Update 10: Routine Federal Procedure is Flouted in CDC Lyme Programs Greeting from Jenna, When working with the US Agency for International Development, I witnessed the Agency’s internal procedures for addressing violations of federal statutes and laws. I was also part of a group of persons who supplied testimony for an Inspector General case involving preferential treatment, conflict of interests and waste. Therefore, I know how federal agencies, such as the CDC, routinely respond to complaints of preferential treatment and the appearance of preferential treatment. [Ref 1] Routine responses include: 1. Investigation of those public servants - identified by the public or colleagues - who are accused of preferential treatment and the appearance of preferential treatment. During the investigation phase, these public servants are routinely barred from any funding decisions including research, contractor awards, hiring, training and educational materials or partner institutions that had any connection to, or promotion of, the preferred institution. Sometimes they are barred from all and any resource allocation. -and- They would be restricted or barred from decision-making authority over any and all technical and policy directions that included the preferred institution or its products. 2.Sometimes a federal agency will take remedial actions without a formal ethics investigation. This might happen in cases where the same public servant is repeatedly identified by the public, through inquiries and correspondences, as appearing to show preferential treatment. Under such circumstances, the Agency often publicizes a new policy or process to reassure the public that steps are being taken so that this situation is not repeated. In such cases, the identified public servants are restricted in authority and barred from certain actions until the Agency has implemented such remedial steps. It is not uncommon to have supplemental supervision over the public servant. 3.Another common remedial action is to remove the public servant from his/her current post and place them in a post where s/he does not engage the preferred institution or policies, programs and funding decisions that were associated with the previous post. It is not uncommon to have supplemental supervision over the public servant. 4. In all such cases, the Agency would routinely impose certain additional restrictions upon the public servant until the matters are resolved. They could: -Require that the public servant not associate with the preferred institution. -Limit or remove the public servant from representational roles for the Agency. -Delay the distribution of publications s/he authored that reference the preferred institution or product of the preferred institution. Given my previous experience, I find CDC’s lack of attention and action regarding Lyme Corps’ appearance of preferential treatment to be highly irregular. I have been in contact with a number of colleagues in various federal agencies and described the situation to them. They too, share my view, that this situation is highly irregular and does not conform to how their Agency would respond to complaints, made by public stakeholders, of appearance of preferential treatment or preferential treatment. To quickly summarize, in the case of the CDC Lyme Corps program, the appearance of preferential treatment for the Infectious Disease Society of America (IDSA) is suggested by: Lyme Corps’ promotion of the IDSA Lyme Guidelines that were removed February 12, 2016 from the federal National Guidelines Clearinghouse (NGC) because they do not meet the high evidentiary standards of the Health and Medicine Division (formerly Institute of Medicine) they are outdated and fall short of NGC selection criteria. Versus Lyme Corps’ exclusion and/or distortion of the International Lyme and Associated Diseases Society (ILADS) Lyme Guidelines. ILADS Guidelines recognize that Lyme disease is a complex and serious illness of epidemic proportion and offers individualized patient-centered treatments. ILADS guidelines are posted on the federal NGC, as they are science based, patient-centered and conform to criteria based on the high evidentiary standards of the Institute of Medicine. See link http://www.guideline.gov/content.aspx?id=49320&search=lyme+disease+and+ilads+guildlines The public servants involved in this appearance of preferential treatment for the IDSA include: Rima Khabbaz, MD, Deputy Director for Infectious Diseases and as the Director of Office of Infectious Diseases (OID); Beth Bell MD, Director of the National Center for Emerging and Zoonotic Infectious Diseases (NCEZID), Centers for Disease Control and Prevention (CDC), Fort Collins, CO; Lyle R. Petersen, MD, MPH Director, Division of Vector-Borne Diseases, National Center for Emerging and Zoonotic Infectious Diseases (NCEZID) and CDC Spokesperson; C. Ben Beard, Branch Chief, Bacterial Diseases Branch (BDB) of Division of Vector-Borne Diseases (DVBD) under CDC/NCEZID; Christina Nelson, MD, MPH, FAAP, Medical Epidemiologist, CDC/NCEZID/DVBD/BDB. Petersen, Khabbaz and Bell are members of the IDSA. [Ref 2] [Ref 3]. All three persons have management roles with significant authority. Khabbaz reports directly to the CDC Office of the Director, and Bell reports directly to Khabbaz. (See Org chart in picture above.) DVBD Director Petersen reports directly to Bell. Please note, the fact that there are no non-IDSA members among the Directors making up the OID - NCEZID - DVBD Chain of Command contributes the appearance of preferential treatment for the IDSA and its products. It has not been confirmed if Beard and Nelson are also members of the IDSA. However, they remain accountable for promoting the outdated substandard IDSA Lyme Guidelines under the authority and oversight of IDSA members Khabbaz, Bell and Petersen. Thanks – Jenna [Ref 1] Standards of Ethical Conduct for Employees of the Executive Branch, Final Regulation Issued by the U.S. Office of Government Ethics Codified in 5 C.F.R. Part 2635 As amended at 76 FR 38547 (July 1, 2011): Employees shall act impartially and not give preferential treatment to any private organization or individual. (Page 2 subparagraph 8) and Employees shall endeavor to avoid any actions creating the appearance that they are violating the law or the ethical standards set forth in this part. Whether particular circumstances create an appearance that the law or these standards have been violated shall be determined from the perspective of a reasonable person with knowledge of the relevant facts. (Page 2 subparagraph 14). [Ref 2] According to CDC website profiles, Rima Khabbaz and Beth Bell are members of the IDSA. [Ref 3] According to the IDSA website, Lyle R. Petersen is a member of the IDSA.