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Conflict of Interest Policies

As set forth in its statutory authority, MACPAC is a non-partisan body, responsible for providing data, reports, and policy recommendations to Congress, the United States Department of Health and Human Services, and the states concerning diverse aspects of the Medicaid program and the State Children’s Health Insurance Program (CHIP). Congress relies on the Commission to develop and recommend policies on the basis of objective evidence. Commissioners are expected to be attentive to and transparent about their personal and political interests and refrain from voting on MACPAC recommendations if their interests could interfere with, or reasonably appear to interfere with, their judgment.

MACPAC has adopted a policy to articulate the conflict of interest principles to which Commissioners are subject. The policy establishes the procedures by which conflicts will be identified and addressed in advance of a vote upon any recommendation to which the conflict relates and sets forth certain activities in which MACPAC Commissioners may not participate during their tenure on the Commission.

The policy recognizes that Commissioners typically hold positions and are professionally involved with many other entities and organizations. Their selection by the U.S. Government Accountability Office to serve on MACPAC is based in substantial part on the developed expertise and perspectives they bring from their individual professions, experiences, and affiliations.  The specific backgrounds, roles, and disciplines are outlined in the statute.

Viewpoint biases that flow from this diversity are inevitable and integral to the design of advisory commissions. Such viewpoints are naturally shared in the course of deliberation and are themselves a force for collective balance in that they counter the dominance of any one perspective.

Unlike viewpoint diversity, biases driven by opportunities for financial gain or other personal advantage are not necessarily apparent and, rather than fulfilling the statutory mandate of the Commission, risk undercutting it. This policy is directed at protecting against such biases. It sets forth a process to reduce the risk that, in carrying out their charge, the Commissioners have competing loyalties that would undermine the trust Congress places in MACPAC’s recommendations.  The full policy can be downloaded below.

Read the policy on Commissioner conflicts of interest

MACPAC staff are considered employees of the U.S. Senate and are subject to its Code of Official Conduct as well as additional rules concerning conflicts of interest set forth in the MACPAC Employee Handbook.  A summary of these rules can be downloaded below.

Read the conflicts of interest policies for MACPAC staff