Securing Approval for Sponsorship of Conferences

Appendix:

GUIDANCE FOR COLLABORATION WITH THE PRIVATE SECTOR

I. PURPOSE

The purpose of this Guide is to delineate policies and procedures on sponsorship by the Centers for Disease Control and Prevention (CDC)¹ of domestic or international conferences held by nonfederal (not-for-profit and for-profit) organizations. This Guide applies to:

• Sponsorship involving CDC financial support for conference organizer(s) through grants and cooperative agreements (including partial use of funds provided to CDC grantees for other purposes), interagency agreements, contracts, or purchase orders.
   
• Sponsorship not involving expenditure of CDC funds.

This Guide does not apply to CDC cosponsorship of conferences when only Federal agencies are involved. However, when other Federal agencies are cosponsoring a conference with nonfederal organizations, CDC should adhere to this Guide in determining whether it wishes to be a cosponsor of the conference.

II. EFFECTIVE DATE

This Guide applies to all requests for CDC sponsorship received on or after February 21, 1997.

III. BACKGROUND

The mission of CDC is to promote health and quality of life by preventing and controlling disease, injury, and disability. CDC is increasingly working with other Federal agencies and nonfederal organizations to fulfill this mission and to maximize public health resources. Evidence indicates that public health interventions and tools will not have the impact that is needed unless their breadth and pervasiveness are increased.

Partnerships with nonfederal organizations enable the agency to utilize expanded public health networks to improve the usefulness of research and the dissemination and effectiveness of health interventions. Sponsorship of relevant conferences can provide opportunities to actively further CDC's mission.

CDC's Guidance for Collaboration with the Private Sector (see Manual Guide - General Administration No. CDC-81) discusses the need to assess the suitability of potential collaborations with not-for-profit and for-profit organizations. The Guidance highlights the following principles, which help ensure that CDC is achieving its primary mission and help govern the assessment of potential partnerships and collaboration:

• Public health decisions must be based on sound science and the public good.
   
• The benefits to society must be a higher goal than benefits to either partner in the collaboration.
   
• The agency must be a diligent steward of public trust and funds.
   
• The agency and its employees should conduct business according to the ethical standards that govern the agency.

Collaboration involves working jointly with another organization or organizations, including working jointly on a particular conference. The Guidance includes criteria to be used when assessing potential collaborations and gives recommendations for collaborations in general. A listing of the criteria and recommendations is provided in the Appendix.

Although the Guidance recommends that each Center, Institute, and Office (CIO) establish a formal review and advisory process for examining potential collaborations and partnerships, an overall policy is needed to safeguard the integrity of the agency's mission regarding the association of CDC's name, through sponsorship, with specific conferences.

IV. DEFINITIONS

A. Conferences

A conference is a symposium, seminar, workshop, or any other organized and formal meeting lasting portions of 1 or more days, where persons assemble to exchange information and views or explore or clarify a defined subject, problem, or area of knowledge, whether or not a published report results from such meeting.

B. Nonfederal Organizations

Nonfederal organizations may be a for-profit or not-for-profit entity. For-profit organizations include corporations, partnerships, proprietorships, and others intended to generate financial gain for their owners. Not-for-profit entities include but are not limited to State, local, and foreign governments; voluntary associations; foundations; civic groups; professional associations; and universities.

C. Sponsorship

Sponsorship is the provision of CDC support for a conference that is undertaken by a nonfederal organization in furtherance of CDC's mission. Sponsorship may involve (1) provision of funds, generally by the Procurement and Grants Office (PGO) through a grant, cooperative agreement, interagency agreement, contract, or purchase order (for printing of materials, equipment or supplies, etc.), or (2) the public expression of support without financial assistance, usually through allowing CDC's name or design element to be used by the sponsoring organization in conjunction with the conference.

D. Technical Assistance, Participation, and Attendance

Technical assistance by CDC staff (e.g., review or provision of conference materials) or official participation by CDC staff as speakers or attendees does not, in and of itself, constitute sponsorship.

