ESTUDIOS
Corruption and COVID-19
Corrupción y COVID-19
Susan Rose-Ackerman *
Yale University
ORCID ID 0000-0002-8502-8437
susan.rose-ackerman@yale.edu
Recommended citation:
Rose-Ackerman, S. (2021). Corruption and Covid-19. Eunomía. Revista en Cultura de la Legalidad, 20, pp.
16-36.
doi: https://doi.org/10.20318/eunomia.2021.6061
Recibido / received: 19/12/2020
Aceptado / accepted: 20/02/2021
Abstract
The coronavirus pandemic has created incentives for corruption, fraud, and self-dealing that
can be explained by the underlying political-economic incentives at work. Three characteristics
of the COVID-19 crisis are especially important. First, the rapidly unfolding pandemic and the
accompanying economic recession have led to fierce competition for essential resources.
Second, governments have rapidly mobilized public funds (for both healthcare and economic
stabilization) at an unprecedented scale, creating opportunities for rent-seeking of many kinds,
including outright corruption. Third, politicians, bureaucrats and medical professionals exercise
substantial discretion in the allocation of resources. A lack of transparency and weak oversight
and enforcement have exacerbated the problems of corruption and fraud, and public measures
against these offenses have not kept pace with the developing crisis. The paper discusses how
these features interact in procurement processes, in government assistance to individuals and
businesses, and in the development and licensing of pharmaceuticals. Those who benefit from
corruption, be they contractors or individuals, will emerge from the pandemic better off than
before it started if governments do not act. Tolerance of malfeasance will be at the expense of
long-term government legitimacy and spread the virus to the most vulnerable. The need for a
speedy response to the pandemic should not be an excuse for undermining institutions that
strengthen governmental integrity.
Keywords
Adverse selection, beneficial ownership, coronavirus, corruption, COVID-19, fraud,
government contracting, healthcare, lotteries, moral hazard, pandemic, pharmaceuticals,
procurement (government), vaccine, whistleblowers.
Resumen
La pandemia del coronavirus ha generado incentivos a la corrupción, al fraude y la autocontratación que pueden ser explicados mediante los incentivos político-económicos que se
tratan en el trabajo. Tres características de la crisis de la COVID-19 son especialmente
Henry R. Luce Professor Emeritus of Jurisprudence and Professorial Lecturer in Law, Yale University. I
want to thank Paul Shortell and Eunsun Cho for excellent research assistance.
*
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importantes. En primer lugar, el rápido desarrollo de la pandemia y la correlativa recesión
económica han conducido a una feroz competencia por los recursos esenciales. En segundo
lugar, los gobiernos han movilizado rápidamente fondos públicos (tanto para el sistema
sanitario como para la estabilidad económica) en una escala sin precedentes, creando
oportunidades de muchos tipos para la captación de dinero fácil, incluyendo las abiertamente
corruptas. En tercer lugar, los funcionarios y los profesionales sanitarios ejercen una
discrecionalidad sustancial en la asignación de recursos. La pérdida de transparencia y de
debilitamiento de la supervisión y del cumplimento de las normas ha exacerbado los problemas
de corrupción y de fraude, y las medidas públicas contra esos delitos no han mantenido el
paso al desarrollo de la crisis. El trabajo discute cómo esas características interactúan en los
procesos de adquisiciones y suministros, en la asistencia gubernamental a las personas y a
las empresas y en el desarrollo y autorización de los medicamentos. Aquellos que se
benefician de la corrupción, sean contratistas o particulares, saldrán de la pandemia mejor que
lo que entraron si los gobiernos no actúan. La tolerancia de las actividades ilícitas será a costa
de la legitimidad del gobierno a largo plazo y extenderá el virus entre los más vulnerables. La
necesidad de una respuesta rápida a la pandemia no debería ser una excusa para debilitar a
las instituciones sino una razón para fortalecer la integridad gubernamental.
Palabras clave
Alertadores, coronavirus, corrupción, COVID-19, contratación pública, fraude, medicamentos,
pandemia, riesgo moral, selección adversa, servicio de salud, sorteos, suministros (públicos),
titularidad final, vacuna.
SUMMARY. 1. Introduction. 2. Expedited Procurement Processes. 3.
Rapid Allocation of Government Assistance to Individuals and
Businesses. 4. Pharmaceutical Licensing and Insider Trading. 5.
Conclusions.
1. Introduction
Wars, catastrophes, and disasters breed fraud and corruption at the same time as they
generate acts of self-sacrifice and generosity. Generous actions may themselves
involve illicit payoffs and the breaking of rules as people bump up against institutions
and practices designed for ordinary times. Nevertheless, the widespread flouting of
the rules, both legal norms and social practices, can hinder efforts to bring the situation
under control and have long-term effects after the end of the crisis1. These dual shortand long-term problems are manifest in the corruption and fraud accompanying the
response to the novel coronavirus. An April 2020 survey of anti-fraud professionals in
58 countries reported widespread incidents of fraud in the acquisition of personal
protective equipment, black market goods, and faulty equipment. Cases of
embezzlement were reported in 58 percent of countries surveyed by 19 percent of
respondents, distributed unequally across the countries’ surveyed. Bribes were
reported in 22 percent of countries by three percent of respondents (Nemexis, 2020).
Much corruption, of course, never comes to light so the study does not permit one to
measure the incidence and impact of malfeasance, but other investigations and press
reports document its occurrence in a wide range of countries 2. Furthermore, even with
no explicit payoffs, contracts may favor the cronies of the politically powerful 3.
On corruption risks in countries emerging from civil war see: Rose-Ackerman and Palifka (2016, pp.
