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How Immigrants, Poor People, Minorities and Children are Modern-Day Guinea Pigs for Big Pharma

"The concentration camps were used as a huge laboratory for human experimentation," says Wolfgang Eckhart, professor of Historical Medicine at the University of Heidelberg in Germany. During the Holocaust, Bayer, Hoechst, BASF and other German pharmaceutical and chemical companies combined into a powerful cartel known as Interessengemeinschaft Farbenindustrie Aktiengesellschaft (IG Farben). As well as manufacturing everything from the deadly gas used to kill Holocaust victims, the gasoline used to move war vehicles and the explosives used to bomb enemies and conquer Europe, IG Farben was also trying its best to put a large number of highly profitable new drugs on the market and used concentration camp prisoners as human guinea pigs to do so.

Now, over 60 years after the Holocaust, we'd all like to think that society is above such cruelty, but in reality, human experimentation is still a common practice in modern medicine. Big Pharma operates by many of the same rules and motives as IG Farben did, and the test subjects are still the most vulnerable members of society -- the poor, immigrants, minority groups and children.

"Few doctors dispute that testing drugs on people is necessary. No amount of experimentation on laboratory rats will reliably show how a chemical will affect people," David Evans, et al. writes in the Bloomberg article "Drug Industry Human Testing Masks Death, Injury, Compliant FDA". Doctors have recognized the importance of human experimentation since the days of Hippocrates, though the ancient Greeks used it to benefit individual patients rather than science itself or any profit-driven industry. In 1833, William Beaumont, the army surgeon physician who pioneered gastric medicine with his study of a patient who'd sustained a gunshot wound that left his digestive system permanently exposed, established the importance of human experimentation as long as it is with the subject's consent.

However, sometimes it's difficult to find human test subjects, especially for studies involving pain or high risk. In the 1930s, research scientists discovered a solution to their difficulty in finding willing test subjects: Don't ask for their consent. In the infamous Tuskegee Syphilis Study, the United States Public Health Service diagnosed 200 black men with syphilis and, rather than treating or even informing them of their illness, used them as human guinea pigs to study the symptoms and progression of the disease. Today, as the University of Virginia Health System writes in its online documentary "Bad Blood", "The Tuskegee Syphilis Study has become a powerful symbol of racism in medicine, ethical misconduct in human research, and government abuse of the vulnerable."

During the Holocaust, IG Farben trumped the moral depravity of the Tuskegee Syphilis Study. Why use and abuse only 200 unwilling human test subjects when you can choose from the multitudes imprisoned in Nazi concentration camps? IG Farben callously used concentration camp inmates of all ages for painful, debilitating and often deadly experiments. Because of this, medical experimentation has become synonymous with injustice, cruelty, prejudice and total disregard for human life. Today, few people would try to justify or support IG Farben's medical experiements, but the sad truth is that modern human medical experimentation is in many ways similar to the horrors carried out by IG Farben.

Experimental drug testing centers During the Nuremberg Trial, Dr. Waldemar Hoven, the Nazi doctor who gave lethal injections to his patients at Buchenwald, gave the following account of the medical experiments he and other concentration camp physicians performed: "It should be generally known, and especially in German scientific circles, that the SS did not have notable scientists at its disposal. It is clear that the experiments in the concentration camps with IG preparations only took place in the interests of the IG, which strived by all means to determine the effectiveness of these preparations. They let the SS deal with the -- shall I say -- dirty work in the concentration camps. It was not the IG¹s intention to bring any of this out in the open, but rather to put up a smoke screen around the experiments so that ... they could keep any profits to themselves. Not the SS but the IG took the initiative for the concentration camp experiments."

Like IG Farben, Big Pharma doesn't perform its own experiments. Instead, it doles out the "dirty work" to experimental drug testing centers, some of which confine test subjects for portions of the study. In a Bloomberg article entitled "Miami Test Center Lures Poor Immigrants as Human Guinea Pigs", Argentinian immigrant Roberto Alvarez describes the eight days he spent confined to the Miami-based SFBC testing center: "It can be weird
inside. It's like a jail."