V. POLICY ON SPONSORSHIP OF CONFERENCES

When CDC is asked to sponsor a conference, the following general conditions must be met:

1. The conference should support CDC's public health principles (described in Section III) and furtherance of CDC's mission of promoting health and quality of life by preventing and controlling disease, injury, and disability.
    
2. Requests for CDC sponsorship of conferences that include funding must be approved by the Director of the CIO(s), or his/her designee, and processed through financial support procedures as described in Section VI-A.
    
3. Requests for CDC sponsorship of conferences that does not include funding must be approved by the Director of the CIO(s), or his/her designee, as described in Section VI-B.
4. Sponsorship must be consistent with CDC's Guidance for Collaboration with the Private Sector (see Manual Guide - General Administration No. CDC-81).
    
5. Any conference sponsored by CDC shall be held in facilities that are fully accessible to the public as required by the Americans with Disabilities Act Accessibility Guidelines (ADAAG). Accessibility as per ADAAG also addresses accommodations for persons with sensory impairments.
6. The conference organizer(s) may use CDC's name only in factual publicity for the conference, and should understand that CDC involvement in the conference does not necessarily indicate support for the organizer's general policies, activities, or products.

Requests for technical assistance, participation in, or attending a conference by CDC staff members should be approved or disapproved according to procedures determined by the employee's CIO.

VI. PROCEDURES

A. Sponsorship Involving CDC Funds

A grant, cooperative agreement, interagency agreement, contract, or purchase order is required when CDC is asked to sponsor a conference with a nonfederal organization and funds are provided. Financial support procedures, as specified by the funding CIO, PGO, and the Financial Management Office, must be followed for such requests. Each grant, cooperative agreement, interagency agreement, contract, or purchase order awarded for conference support must have approval by the Director, or his/her designee, of the CIO(s) providing the funds. CDC grantees that use portions of general program funds to support conferences must also have CDC approval if CDC is to be identified as a sponsor of the event.

The following language must be included in all program announcements, including conference support announcements, for CDC sponsorship of nonfederal conferences when funds are to be awarded:

The purpose of conference support funding is to provide PARTIAL support for specific nonfederal conferences in the areas of health promotion and disease prevention information/education programs. Because conference support by CDC creates the appearance of CDC cosponsorship, there will be active participation by CDC in the development and approval of those portions of the agenda supported by CDC funds. CDC funds will not be expended for nonapproved portions of meetings. In addition, CDC will reserve the right to approve or reject the content of the full agenda, press events, promotional materials (including press releases), speaker selection, and site selection. Contingency awards will be made allowing usage of only 10% of the total amount to be awarded until a final full agenda is approved by CDC. This will provide funds to support costs associated with preparation of the agenda. The remainder of funds will be released only upon approval of the final full agenda. CDC reserves the right to terminate cosponsorship if it does not concur with the final agenda.

B. Sponsorship Not Involving CDC Funds

When sponsorship of a conference is requested and does not involve expenditure of CDC funds, the requesting organization must submit a formal request in writing to the CIO(s) having related programmatic responsibility and/or the Office of the Director (OD), CDC. The following information must be provided:

• The organization's mission
   
• Purpose of the conference
   
• The organizer's demonstrated capacity to plan and conduct such a meeting
   
• Proposed content and format
   
• Intended audience
   
• Other cosponsors, their mission, and their role in the conference

The CIO Director, or his/her designee, is responsible for reviewing and approving or disapproving all requests submitted to the CIO. Requests made to the OD, CDC, should be coordinated promptly with the Director(s) of the CIO(s) having programmatic responsibility.

1. Disapproval of Sponsorship

When the CIO or the OD, CDC, does not wish to sponsor the conference, a written response must be provided to the conference organizer(s) indicating disapproval of the request.

No verbal disapproval of sponsorship may be provided.