316-340). For more details see: Rose-Ackerman (2009).
2 For example, see: Slattery and Brito (2020); URN (2020); Gascón Barberá (2020).
3 For example, see: Sishi and Winning (2020); Harris, et al. (2020); Bradley, Gebredekidan and McCann
(2020); Maswood (2020).
1
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Corruption may accompany any rapidly developing crisis that leads to loss of
life, widespread injury and illness, or destruction of property. Taking a politicaleconomy approach, this essay isolates several reasons for this connection illustrated
by, but not unique to, the current pandemic 4.
First, governments need to respond quickly to a crisis, such as a hurricane, a
wildfire, or an earthquake. Some governments will have set aside reserve funds and
personnel, but other polities will have skimped on spending, judging it to be
improvident to divert funds from citizens’ day-to-day needs or to acknowledge lowprobability risks. Regardless of resource constraints, many governments simply
neglect to provide for even quite predictable disasters; responses to wildfires in
California, earthquakes along the “ring of fire”, or urban unrest may be underfunded,
and preventive actions, such as building codes, fire resistant housing, and police
training may have low priority. Then, what could have been a routine response to a
predictable event becomes a desperate race against time with devastating
consequences 5.
As a result, governments spend large amounts of money and make regulatory
changes in a short time period with little oversight, precisely when the very speed of
the response suggests that oversight is especially needed. Such haphazard
responses can cement political patronage and result in waste and fraud at the expense
of equity and effectiveness.
Second, in the case of COVID-19, the need for a rapid response is not the only
risk factor; multiple sources of uncertainty complicate the policy response. The virus
was and remains poorly understood. When the pandemic began, there were no
vaccines to limit the risk of infection or proven anti-viral medicines to give to those
afflicted. There was considerable uncertainty about the best strategies with respect
testing, treatment, and safety protocols that balance safety with ongoing economic and
social life. Several vaccines have now obtained regulatory approval in the U.S. and
elsewhere, but the effectiveness of distribution networks remains uncertain (Financial
Times, 2020, December 4).
Further, governments may need to make unexpected regulatory changes with
few precedents to draw on. For example, governments across the world are constantly
under pressure to decide on the timing, length, and severity of lockdowns, with no way
to satisfy all constituencies. Utilizing the existing capability for online diagnosis during
a pandemic meant resolving conflicts with privacy regulations and creating new
guidelines for widespread use (Sultan Mahmood, et al., 2020).
In such situations, much depends upon the professional integrity of both market
actors and government agencies to guard against the opportunities for corrupt or, at
least, self-serving behavior. The corrupt opportunities presented by severe uncertainty
go beyond bribery or fraud. Profit-seeking individuals and firms may take advantage
of market disruptions and regulatory loopholes at the public’s expense. Thus, the
pandemic has exacerbated the risks of corruption that exist whenever public officials
International financial institutions, such as the World Bank and the IMF, are acutely aware of these risks.
See: World Bank Group (2020, April 28); Gaspar, Mühleisen and Weeks-Brown (2020). A webpage
provides links to other World Bank material on governance and the response to COVID-19:
https://www.worldbank.org/en/topic/governance/brief/governance-institutions-covid-19-responseresources
5 For example, see: Sullivan (2018).
4
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are charged with allocating scarce benefits and costs under unclear or inconsistent
legal rules 6.
Third, the healthcare sector differs from the ordinary competitive market even
in normal times, and market imperfections arise in the accompanying insurance
markets. Some libertarians argue that society can depend upon the private sector to
respond promptly. Competitive markets, according to that view, will rush to develop
the needed tests, vaccines, and anti-viral medicines, and government interventions to
increase accessibility to these goods will only remove the producers’ profit motives 7.
Individuals, at the same time, will take precautions to protect themselves without the
need for government action. Under this view, even if society does not achieve herd
immunity through widespread infection, individual choices are preferable to imposed
lockdowns 8.
However, this perspective ignores the pervasive market imperfections in
healthcare 9. Consumers are largely ignorant of the proper treatments for their
ailments, reinforcing the need to enforce the professional competence and integrity of
providers. Insurance is subject to moral hazard and adverse selection (Arrow, 1963;
Powell and Goldman, 2020). Individuals may not truthfully reveal their underlying
health conditions to insurance companies if insurers seek to set prices to reflect an
individual’s risk of making a claim. Once insured, they may demand excessive care
because they do not bear its full cost out of their own pockets (moral hazard). Such
actions will increase the breakeven cost of insurance and make certain types of
coverage unavailable. In addition, if insurance companies cannot adjust their prices to
reflect the risks to their bottom line, the healthy may forgo insurance, leading the
insurance system to unravel because it depends upon the averaging out of claims
across policyholders (adverse selection). In short, unlike many natural disasters, the
underlying structure of the relevant sector (healthcare) is riddled with inefficiencies that
have been exacerbated by the pandemic. Of course, there can be price gouging and
corruptly obtained contracts for recovery from natural disasters and human conflicts,
but having healthcare at the center of recovery creates special problems.
***
As the Group of States against Corruption (GRECO) of the Council of Europe
observed in its guidance to member states:
[Covid-related corruption can take the form of] facilitation payments/bribes to push
ahead processes that may have stalled due to shortages of staff or closure of public
offices, falsification of documents to meet the conditions of State aid schemes for
pandemic relief measures, bypassing product certification requirements, noncertification of alternative supply chains, donations, lack of resources to supervise
misconduct by individual employees, etc. (2020, p. 5).