In many ways, it is like a jail. In Miami's SFBC, which is the largest center of its kind in North America, test subjects sleep six to a room in double-decker beds. They even have uniforms to wear -- purple drawstring pants and T-shirts, much like the uniforms of concentrate camp victims. Dr. Hoven's criticism of IG Farben's experiments in Nazi concentration camps could easily be directed to Big Pharma's human experiments. In fact, it has. "Some test centers, FDA records show, have used poorly trained and unlicensed clinicians to give participants experimental drugs. The centers ... sometimes have incomplete or illegible records," David Evans, et al. writes.

Informed consent?

Even though the FDA has required informed consent of test subjects since 1981, many people believe that researchers often don't fully explain risks and potential side effects, so as not to deter potential test subjects.

"Human subjects are in very short supply, so it's not surprising that under the growing pressure to find them, there are sometimes terrible ethical violations," says Marcia Angell, who was editor-in-chief of the New England Journal of Medicine from 1999 to 2000. The centers meet the legal requirements of informed consent by providing an informed consent form, but the form may be written in a language the potential subjects do not fully understand because they are immigrants, who make up a large portion of human test subjects. Even if they are written in the subjects' native language, the forms may be long and dominated by obscure technical jargon. In "Drug Industry Human Testing Masks Death, Injury, Compliant FDA", Argentinian immigrant Roberto Alvarez admits, "The thing I pay most attention to when filling this thing out is this: How much it pays and how long it takes. I don't read them too carefully," while skimming through a 12-page consent form.

The Nazi doctors didn't even bother with consent forms. Why waste time when you can just force-feed concentration camp inmates a pill or inject them with an experimental substance? "I remember one of the SS doctors holding my jaw open and forcing pills down my throat," Auschwitz survivor Zoe Polanska Palmer told BBC Radio 4 reporter Mark Handscomb in It's My Story. Granted, giving potential subjects long consent forms written in language they can't fully understand is better than shoving pills down someone's throat, but it still seems unethical and it can still put human life at risk.

Even Kenneth Lasseter, the executive medical director of the SFBC experimental drug testing center, admitted in the Bloomberg article, "It's clear to me. Perhaps it needs to be explained more." Lasseter was speaking of the consent form for an experimental drug that may treat overactive bladders. "The goal of this study is to determine the highest daily dose of TD-6301 that will not cause an undesired increase in heart rate." Yes, that wording may be clear to Lasseter, but it may not be clear to the average test subject. "They're saying it backwards to a population that may not be of the highest education level. The real purpose of the study is, 'We're going to make you sick in order to find out at what level you get sick when given this drug.' Obviously, they don't want to say that," University of Miami bioethicist Ken Goodman told David Evans, et al..

Preying on immigrants and other poverty-stricken individuals During the Holocaust, the Nazis confined the marginalized sectors of society
-- Jews (including children), gypsies, homosexuals, the mentally ill and the mentally retarded -- into camps that became human guinea pig-filled laboratories for IG Farben's experimental drug studies. Today, marginalized populations still make up a large portion of experimental drug test subjects; however, socioeconomic factors, rather than concentration camp authorities, make them more likely to sell their bodies to Big Pharma.

It's no accident that SFBC, the largest experimental drug testing center in North America, is located in Miami. According to the St. Petersburg Times, Miami-Dade County "is the only county in the country where more than half the residents are foreign-born." After immigrants come to Miami from countries like Cuba, Colombia, Haiti, Nicaragua, Jamaica, Argentina and Mexico, they need money, yet experience the employment limitations that little or no fluency in English, little education, unfamiliarity, prejudice and, in some cases, lack of a work permit brings. With few other options available, these immigrants find one of the few legal jobs that doesn't require any amount of English proficiency or education and may even accept forged social security cards: Professional guinea pig.

Many immigrants participate in multiple, simultaneous drug studies.