2. Approval of Sponsorship

If the CIO is interested in sponsoring the conference, a written response must be provided to the conference organizer(s) indicating tentative approval. This response must contain the following language:

Because use of CDC's name or design element indicates sponsorship, there must be active participation by CDC in the development and approval of all or specific portions of the conference for which CDC's name is used. CDC reserves the right to have a staff member serve on the conference planning committee and to review the content of the full agenda, press events, promotional materials (including press releases), speaker selection, site selection, and reports or proceedings resulting from the conference. CDC reserves the right to terminate sponsorship of any portion of the conference with which it does not concur.

After reviewing the full final conference agenda and other conference information, the CIO will provide a written response to the conference organizer(s) indicating final approval or disapproval of sponsorship.

No verbal approval of sponsorship may be provided.

C. Accessibility Requirements

All conferences sponsored by CDC shall be held in facilities that are fully accessible to the public as required by ADAAG. Accessibility under ADAAG addresses accommodations for persons with sensory impairments, as well as persons with physical disabilities or mobility limitations.

The Director, or his/her designee, of the CIO(s) providing funds or approving CDC sponsorship of a conference must assure that the proposed meeting facilities comply with ADAAG by onsite survey prior to approving any request or issuing any obligation documents. Assurance of compliance will be determined by the following actions: (1) completion of an onsite survey, "Meeting Facility Accessibility Survey"² by CDC or CDC contractor staff from the sponsoring CIO(s); and (2) review of the completed "Meeting Facility Accessibility Survey" by CDC or CDC contractor staff from the Disabilities Prevention Program, National Center for Environmental Health.

Once a facility has been surveyed, as noted above, and approved, it will not be necessary to resurvey the facility as long as the survey document is maintained and the facility has not undergone any renovation that would change the accessibility of the facility.

D. Reporting Requirements

A copy of all written correspondence regarding conferences that CDC is asked to sponsor (including the incoming request and subsequent CIO approvals or disapprovals) will be maintained on file in the Office of the Director of the CIO having programmatic responsibility. A specific person should be assigned responsibility for maintaining these records, and for submitting a quarterly line listing of all conferences sponsored or disapproved to the OD, CDC (i.e., the Associate Director for Management and Operations). The OD will maintain records of these listings and make them available to the CIOs upon request.

APPENDIX

Guidance for Collaboration with the Private Sector

I. Criteria for Assessing Potential Collaborations*

1. CDC should be clear how the potential collaboration fits within its overall mission and priorities and the private partner's mission and priorities.
    
2. CDC should address independence and objectivity of scientific judgment in the potential collaboration. Further, mechanisms should be identified that will ensure such objectivity and independence during the collaboration.
    
3. CDC should assess the effect of the private partner's products or services on health and whether they are compatible with CDC's mission.
    
4. CDC should assess the behavior of the private partner in conducting business and determine whether the partner's behavior is consistent with CDC's mission and the principles guiding private sector collaboration.

II. General Recommendations for Collaborations*

1. CDC should assess not only the specific area of mutual interest but the public impact of the partner's broad public mission and image. For highly controversial issues, multiple collaborators should be sought that represent a broad spectrum of opinions and interests.
    
2. CDC should avoid participating in indirect collaborations unless it would participate in a direct relationship with the partners.
    
3. Private partners should be informed that the existence of the collaborative relationship will be made a matter of public record. How this will occur should be worked out early, especially if implied endorsements are likely. No direct endorsement of a product or service is permitted by the agency.
    
4. CDC should maintain a process of openness and fairness in developing collaborations with partners on similar projects or projects with similar intent.
    
5. Within each Center, Institute, and Office (CIO), a formal review and advisory process should be established for examining potential collaborations according to the principles, criteria, and recommendations described in this document.
    
6. Employees who will be developing collaborations with the private sector should receive orientation and guidance from the CDC Ethics Officer concerning the agency's principles, criteria, and recommendations for collaborating with the private sector.

* Excerpt from Manual Guide - General Administration No. CDC-81, Guidance for Collaboration with the Private Sector

¹ References to CDC also apply to ATSDR.
² Survey available upon request from the Disabilities Prevention Program, National Center for Environmental Health.