These three characteristics of the COVID-19 crisis, taken together, have
significantly increased corruption risks. First, the rapidly unfolding pandemic and the
accompanying economic recession have led to fierce competition for essential
resources. Second, governments have rapidly mobilized public funds (for both
healthcare and economic stabilization) at an unprecedented scale, creating
opportunities for rent-seeking of many kinds, including outright corruption. Third,
6 The background incentives for bureaucratic corruption are outlined in: Rose-Ackerman and Palifka (2016
pp. 51-92).
7
See: Lybecker (2020); Swan and Gerstein (2020).
8 See: Brumfiel and Keith (2020); Cannon (2020).
9 The economics of healthcare is a well-developed field of study that was launched by a classic article by
Kenneth J. Arrow, “Uncertainty and the Welfare Economics of Medical Care” (1963).
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politicians, bureaucrats and medical professionals exercise substantial discretion in
the allocation of resources. A lack of transparency and weak oversight and
enforcement have exacerbated the problems of corruption and fraud, and public
measures against these offenses have not kept pace with the developing crisis. I
discuss how these features interact in procurement processes (section 2), in
government assistance to individuals and businesses (section 3), and in the
development and licensing of pharmaceuticals (section 4).
2. Expedited Procurement Processes
Awarding government contracts during a public emergency faces challenges that differ
from those that arise in normal times. Procurement is usually a buyers’ market, with
the contracting agency holding significant leverage over suppliers. However, during
an emergency, time pressures and a lack of qualified suppliers may undermine clarity
and transparency in the contracting process, creating a favorable environment for
firms to engage in bid-ridding, price-gouging, and fraud 10.
Examples abound. To list just a few, in the United States, contracts worth
hundreds of millions of dollars were awarded to companies with little or no prior
experience in producing the needed goods, including those in the arms industry or with
histories of fraud 11. In Slovenia, of the approximately 80 million euros in contracts
awarded in the last week of March 2020, thirty-five percent went to a firm controlled
by a mainstay of the gambling industry who had no previous experience in healthcare
(Delic and Zwitter, 2020). In Poland, over $60 million was wired to a supplier that never
delivered the medical equipment (Slattery and Brito, 2020).
Even if goods and services are delivered, they may be supplied at much higher
prices than in normal times 12. In Colombia, when officials began giving food boxes to
families hit by the coronavirus lockdown, one lawmaker noted the exorbitant prices
paid to vendors. An inquiry revealed that the state was paying more than double the
market price of certain goods, for example $2.81 for 250 grams of coffee that retailed
for $1.20 at grocery stores (Faiola and Herrero, 2020). Kenya’s anti-corruption
commission revealed a similar problem, with state agencies paying 60 percent higher
for goods than their market prices (Malalo, 2020).
In several countries, contracts awarded to those with ties to those in power
raised eyebrows. In the United Kingdom, contracts were given to companies whose
shareholders, board members, and employees include present and former high-level
public officials (Tabby Kinder, et al., 2020). South Africa’s ruling party was met with a
public uproar after the husband of the president’s spokesperson won PPE contracts
(Sishi and Winning, 2020). One study shows that local governments in Colombia with
historically high levels of corruption were more likely to award contracts to campaign
donors and experience cost overruns and inefficiencies during the COVID-19 crisis
(Jorge Gallego, et al., 2020).
Even after fraud schemes are discovered, it is sometimes difficult or impossible
to hold violators accountable and recover losses. Under-performing contractors may
be judgment-proof or have disappeared into a maze of shell companies leaving no
trace. The U.S. FBI identified numerous incidents of lost funds that were wired to
10 These incentives come on top of the background risks of corruption in procurement discussed in RoseAckerman and Palifka (2016, pp. 99-109). The relative bargaining power of public officials versus private
firm suppliers determines the level of payoffs, but may not affect their incidence.
11 See: Gabrielson, et al., (2020); Salman and Penzenstadler (2020); Gelles and Abrams (2020).
12 See: Malalo (2020).
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fraudulent contractors and subsequently flowed out of the jurisdiction of the U.S.
(Federal Bureau of Investigation, 2020).
Several types of responses are possible, but there is little systematic evidence
about how they might be prioritized or combined. The options include: opencontracting, pre-registration of suppliers, beneficial ownership information, freedomof-information acts, limits on conflicts of interest, oversight by public bodies, and
sufficient investigative resources to bring cases promptly and to protect and reward
whistleblowers.
A number of international organizations and NGOs have urged the use of open
contracting systems to combat corruption and fraud in procurement processes. As
summarized by Open Contracting, an NGO, governments should make emergency
procedures public, require written justification and documentation, and publish open
data on contract terms to permit civil society oversight on a timely and regular basis
(Open Contracting, n.d.; Amin, 2017). During the financial 2008 crisis, the American
Recovery and Reinvestment Act stipulated that procurement contracts not awarded
through fixed-price competitive bidding must be disclosed on a centralized online
platform (Congressional Research Service, 2009). The Open Government Partnership
points with approval to Ukraine’s anti-corruption reforms that oblige the open
publication of all emergency contracts, including terms of payment and delivery, and
value. Ukrainian civil society has developed a business intelligence tool to monitor
medical procurement and emergency spending. It can track price differences for
COVID-19 tests in the country’s regions and capital to check the price of critical
medical supplies to ensure that authorities are committed to filling treatment centers,
not private pockets (Gavin Hayma, 2020). It will be important to check if these reforms
are able to counter Ukraine’s otherwise high levels of corruption.
A complementary, strategy, used in Colombia, concentrates on pre-registering
suppliers. An emergency decree governs public procurement during the COVID crisis,
allowing expedited procedures to procure the necessary goods and services. The
National Procurement Agency, Colombia Compra Eficiente (CCE), has asked all
companies that want to supply these critical products to register. CCE verifies the
information and includes qualified suppliers in a framework agreement, allowing
agencies from all over the country to procure efficiently, and to compare online prices
and characteristics 13.