Combining these experimental drugs is a recipe for disaster "because researchers don't know how the different chemicals interact or what side effects the mix may have on a person," according to the Bloomberg article "Miami Test Center Lures Poor Immigrants as Human Guinea Pigs". However, given the fact that some studies only pay $25 per day, what else are the truly marginalized subjects supposed to do? "It's not the job I would choose, but financial circumstances require you to do it sometimes,'' Venezuelan immigrant Oscar Cabanerio told Bloomberg.
Originally published March 7 2006
Human medical experimentation on children: The exploitation of poor children by Big Pharma (part two)

The crimes committed against children define some of the Holocaust's most morally despicable horrors. In It's My Story, Palmer told Handscomb of the abuses she received as a 13-year-old at Auschwitz. As a result of the damage done to her body by the contraceptive drug experiments forced upon her at Auschwitz, she had to undergo several painful surgeries immediately following the war and, even after the surgeries, Palmer remained unable to bear children for the rest of her life. Today, in her 70s, Palmer has cancer.

Now, no one can say for certain whether or not Palmer's cancer is linked to the medical experiments she underwent roughly 60 years earlier, but it is a likely possibility. Exposure to drugs and other chemicals produces extremely negative effects on children, especially those who are even younger than Palmer was during the experiments.

In the April 2004 Pediatrics article "Trends in Environmentally Related Childhood Diseases," Tracey Woodruff, et al. writes, "Children may be particularly susceptible to exposures in utero or during early life because the fetus' or young child¹s physiology is undergoing rapid development, such as rapid cell division, changing metabolic activity, and evolving hormonal systems."

With this in mind, running experimental drug studies on children seems especially dangerous and thus horrendous, yet it is still a common occurrence even in modern society. In her Nov. 30, 2004 BBC News article "Guinea Pig Kids" and her subsequent documentary of the same name, Jamie Doran reveals New York City's Administration for Children's Services' (ACS) little-known practice of using HIV-positive children kept in the city's orphanages and foster care homes as human guinea pigs for experimental AIDS drugs. For his documentary and article, Doran interviewed Jacklyn Hoerger, a pediatric nurse who worked at the Catholic Church-run Incarnation Children's Home in Harlem. Hoerger maintains that social work authorities never told her that the drugs she and the other Incarnation employees were administering the orphans and foster care children were experimental. "We were told that if they were vomiting, if they lost their ability to walk, if they were having diarrhea, if they were dying, then all of this was because of their HIV infection," she said to BBC.

In reality, these symptoms were due to the experimental drugs that the workers were giving them. When BBC asked him his opinion on the experimental drug studies done on New York City's orphans and foster children, University of Berkeley visiting scholar Dr. David Rasnick explained, "We're talking about serious, serious side effects. These children are going to be absolutely miserable. They're going to have cramps, diarrhea and their joints are going to swell up. They're going to roll around the ground and you can't touch them." According to BBC reporter Doran, Dr. Rasnick went on to call the experimental AIDS drugs that were given to the children "lethal." If children refused to take them by mouth, workers at Incarnation force-fed them the drugs through feeding tubes inserted into their stomachs. It's no doubt that these HIV-positive and AIDS symptomatic children needed medication. The question is why were they given experimental drugs, rather than the same medications that a child living in an expensive brownstone on the Upper East Side would have received? In the words of Alliance for Human Research Protection spokesperson Vera Sherav: "They tested these highly experimental drugs. Why didn't they provide the children with the current best treatment? That's the question we have. Why did they expose them to risk and pain, when they were helpless? Would they have done those experiments with their own children? I doubt it." Furthermore -- when you consider the fact that, according to the BBC article, 99 percent of the children in New York City children's homes are either African American or Hispanic -- issues of race and prejudice also come into play.

Hoerger told BBC that she didn't realize what was going on until she later took two children from Incarnation home as foster children. As a trained pediatric nurse, she decided to take the two children she was caring for in her home off the medications given to them while at Incarnation. This resulted in "an immediate boost to their health and happiness," according to BBC. However, soon after her decision, ACS came to her home and took the children out of her care. She was then labeled a child abuser in court and, after that, she never saw the children again.

Performing medical experiments on children is a serious accusation.

Realizing this, while working on his documentary and article, Doran went to Incarnation for its side of the story, but it only referred him to its public relations firm. The expensive Manhattan firm told him that it didn't give comments about what goes on inside the home. In light of these accusations, former ACS Commissioner John B. Mattingly ordered a comprehensive review of all ACS records. By early April, based on the records they had examined, ACS staff members revealed just how common the experimentation Hoerger described at Incarnation was throughout the city:

* Between 1988 and 2001, 465 foster care children and orphans were used in experimental AIDS drug trials.

