in less developed countries due to a lack of the proper infrastructure to effectuate such technology.

  6. Disclaimer: as this was an assignment for school, my apologies for the rather strongly-worded language.

    I completely agree with so much of what this post says regarding “significant corruption risks associated with the response to both the public health crisis itself and the economic disruption it has caused. Anticorruption advocates have…emphasized the need for reforms like enhancing transparency, requiring audits, and ensuring protections for whistleblowers.” However, the author finds that it is surprising that there is “little sustained discussion or planning concerning…the inevitable corruption risks that will be associated with the distribution of a COVID-19 vaccine, if and when such a vaccine becomes available.” I realize that harping on one word, “surprising” may seem silly but the optimism and naivety in that sentence makes me laugh; not necessarily at the author but how prevalent (and concerning) this reaction actually is.

    In reality, and sadly, corruption and exploitation in the medical field is far from surprising for anyone who has looked into the topic. It has been an issue in the US for far longer than just the recent concerns related to the Covid-19 pandemic, PPE, and potential vaccine(s). Science, politics, and corporate American re-creating race issues and exploitation in the 21st Century is nothing new. Well-known examples include the many studies publishing objective data showing that doctors have long downplayed levels of pain reported by women and people of color.

    The list is long but some of the most infamous exploitations of people in the medical field, particularly of Black and Hispanic-Americans include:
    • The decades of grave robbing from predominately Black cemeteries of bodies to be used by and/or sold to medical schools for dissection and research.
    • The two fenfluramine experiments where black foster children were targeted in HIV clinical drug trials in New York City.
    • A lead abatement experiment in Baltimore.
    • While not directed at just black children, they were part of a a 1963-1966 study at Willowbrook State School on Staten Island that purposely infected mentally-ill children with hepatitis in order to test gamma globulin against it.
    • Irradiation studies on Black-American cancer patients by Eugune Saenger.
    • Lead-tests carried out by Johns Hopkins research facilities in Black neighborhoods.
    • Forced sterilization
    • The theft and cloning of Henrietta Lacks’ Cells that allowed for the creation of a continuously reproducing cell line
    • Forced surgical sterilization such as one surgeon’s unauthorized removal of the testes in a teen boy with appendicitis while operating on him and another surgeon, Dr. J.M. Hayes’ proposals to sterilize an unconscious woman while performing an experimental caesarean section on her.

    The modernized exploitation of minority groups in the medical field continues but with much of the harm coming from more subtle practices. Even “after controlling for differences among the races in socioeconomic status, health insurance, access to health care and geographic differences, the evidence still shows that Blacks and Latinos receive fewer and inferior clinical services than whites, irrespective of whether those services are for treatment of cardiovascular disease, cancers, mental illness, pre-natal care or HIV/AIDS.” On the other hand, it is ironic that “Black, Native – and Hispanic-American patients have greater access to some healthcare services than do whites – those un-desirable services such as amputations, orchiectomies for prostate cancer and cesarean section deliveries.”
    For example, we spent years criminalizing diseases such as HIV and AIDS. AIDS now affects millions of people across the globe but, in the US, it has largely become associated with people who are poor, promiscuous, or Black. However, the disease was first associated with gay white men. Furthermore, the media would often refer to the “innocent victims of AIDS,” that included children such as Kimberly Bergalis who was purposely infected by her dentist and ten-year old Ryan White who was isolated and ostracized for having the disease. The traits that garnered sympathy in the media for these victims was their white skin and their virginity. Id. The existence of these innocent victims also intimated the existence of “guilty victims.”
    From the very beginning, there were always proponents voicing their beliefs that AIDs was divine punishment for the “homosexual” lifestyle. But as those with the highest rates of deaths from AIDS moved from Whites in the early years of epidemic to Blacks and Hispanics, the narrative soon changed. The term “innocent victim” largely disappeared from the media. Those with the disease began to be profiled “immoral” people whose own actions caused them to be infected. Id. The disease was believed to only strike those who were “sexually promiscuous, drug-addicted, desperately poor.” Id.