These measures could help limit conflicts of interest in times of emergency.
Any realistic set of rules needs to acknowledge that, especially in small countries or
for specialized procurements, there may be only a few domestic suppliers. Stringent
conflict-of-interest rules may give excessive bargaining power to the few firms
permitted to bid. Sometimes a better response is to permit many firms to bid and adopt
open-contracting rules that impose rigorous standards and oversight to assure value
for money. Procurement agencies need to face clear, written requirements to maintain
complete and accurate records and procedures for measuring the contractors’
suitability and performance (Office of the Inspector General for the U.S. Department
of Defense, 2015; Rose-Ackerman, 2014). If emergency circumstances make timely
publication of awards impossible, the contracting authority should publish a report after
the fact that justifies its decisions at the time (European Commission, 2020). Public
officials, on their part, should be required to place their shares in the companies
A summary is available at Submission to OECD COVID-19 Innovation Report: https://docs.google.com
/document/d/1Qy_7GwHMjIt71psdSkxPLwdxL3pdOEdIiiRY5D01c7Q/edit
13
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bidding for and benefiting from procurement contracts in a blind trust until the
expiration of the programs (Oldfield, 2020).
In order to check for fraud and to recover misused funds, governments and
civil-society watchdogs need to know the beneficial owners of the firms that obtain
contracts. Certain countries have cited the crisis as a reason to delay compliance with
transparency and beneficial ownership requirements. For example, the Financial
Crimes Enforcement Network (FinCEN) in the U.S. Department of the Treasury has
announced that for eligible federally insured depository institutions, Paycheck
Protection Programs (PPP) loans “will not require reverification” of existing customers’
beneficial ownership information “under applicable BSA (Bank Secrecy Act)
requirements, unless otherwise indicated by the institution’s risk-based approach to
BSA compliance” (Wolf, 2020). A similar weakening of the rules has occurred in the
Bahamas where the obligation to comply with the provisions of the Register of
Beneficial Ownership Act has been suspended during the public emergency and for
an additional 60 days after it has passed (Renee Farquharson, 2020). The Polish
government extended the deadline for registering beneficial owners, which already
had a low rate of compliance (Linklaters, 2020).
The weakening of transparency rules under the excuse of relieving the burden
on business can backfire. Such a policy exposes businesses and individuals to a
heightened risk of fraud and corruption, undermining the effectiveness of the
programs. Registries of potential suppliers and data on signed contracts must make it
possible to trace the beneficial owners of government contracts, especially if they
reside outside a jurisdiction’s borders 14. As a step in that direction, the IMF reports that
Gabon, Moldova, and Nigeria have committed to publishing information on crisisrelated public procurement and beneficial owners of companies contracting with the
government (International Monetary Fund, 2021). The IMF hopes to use these
programs as positive examples for others.
If the government’s own practices are lacking, civil society may be able to make
use of the Freedom-of-Information Acts (FOIAs) available in many countries. These
acts, which have spread globally in recent years, allow anyone –including ordinary
citizens, civil society groups, and the media– to request information from the
government (Ackerman and Sandoval, 2006). They can be potent tools if they do not
have too many open-ended exemptions and if the government promptly and
adequately responds to requests. Although up-front disclosure is a simpler and more
streamlined way to provide information, ex post FOIA requests can supplement opencontracting laws by assuring that the required information is available to the public.
Yet, during a crisis, responding to such requests may be a low priority. The
government may permit the temporary relaxation of FOIA rules to allow flexibility in an
emergency. Some jurisdictions have explicitly extended deadlines for responding to
requests until the pandemic is over, making it clear that FOIA requests will have no
priority 15. In the U.S., civil society groups have filed lawsuits against government
agencies that have declined to release information related to the pandemic
response 16. It remains to be seen if they will improve the effectiveness of FOIA in
checking abuse.
See: Open Ownership (2020).
See: Frary (2020); Office of the Governor State of Hawaii (2020); D.C. Policy Center (2020).
16 For example, see: Compliant for Injunctive and Declaratory Relief. Knowledge Ecology International v.
National Institutes of Health. Case No. 8:20-cv-2927. (United States District Court for the District of
Maryland, 2020). Available here: https://www.keionline.org/wp-content/uploads/1092020KEINIHFO
IAComplaint.pdf; Complaint. Pro Publica, Inc. v. United States Department of Health & Human Services.
14
15
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Some governments may delay meeting FOIA requests as part of an attempt to
quash reforms by citing the emergency as an excuse. Such actions risk making
corruption easier to hide in the short-run and can undermine government legitimacy if
malfeasance surfaces later. Severe economic pressure and the difficulty of obtaining
information can pose a double hurdle to local media and oversight groups. Hence,
prolonged and purposeful FOIA exemptions can have long-term consequences for the
quality of governance (Vittori, 2020).
Law enforcement investigations concentrate on criminal acts of fraud and
corruption, but some types of misbehavior also can be prosecuted as civil offenses
committed by private firms and as violations of civil-service rules and codes of ethics.
In the U.S., various government institutions, including the Departments of Justice
(DOJ), Homeland Security (DHS), and Health and Human Services, can bring anticorruption and anti-fraud actions related to the Covid-19 crisis, including under the
Foreign Corrupt Practices Act (FCPA), which criminalizes the payment of bribes to get
business abroad 17. Nevertheless, even in the U.S., the investigative capacities of
government institutions remain limited relative to the magnitude of government
financial outlays.