* Most of these children participated before 1996.

* The majority of HIV-positive children living in New York City were diagnosed from the mid-1980s through the mid-1990s.

* The highest number of AIDS-related deaths among New York City children happened from 1990 to 1995.

* The 465 children used in the studies were in approximately two dozen different independent agencies operating under contract to ACS.

Then, on Apr. 22, 2005, ACS sent out a press release stating that it had "contracted with the Vera Institute of Justice to conduct an independent review of ACS policy and practice regarding the enrollment of HIV-positive children in foster care in clinical drug trials during the late 1980s and 1990s." It also asserted: "The last child to enter an HIV-related clinical trial while in foster care did so in 2001. There are no ongoing HIV-related clinical trials involving children in foster care in New York City." This directly contradicts the conclusion Doran writes in his 2004 article: "The experiments continue to be carried out on the poor children of New York City."

ACS maintains that it ordered the studies with the best interest of HIV-positive children in mind. "The purpose of the drug trials was to develop effective treatments for pediatric AIDS, at a time when there were no known, FDA-approved medications available to treat children with the disease, and many children were dying," reads the press release. As proof of the gravity of the AIDS crisis ACS faced when conducting the trials, the press release cites the following figures from the New York City Department of Health and Mental Hygiene:

* Out of the 13,927 HIV-positive children under age 13 nationwide prior to 2003 (according to CDC estimates), the percentage of HIV-positive children in New York City was "the highest by far of any jurisdiction in the country."

* From 1979 through 2003, 3,634 children living in New York City and under the age of 13 were HIV positive.

Even though ACS believes that its decision to give the experimental AIDS drugs to the 465 foster children and orphans was not wrong, it is nevertheless ordering the Vera Institute to conduct the independent study, so as to assure the public and the media. As Commissioner Mattingly explained, "We are taking this step because, while we believe that the policies in place at the time reflected good practice, we acknowledge the need for transparency in all of our dealings with the public. In order for us to be effective in our mission to protect New York City¹s children, we must have a sense of mutual trust with those families we seek to serve." According to the press release, the Vera Institute "will research ACS policies and procedures to ensure that HIV-positive children and children with AIDS who were in the care of ACS were appropriately enrolled in the correct clinical drug trials." This includes finding out whether:

* ACS obtained consent from the children's parents or other guardians before enrolling them in the experimental drug studies.

* The children enrolled in the trials met the medical criteria to do so.

* ACS adequately and properly monitored the children who were enrolled.

* Enrollment was "appropriate based on sound medical knowledge at the time."

As of an Oct. 5, 2005 update to its web site regarding the analysis, the Vera Institute still had not completed its investigation. It writes that it is "assembling an advisory board of medical, child welfare, legal, and community experts to review our findings and assure the public of the independence of our research." Meanwhile, in its description of the project, the Vera Institute acknowledges both sides of the controversy:

"Opponents of involving foster children in clinical trials -- where the risks and benefits are often unknown -- worry that this highly vulnerable population may be too-easily neglected or even exploited. When it comes to children of color, in particular, they point to historic examples where the health care system has acted in discriminatory and prejudicial ways.

"On the other hand, those who favor including foster children in clinical trials argue that enrollment can provide high quality care and cutting-edge medicine to children who otherwise would receive only routine medical services. In this view, excluding foster children unfairly bars them from the best the medical profession has to offer."

It will be very interesting to see the Vera Institute's findings -- which are, according to the Institute itself -- "part of Vera's mission to improve government systems." "We hope that the information we provide will contribute to the public debate that will help shape future policies regarding clinical trials and children in government custody," the site reads. On a national level, between 12,000 and 13,000 children under the age of 13 have participated in National Institutes of Health-sponsored AIDS drug trials from 1986 to 2005.

Even though the Vera Institute's findings are not yet complete, the Environmental Protection Agency's (EPA) Apr. 8, 2005 cancellation of its Children's Health Environmental Exposure Research Study (CHEERS) shows what a combination of intense opposition from environmental and public health groups (as well as a little help from Congress) can do to end experimentation on poverty-stricken children.