    The current Covid-19 epidemic has brought these problems back with a vengenace. With even President Trump referring to Covid-19 as the “Chinese virus,” in the media, the effects have been obvious. Besides from the continued hate crimes perpetrated on Asian-Americans, there have also been more subtle practices. My family is Vietnamese and Chinese. Prior to the stay-at-home order being issued in Boston, my mother got a phone call from the school to come pick up my 7-year old sister. She was not given a reason but upon further questioning, it was discovered that my sister was wearing a mask at school. While my parents had not been aware of this, they found out that about half of the students in her class were doing the same. However, without ever asking my sister any questions, the school automatically assumed that she was sick and needed to be sent home. Not surprisingly, we found out that a few other students, all Asian-American, had also been asked to be picked up by their parents. From my community, there are been many instances where we were stopped by officers for not wearing a mask in public; well before it became mandatory.

    For these issues, the solutions need to come from the policy level. Lawmakers may be hesitant to step into the scientific and medical institution, whether for a lack of expertise or because of discretionary practice of doctors, there needs to be some over-arching system put in place. The medical system is simply too decentralized. There are too many hospital systems and they are too spread out.

    Due to a lack of data, I reached out to various acquaintances to better understand the issues with the current epidemic. After interviewing various contacts in the medical community including attending doctors, residents, nurses, and medical students, many voiced the same issues and proposals. However, there is lack of authority or mandatory implementations.

    First and foremost, almost every person has said that they believe that there should be a federal system for tracking demographic data associated with major contagious diseases, particularly covid-19, where it is mandatory for the states to report their numbers. Furthermore, the lack of personal protective equipment (PPE) disproportionately affects essential workers, the vast majority of whom are poor, black, and/or Latino. In hospitals, the majority of affected employees are the members of environmental services, medical assistants, and security guards who are not as prioritized for PPE as doctors and nurses. Proposed solutions include mandated PPE, timely health screenings, expedited top-notch health insurance for these workers (as their hospital bills would be high if admitted). Many workers who do get sick due to their work often weren’t even qualified for hazard pay. Qualification and implementation of it has been spotty and inconsistent.

    Of course, the effects of the virus have spilled into people’s homes as well. Because of the lack of better oversight, the food, health, and education gap between minority and white children has been further being exacerbated by the pandemics. Children are not getting their education simply because of a lack of internet or computers in their homes. The stay-at-home orders have prevented access to free internet at cafes and access to computers at libraries. While the $1200 per adult stimulus checks (and additional amounts for children) have helped, many are still struggling to provide adequate access to food and healthcare for their families.

    While I appreciate and absolutely understand the concern for the corruption that will (not, may) result when a vaccine is released and the pursuit of ways to counter thus, I am too jaded by what I have seen, know, and researched to believe that there will be any real solutions, especially not in light of how soon a vaccine is expected to be released based on press releases issued just in the past week. The FDA is trying to ensure transparency and accountability but how is this any different from what they were supposed to have already been doing?

    Transparency related to drugs and healthcare has long been an issue. The “White Wall of Silence,” is very real. When looking for more transparency, more information, and more reporting (particularly, on demographics), many see a white wall of silence in hospitals. One doctor speaks about how, when asked for more transparency in healthcare, he repeatedly hears colleagues say “that the rest of the world could not ‘understand’ the tough calls, the gray areas, the complexity of medical knowledge.” Doctors fear that, “[t]elling a patient about another doctor’s medical error can mean losing business or suffering retribution.” Furthermore, a lack of reporting on demographics makes it difficult to institute policies to remedy racial inequities in healthcare.