Because many types of fraud and corruption have willing participants on both
sides, it is especially important for prosecutors to be able to encourage and protect
whistleblowers (Rose-Ackerman and Palifka, 2016, pp. 219-221). The survey of antifraud professionals cited above indicates that whistleblower retaliation occurred in
almost half of the countries surveyed (46%), and the problems to which whistleblowers
pointed were diverse (Nemexis, 2020; Feinstein, 2020). Even if a whistleblower law
exists, it may only protect a narrow range of individuals and disclosures, and the
measures to protect the rights of whistleblowers may be inadequate (OECD Webinar,
2020, May 22). The United States generally has stronger protections for
whistleblowers than many other countries, and private-sector whistleblowers can earn
bounties from reporting malfeasance involving public contracts. Nonetheless, that
system does not always work fairly. For example, when a former Florida Department
of Health employee alleged that she was fired after refusing to manipulate COVID-19
data, Florida law enforcement raided her home under the charge that she attempted
to “hack” the department by trying to log in with expired credentials (Ceballos, 2020;
Chappell, 2020).
In a rapidly evolving crisis, normal procedures that take months are unlikely to
allow timely disclosure and actions. If a crisis results in severe economic stress,
whistleblowers may be even more reluctant to engage in behavior that might cost them
their jobs (OECD Webinar, 2020, May 22). If existing protections are insufficient, it is
important for the legislature to include special whistleblower protections in emergency
stimulus programs and to send consistent messages to the public stressing that
reporting malfeasance is important and appreciated.
Controlling price gouging needs a nuanced approach. There may be genuine
shortages of certain products that produce temporary price increases. Although
opportunistic cartels should be punished, price limitations may create a black market,
and severe punishments can discourage the production of needed goods. However,
the government can limit the upward pressure on prices by coordinating and
centralizing procurement processes. State and local governments can leverage their
Case No. 20-4092 (United States District Court for the Southern District of New York, 2020). Available
here: https://www.documentcloud.org/documents/6935608-2020-05-28-DE-001-Complaint-DMWEST40181066.html.
17 See: Office of the Attorney General (2020); Department of Homeland Security (2020); Department of
Health and Human Services, Office of Inspector General (2020).
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collective buying power, while the national and federal government can assist with
coordination and sourcing back-up supplies (Folliot Lalliot and Yukins, 2020).
Nonetheless, relying solely on market mechanisms is not the solution. Aside
from the grave ethical implications of allowing chances of survival to depend upon
existing privileges, a pure market-based allocation is also inefficient in harnessing the
positive externalities of certain healthcare benefits. Furthermore, because of the social
consequences flowing from the allocation of scarce benefits, their distribution should
be made systemically, not left to the decisions of individual physicians.
The allocation method should depend upon the nature of supply as well as
distributive justice concerns. As in wartime, ration tickets, lotteries, or application
procedures may be necessary. During a pandemic, ensuring the supply of personal
protective equipment and vaccines to medical and essential workers and then
rationing their availability to others would be more effective in controlling the spread of
the virus than leaving them accessible only to the well-resourced (Glazer, 2020). Firstcome-first-served also has little to recommend it on the grounds of either fairness or
efficiency, and it can incentivize some to use unofficial and illegal means to get ahead
in the line (Meskell, 2020).
Any approach should take into account the principle of fairness and the
possible spillover of benefits, with appropriate safeguards against corruption (Bloom,
2020; Bersad et al., 2009). Ideally, the allocation would be based on criteria that are
easy to identify in order to minimize the room for discretion and manipulation. But when
faced with an overwhelming demand from a practically indistinguishable group of
people, a lottery system is an alternative that is fair and can be less susceptible to
corruption if operated under transparent rules (Emanuel et al., 2020; Kenen, 2020;
Vogel, et al., 2020). Clear communication to the public on the need for and basis of
the rules of distribution would be key to preserving the legitimacy of the intervention
and reducing the motivation to bypass or disobey the rules.
An additional benefit of using a lottery to allocate a scarce experimental
treatment is that it also has scientific merit. Faced with scarcity, all eligible patients are
treated fairly in that all have an equal chance of being selected. In addition, as two
medical doctors point out, the lottery itself provides information about the efficacy of
the treatment. It permits a comparison between those who do and do not receive the
treatment. If there is a reason to prioritize certain types of patients, such as front-line
healthcare workers, then the lottery itself can be designed to give them a higher
chance of selection (White and Angua, 2020). This example illustrates the value of
nonmarket allocation methods and the need to prevent corruption and cronyism from
undermining such methods. Leaving these choices in the hands of individual
physicians, risks cronyism and corrupt side deals. Corrupt access is not only is unfair;
it also prevents an adequate test of the treatment’s value in the population.
3. Rapid Allocation of Government Assistance to Individuals and Businesses
Many countries have set up programs of financial aid for households and business.
The rapid rollout of emergency payments to individuals and firms amplifies bribery,
fraud and embezzlement risks. Improper management of public funds can take various
forms, including payments for access to medical services, payments to re-open
businesses or avoid enforcement actions, payments to receive preferential forms or
amounts of government assistance, and self-dealing or kickback schemes. The
particular difficulty here is the large number of beneficiaries so that individual lawenforcement efforts are likely excessively costly, and lawmakers are subject to
heightened interest group pressure as businesses try to shape the distribution of
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benefits in their favor (Vogel, et al., 2020). Studies show that in the first quarter of
2020, when the U.S. Congress was debating the $2 trillion Coronavirus Aid, Relief,
and Economic Security (CARES) Act, lobbying expenditures noticeably increased
across different sectors, with the health sector’s spending and registrations rising most
rapidly (Olson, et al., 2020).