Child medical experiments at the EPA In October 2005, the American Chemistry Council gave the EPA $2.1 million to study how children ranging from infancy to three years old ingest, inhale or absorb chemicals. Like IG Farben was for the German pharmaceutical companies of Nazi Germany, the American Chemistry Council acts much like a front group for chemical industry bigwigs like Bayer (which was incidentally also a member of IG Farben), BP, Chevron, Dow, DuPont, Exxon, Honeywell, 3M, Monsanto and Procter & Gamble. Studies have already proven that the chemicals made by these companies have long-term effects on children and adults. A short, two-year study like CHEERS would of course fail to reveal these long-term effects and the American Chemistry Council could then publicize these findings as "proof" that its chemicals were safe.

This represents an ethical problem in itself, but the demographic of the proposed child test subjects worsen the issue, especially in light of the use of foster children (the majority of which were African-American and Hispanic) by both the New York City ACS and the Tuskegee Syphilis Study. According to the EPA's original study proposal, portions of which were reprinted by the Organic Consumers Association, test subjects would be chosen from six health clinics in Duvall County, Fla. Given the characteristics of these health centers, page 23 of the study proposal itself highlights that minority children from low-income families would be the likely test subjects: "Although all Duval County citizens are eligible to use the [health care] centers, they primarily serve individuals with lower incomes. In the year 2000, seventy five percent of the users of the clinics for pregnancy issues were at or below the poverty level ... The percentage of births to individuals classified as black in the U.S. Census is higher at these three hospitals than for the County as a whole."

In fact, the health care centers report that 51 percent of their births are to non-Caucasian mothers, and that 62 percent of mothers received only elementary school or secondary school educations. If the EPA were to have proceeded with CHEERS, children born to these health care centers would have been used as human guinea pigs simply because they belong to minority groups and poverty-stricken families. In return for allowing their children to be exposed to toxic chemicals, the families were to have received $970, a free video camera, a T-shirt and a framed certificate of appreciation.

Fortunately, the EPA decided not to go through with CHEERS, once U.S. Senators Bill Nelson (D-Fla.) and Barbara Boxer (D-Calif.) decided to put their feet down and block President Bush's nomination of Stephen Johnson for head of the EPA. In his Apr. 8 statement, Johnson reversed the EPA's earlier decision to await a report from an independent science advisory panel before making a decision about CHEERS. He explained his decision as being a result of public and media "misrepresentations" of the study:

"Last fall, in light of questions about the study design, I directed that all work on the study stop immediately and requested an independent review. Since that time, many misrepresentations about the study have been made. EPA senior scientists have briefed me on the impact these misrepresentations have had on the ability to proceed with the study.

"I have concluded that the study cannot go forward, regardless of the outcome of the independent review. EPA must conduct quality, credible research in an atmosphere absent of gross misrepresentation and controversy."

Boxer, who says that she will continue to oppose testing toxins on humans, called CHEERS an "immoral program to test pesticides on children" and "a reprehensible idea that never should have made it out of the boardroom" in her statement to the Associated Press following Johnson's decision. Luckily, unlike Tuskegee, the study was stopped before anyone got hurt.
Originally published March 7 2006
Human medical experimentation in modern times: Silencing the victims (part three)

Even though it is openly denying any wrongdoing, New York City's ACS (Administration for Children's Services) deserves some credit for taking the effort to investigate its past involvement in medical experimentation on humans and contracting the Vera Institute of Justice to conduct an independent review. IG Farben "daughter" companies like modern Bayer, though openly denying connection to IG Farben's war crimes, have also made an effort to help human medical experiment victims. These companies have worked with the German government to set up a compensation fund for those Holocaust survivors who lived through the gruesome medical experiments to which they were subjected by their captors.

According to a Bayer spokesperson who was quoted in Handscomb's It's My Story, "The company's contribution to this fund amounted to more than £40 million (over $70 million)." On the other hand, as Handscomb points out, some Holocaust victims have had to campaign to receive money from this fund for decades. Palmer, for example, fought to receive compensation for 28 years, yet received nothing from authorities until her story received media attention. As Handscomb writes, "Within weeks of the authorities being contacted by the BBC, Zoe received a check for a little over £2,000 (approximately $3,500) from the German compensation fund."