    However, the wall of silence is not just between doctors and laymen. There are many within hospitals: between residents and doctors, between doctors and the insurance company, and between doctors and the hospital administrators. In general, residents are often the youngest, most progressive, and most likely to want to address racially motivated practices. Yet, they are in the poorest position to speak up about problems they see. They face the worst working conditions and most exposure during the pandemic and cannot even speak up about their own safety, let alone try to institute real change for patients. Hospitals have created diversity boards in an attempt to give the younger generation of doctors a chance to implement change. Based on my interviews of actual residents and doctors, the boards are little more than sounding boards and rarely effect any change.

    I want to be proven wrong; that these opinions are simply a result of my jaded worldview. Despite the naivety that I laughed at, I can only hope that I will be pleasantly surprised (likely, shocked speechless) if there is real, positive, and effective change.

    Endnotes:
    Roberts, Dorothy E., “Fatal Invention: How Science, Politics, and Big Business Re-create Race in the Twenty-first Century” (2011). Faculty Scholarship at Penn Law. 433. https://scholarship.law.upenn.edu/faculty_scholarship/433.
    Alliance For Human Research Protection. 2005. AHRP Testimony: Protections for Foster Children Enrolled in Clinical Trials Submitted to Cong. Ways & Means Hearing. Retrieved December 12, 2019 from http://www.ahrp.org/infomail/05/05/18.php.
    Leiter, V., & Herman, S. (2015). Guinea Pig Kids: Myths or Modern Tuskegees? Sociological Spectrum, 35(1), 26–45. https://doi-org.ezproxy.wlu.edu/10.1080/02732173.2014.978429.
    McNeil, D.G., “U.S. Apologizes for Syphilis Tests in Guatemala,” 2010, https://www.nytimes.com/2010/10/02/health/research/02infect.html.
    Id.
    Pohl, L. (2012). African American Southerners and White Physicians: Medical Care at the Turn of the Twentieth Century. Bulletin of the History of Medicine, 86(2), 178-205. Retrieved from http://www.jstor.org/stable/26305846.
    Washington HA, editor. Medical Apartheid: The dark history of medical experimentation on Black Americans from colonial times to the present. New York: Random House, Inc; 2006.
    P. 794, https://www.nasi.org/usr_doc/Matthew_Working_Paper.pdf

    Click to access Matthew_Working_Paper.pdf


    Washington HA. P. 330.
    Id.
    Hopppe, T. (2018). INTRODUCTION.: Punishment: AIDS in the Shadow of an American Institution. In Punishing Disease: HIV and the Criminalization of Sickness (pp. 1-14). Oakland, California: University of California Press. Retrieved May 4, 2020, from http://www.jstor.org/stable/10.1525/j.ctt1wn0rqg.
    Stephen V. Kenney, Criminalizing HIV Transmission: Lessons from History and a Model for the Future, 8 J.
    Contemp. Health L. & Pol’y 245 (1992). Available at: https://scholarship.law.edu/jchlp/vol8/iss1/18. Citing Centers for Disease Control, Mortality Attributable to HIV Infection/AIDS-United States, 40 Morbidity & Mortality Wkly. REP. 41, 41 (1991).
    Washington HA. P. 330.
    https://www.pfizer.com/news/press-release/press-release-detail/pfizer-and-biontech-conclude-phase-3-study-covid-19-vaccine
    https://www.fda.gov/news-events/press-announcements/coronavirus-covid-19-update-fda-announces-advisory-committee-meeting-discuss-covid-19-vaccine.
    White Wall of Silence: Denial isn’t conscious. http://www.patient-safety.com/white_wall_of_silence.htm.
    Allen, M. Why Doctors Stay Mum About Mistakes Their Colleagues Make. Nov. 8, 2013. https://www.propublica.org/article/why-doctors-stay-mum-about-mistakes-their-colleagues-make.
    Corley, J. “Doctors In Training Are Dying, And We Are Letting Them Down”, Apr 5, 2020. Forbes. http://www.forbes.com/sites/jacquelyncorley/2020/04/05/doctors-in-training-are-dying-and-we-are-letting-them-down/#40eb01ac6cdc

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