It is especially important to limit corrupt incentives up-front in the fundamental
structure of stimulus programs. That may mean keeping the eligibility standards simple
and clear-cut, even if they would not be the ideal standards in a perfectly honest world.
For example, a World Bank study notes that in regions where the state’s administrative
capacity remains weak, categorical targeting based on easily observable
characteristics that are highly correlated with poverty can substitute for eligibility
criteria that are more difficult to measure, such as income (Tabor, 2002). Regardless
of which criteria are used, information about eligibility and the scope of benefit should
be easily accessible and be accompanied by outreach to enhance public
understanding of the intended beneficiaries (United Nations Office of Drugs and
Crime, 2020, p. 2; Ellena, Brown and Dreher, 2020, p. 13).
However, ex post monitoring and review remain important. Unfortunately, in
the U.S. there appear to be weaknesses in the CARES Act’s oversight mechanisms.
Oversight is a necessary condition to prevent malfeasance and to punish those who
step over the line. The CARES Act mandates that the program will be overseen
through three key mechanisms: the Congressional Oversight Commission, which
submits monthly assessments of the Department of the Treasury’s $500 billion
stabilization fund; the Pandemic Response Accountability Committee, which oversees
the implementation of the CARES Act to detect and prevent fraud, waste, and abuse;
and the Special Inspector General for Pandemic Recovery, nominated by the
President to report on the appropriateness of the spending by the Treasury
Department (Mellman and Eisen, 2020).
Even though the act was passed in late March 2020, the Special Inspector
General, who is supposed to oversee the Treasury Department’s activities, was not
confirmed by the Senate until mid-June, more than two months after the CARES Act
was signed (Rappeport, 2020). The chairperson of the Congressional Oversight
Commission had not been confirmed by mid-February 2021 (Congressional Oversight
Commission, 2021). After President Trump removed the initial chairperson of the
Pandemic Response Accountability Committee, a group of 21 inspector generals
(IGs), the committee went ahead without an officially appointed new chairperson. The
group is now led by the IGs from the Department of Justice and NASA (PRAC, 2021;
The White House, 2020, March).
Past emergencies illustrate how difficulties can arise. Consider Hurricane
Katrina in the U.S. and the Ebola epidemic. Hurricane Katrina made a direct hit on
New Orleans in August 2005. As reported by The Hill, the Government Accountability
Office estimated that by June 2006 approximately $1 billion in Hurricane Katrina aid
was improperly distributed and potentially fraudulently obtained. By 2011, 1,439
people spanning 41 federal districts were federally charged with hurricane related
fraud against the government. By 2014, the seventeenth New Orleans area public
official had been arrested on federal corruption related charges, including a school
board member, a state senator, a state representative, a judge, multiple city council
members, a coroner, and multiple mayors. To this day, it is unclear how much aid from
Hurricane Katrina was lost to fraud and corruption (Cortese, 2020).
Ebola hit West Africa in 2014-2016. The International Red Cross estimated the
cost of corruption associated with the outbreak in Guinea and Sierra Leone to be more
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than US$6 million. Reports show that the Ebola epidemic resulted in the diversion and
mismanagement of funds, misreporting of salaries, payments for duplicate supplies,
and bribery of health professionals to receive medical care and leave quarantined
zones (Divjak and Dupuy, 2015).
To complement and encourage low-income countries to spend responsibly,
multilateral and bilateral donors could incorporate stronger anti-corruption measures
into aid packages. Earlier this year, the IMF and World Bank were flooded with
requests for foreign assistance 18. The multilateral lenders have maintained that all
funds will be subject to pre-existing integrity requirements, perhaps, in part, due to
continued lobbying by several anti-corruption NGOs. As the IMF Fiscal Affairs
Department stated in 2020: “Do what it takes, but keep the receipts” (International
Monetary Fund Fiscal Affairs, 2020). Its Managing Director stated that “We don’t want
accountability and transparency to take the back seat” (International Monetary Fund,
April 15, 2020). The IMF notes that 58% of all financial agreements contain specific
commitments to control the risk of corruption, such as auditing of COVID-19 spending
and publishing procurement information (Berazategui, 2020; International Monetary
Fund, 2020, June 30).
These signaling and voluntary commitments are not sufficient to ensure that
the funds will be spent responsibly, especially in countries with histories of endemic
corruption. Careful documentation of spending is a necessary condition for
accountability, but is it sufficient? What does “do what it takes” mean? It signals the
IMF’s deference to member countries’ choices about how to respond, but in many
cases, that may simply cement connections based on cronyism and patronage.
Although one can understand the unwillingness of the IMF to get involved at the micro
level in directing policy, citizens within individual countries and organized business,
labor and civil society should not be content with ex post accountability alone. Even if
no bribes were paid, outright fraud can occur in cases where receipts exist but where
the contracted-for supplies were not delivered or were defective.
Several measures have been proposed to control the risk of corruption in
foreign aid. In the US, the Carnegie Endowment has highlighted the Countering
Russian and Other Overseas Kleptocrats (CROOK) Act (H.R. 3843/S. 3026). The bill
would form an Anti-Corruption Action Fund to rush support to countries eager to take
rapid action against corruption, as the current crisis demands (Bellows, 2020). The
proposal is budget-neutral and enjoys bipartisan support. However, as one observer
notes, the CROOK Act does not address the causes of corruption arising from
personal interactions and discretion created by various trade barriers and other
distortionary regulations (Koehler, 2020). A draft bill passed by the Senate in 2019
would have required the State Department to assess corruption risks in countries
receiving certain U.S. foreign aid and develop appropriate anti-corruption
mechanisms 19. This year, Germany’s development ministry announced a plan to
reduce the number of aid recipients and make good governance, respect for human
rights, and tackling corruption the criteria for future aid cooperation (Deutsche Welle,
2020, May 5). Other suggested mechanisms include linking the disbursement of aid to
evidence of outcomes, such as testing and vaccination levels (Loayza, 2020).
Although it is true that states vary in their capacity to enforce rigorous oversight,
most states have the infrastructure and resources necessary for a basic level of budget
controls. In the past and during the current pandemic, donor countries and agencies
See: World Bank Group (2020, May 19); International Monetary Fund (n.d.)
Combating Global Corruption Act of 2019, S.1309, 116th Cong. (2019). Available here:
https://www.congress.gov/bill/116th-congress/senate-bill/1309/text
18
19
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were able to work with local governments to develop tracking systems to identify
intended beneficiaries of relief programs (International Monetary Fund, 2020, May 19).
Oversight in times of crisis is not a privilege reserved for developed countries. If they
centralize and streamline crisis response spending, minimize extra-budgetary funds,
and introduce ex-post verification, even low-income countries can significantly reduce
lost resources.
4. Pharmaceutical Licensing and Insider Trading
The pandemic has generated a flood of new money into drug research and
development, most of it from public sources. The speed with which policymakers are
seeking solutions to the pandemic creates opportunities for companies to bypass the
usual regulatory review to get drugs to market or into publicly financed programs. It
can also help some drug developers to secure preferential treatment for not only
licensing but also favorable tax treatment and other benefits. At the same time,
intellectual property laws limit transparency in product development, reducing the
ability of third parties to challenge company behaviors.
One type of favorable treatment is “fast-tracking”. For example, U.S. Food and
Drug Administration (FDA) rapidly granted Gilead Sciences “orphaned drug status” for
an experimental drug to treat COVID-19, a designation usually reserved for drugs
treating rare diseases. That status comes with market exclusivity, tax breaks, and the
waiving of regulatory fees (Chua and Cont, 2020). The company eventually gave up
that status following outcry (Lupkin, 2020). The U.S. federal contracting standards for
subsidizing medical research during the pandemic could weaken the government’s
ability to license generic competitors if the subsidized company fails to make the
product accessible on reasonable terms (Rowland, 2020). Under normal
circumstances, the business practices of this industry have raised ethical concerns,
and during the pandemic private companies may use this opportunity to enrich
themselves at the expense of the public interest.
The promising vaccines now receiving regulatory approval suggest that the
pandemic may be tamed in 2021, but it will be important for governments to remain
vigilant. Of course, drug firms should be able to make a profit from their discoveries,
but they should not exploit the vulnerable positions of governments and patients,
especially in low-income countries.
Insider trading may be a concern. Four U.S. Senators were publicly accused
of insider trading after it appeared that they personally profited from trades following a
private all-senators coronavirus briefing (Lipton and Fandos, 2020) 20. This prompted
the Securities and Exchange Commission to issue a warning on non-public material
information related to the virus (Avakian and Peikin, 2020).
Medication and medical device production chains frequently extend across
national boundaries, but the COVID-19 crisis has disrupted regular patterns of
manufacture, sale, and export. As mentioned earlier, the need to contract with new
vendors in an emergency can circumvent normal due-diligence processes. The
imperative to obtain healthcare supplies as quickly as possible may stimulate the
payment of bribes, for example, by company agents to regulatory and customs
officials. Law firms are quick to point out that firms that respond rapidly potentially
expose themselves to liability under foreign bribery and anti-money laundering laws 21.
20
21
Three cases were closed in May 2020.
For example, see: Kostolampros, et al. (2020).
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Open-contracting initiatives and beneficial ownership registries can be helpful here,
just as they can be for any kind of procurement.
But the corrupt incentives go deeper than in other types of procurement
because of the distinctive features of the healthcare sector. The risks arise not just
from the need for speed and the possibility of privileged insiders obtaining special
benefits. In addition, consumers’ lack of expertise, and the moral hazard and adverse
selection that characterize insurance markets can raise the stakes in the fight against
corruption in the pandemic (Arrow, 1963; Powell and Goldman, 2020). The study of
corruption always raises the question of when to use the price system and the private
market to allocate scare goods and services and when to select allocation methods
based on desert, efficacy, or over-all social value. Poor information about the future is
a problem for everyone and can lead to fatalism or to the creation of insurance markets
to spread the risk over a certain population –for automobile accidents, life expectancy,
risks of fire and theft– and, of course, healthcare.
Poor information, however, is not the only problems. In addition, the same
dollar price represents a trivial outlay to one person and a major sacrifice to another.
The private market is a poor mechanism for the redistribution of income to those at the
bottom. Furthermore, if consumption by one person creates spillover benefits and
costs for others, the purchaser may not take these external effects into account. Some
commodities cannot be parsed into individual consumption bundles. They are
consumed in common. Even if a vaccination provides a personal benefit to an
individual, a widespread vaccination program benefits even those who do not choose
to get a shot.
The healthcare sector is a prominent illustration of these distributive effects and
market failures. Thus, even without the overlay of a pandemic, an unregulated
competitive healthcare market is neither efficient nor fair. Rather, public policies should
accommodate both distributive justice concerns and take account of informational
weaknesses and external effects. In fact, the healthcare sector is hedged about with
public programs and regulations in all polities. Health insurance is a complex mixture
of public and private provisions in most countries, although a few have sought to
outlaw both private provision and private insurance. For healthcare, where scarcity
combines with regulation and where the public sector determines who is qualified to
provide and to receive treatment, corrupt incentives exist in ordinary times and have
increased during the pandemic 22.
For health insurance, responding to the problems of moral hazard and adverse
selection can create corrupt incentives. Consider moral hazard. Individuals may
demand healthcare with little concern for the social costs if their own out-of-pocket
costs are low or nonexistent. However, there is an opposite force at work during the
pandemic. Prevention and treatment are troublesome and costly for individuals, but
the benefits of their actions are partly felt by other people who face less risk of
exposure because of others’ preventive actions. These external benefits are a strong
justification for requiring individuals to take costly actions that benefit both themselves
and others. Because some of these benefits flow to strangers, individuals may not take
them into account. To some extent, the two effects may balance out, but unfortunately,
actions that protect others are not always the same as the ones that benefit yourself,
your family, or your religious community. Thus, corruption and other types of shirking
will predictably occur in those situations. For example, a restaurant owner might pay
off inspectors to cut corners on sanitizing the premises and might fail to purchase
For example, before the pandemic, pharmaceuticals and medical equipment became major profit
centers for Chinese hospitals and suppliers paid bribes to get contracts (Rose-Ackerman and Tan, 2015).
22
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effective personal protective devices for staff. Suppliers of such devices might pay off
officials to get approval for inadequate products that can be sold as compliant. Police
may let people avoid lockdowns and quarantines in return for bribes 23. Businesses
using these products have little incentive to check them for efficacy partly because
they do not have the expertise to make quality judgments and partly because their
main concern is to attract customers by claiming to follow government guidelines.
Now consider adverse selection where low-risk individuals opt out of insurance.
One response to this problem is to require everyone to obtain coverage or to charge
a fee to those who opt out, as was done in the original version of the U. S. Affordable
Care Act 24. If governments enact such rules, low-risk individuals could make payoffs
to avoid a citation for non-compliance, or they might avoid a fine through paying a
bribe. This incentive exists under any effort to avoid adverse selection, but it has
additional costs during a pandemic. Now, low-risk individuals who opt out may infect
others if they do become sick. Those who opt out may include, not only those at lowrisk, but also those who are more tolerant of risk than the average person. If that is
true, the external costs of their lack of insurance will be especially socially harmful if
they do become infected. Adverse selection can lead the entire insurance program to
unravel as the refusal of some low-risk people to join increases the overall risk of the
program, causing the newly marginal people to exit and so forth. In contrast, if those
who opt-out are not low risk but rather have a high tolerance for all levels of risk, then
the insured pool will not unravel. It will just cover fewer people. However, that latter
version of adverse selection will be especially damaging in the context of a highly
contagious disease. Now, risk-acceptant people with no social conscience may spread
the virus to others who are either more risk averse or more susceptible to catching the
disease and/or have life-threatening health conditions. Thus, once again there is a
strong case for requiring everyone to take precautions and to have insurance
coverage. The goal is not just to spread the costs broadly but also to implement
preventive measures. Denying care or charging for uninsured healthcare may provide
an incentive to sign-up, but those who remain outside the insurance system are
imposing costs on others. The penalties need to reflect the external costs imposed by
the uninsured on everyone else. However, if the program did reflect those costs, the
individual incentives to seek an exception through corrupt payoffs could be high.
Corrupt officials could register individuals in the program even though they had paid
nothing to the regulatory authority. Alternatively, if the state makes insurance free to
all so that no adverse selection occurs, moral hazard will remain a problem. Then, the
incentives for corruption are identical to those that arise whenever the government
provides a public service that can vary in quality across beneficiaries. Corruption would
be an allocation mechanism that favors the wealthy and the unscrupulous, as occurred
in the healthcare system of Eastern Europe after the fall of the socialist systems. In
those countries, healthcare remained a public responsibility but was not funded well
enough to satisfy middle-class demands (Rose-Ackerman, 1995; Kornai and
Eggleston, 2008; Stepurko, et al., 2015). As a result, a flourishing, but illegal private
market for healthcare existed in many countries that permitted the old system to
survive, but at low quality and with vastly unequal levels of care. If that system had
coincided with a pandemic, the result could have been tragic.
See: Transparency International (2020).
The mandate under the Affordable Care Act levied a fee on those who did not sign up for insurance
under the ACA or for an equivalence or better plan. That portion of the act was repealed, effective in 2019
(Eibner and Nowak, 2018).
23
24
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5. Conclusions
The political economy of the coronavirus pandemic has created incentives for
corruption, fraud, and self-dealing. Along with the generous behavior of many millions
of front-line workers, government officials, and private individuals and firms, others
have sought to take advantage of the situation to benefit at the expense of the public
and of victims of the pandemic. This anti-social behavior is readily explained by the
underlying economic incentives at work in a health-related crisis where government
must act quickly in a haze of uncertainty about the best path forward. Unlike other
sorts of catastrophes, related to the weather, earthquakes, or volcanic eruptions, a
health emergency raises special problems. Patients face problems of moral hazard
and adverse selection that undermine free market solutions and demand a public
sector response, even in ordinary times. Furthermore, neither a vaccine nor an antiviral medicine existed when the coronavirus began to spread worldwide. The rapid
response of pharmaceutical researchers produced several vaccines in record time,
but this effort co-existed with both fraudulent cures and over-priced or useless
protective equipment.
Although some malfeasance was probably inevitable in a pandemic, it should
not be ignored. Overall, those who benefit from corruption, be they contractors or
individuals, will emerge from the pandemic better off than before it started if
governments do not act. Tolerance of malfeasance will be at the expense of long-term
government legitimacy and lead to the spread of the virus to the most vulnerable. The
need for a speedy response should not be an excuse for undermining institutions that
strengthen governmental integrity.
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