In contrast to both ACS and Bayer, SFBC is both failing to acknowledge wrongdoing and trying to silence test subjects. According to a Nov. 20 Seattle Times article by original Bloomberg drug experiment exposé authors Evans and Michael Smith, SFBC threatened three of the experimental drug test subjects they interviewed for their Bloomberg series. According to the threatened participants who now wish to remain anonymous, shortly after the Bloomberg articles were published, SFBC placed them in separate rooms with SFBC officials, including Chief Executive Arnold Hantman. While keeping them confined, Hantman used profanity and told the foreign-born participants that he would call the U.S. Department of Homeland Security and have them deported if they didn't agree to sign statements saying that the Bloomberg reporters who had interviewed them hadn't clearly said they would publish an article or use their photographs, thus undermining the credibility of the Bloomberg exposés. Though they signed the statements, the test subjects told Smith and Evans that they only did so out of fear of getting arrested and deported, and that they would be willing to tell their story to U.S. Senate investigators.

SFBC denies the information revealed in the Bloomberg articles "Drug Industry Human Testing Masks Death, Injury, Compliant FDA" and "Miami Test Center Lures Poor Immigrants as Human Guinea Pigs". In a conference call, SFBC President Lisa Krinsky said of the articles, "Approximately 99 percent of the information that was documented regarding SFBC is a total fabrication, and the remaining one percent was entirely misquoted."

If SFBC officials in fact threatened the test study participants, it is injustice upon injustice. As Arthur Caplan, director of the Center for Bioethics at the University of Pennsylvania in Philadelphia, explained in the Seattle Times article, "It's clearly beyond the pale to bully and coerce people because they reported ethical violations. It's simply heinous to try and cover up misdeeds with these actions."

On this note, though human medical experimentation is a valuable part of science, its ethics are questionable at best. For this reason, it is important for the Office for Human Research Protections, organizations like the Vera Institute of Justice and human rights activist groups to make sure that test subjects are not being exploited, especially when these subjects include children, immigrants, poor people and other groups that are especially susceptible to exploitation. Humanity and the public good should always be given priority over profit.
Originally published March 7 2006

The human medical experimentation comparison chart: Nazi Germany vs. present-day Big Pharma

Historians usually refer to Nazi Germany's IG Farben as the epitome of bad medicine, where horrifying medical experiments were routinely carried out on innocent civilians. Most people accept the history of IG Farben as true, yet those same people are reluctant to admit that today's modern pharmaceutical industry is not only directly descended from IG Farben, it still follows many of the same inhumane practices.

In this comparison chart, we take a closer look at the similarities between the medical experimentation carried out in Nazi Germany vs. the practices of Big Pharma in the United States today. The times have changed, and medical experimentation has a prettier face, but it's still the same horrifying practice of exploiting the most vulnerable citizens in society to outright criminal experiments with pharmaceuticals.

Be sure to also read the Human Medical Experimentation Timeline to get the big picture on the true history of human experiments in modern medicine.

Then: In Nazi Germany
Now: In the United States
IG Farben Big Pharma The American Chemistry Council
Concentration camps Experimental drug testing centers New York City children's homes (during the late 1980s and 1990s)
For the EPA's proposed CHEERS study: Health care centers in Duvall County, Fla. SS Doctors "Poorly trained and unlicensed clinicians" Workers in New York City children's homes

Concentration camp inmates (Jews -- including Jewish children, gypsies, homosexuals, mentally ill individuals, mentally challenged individuals) Experimental drug test subjects (poor people -- including children in poor families, orphans and foster care children; immigrants; mentally ill and mentally challenged individuals who are unable to hold down a regular job)

For CHEERS: Children born to low-income, minority families
Concentration camp scientists forcing inmates to take pills and powders, or simply just injecting them

Giving potential test subjects long forms written in language they may not understand (either because they are immigrants or because it's written in obscure technical jargon) as "informed consent"

In the New York City children's homes: Forced noncompliant children to take experimental AIDS drugs by feeding them medication through tubes placed in their stomachs

Test subjects "paid" for use of their bodies by being allowed to live Test subjects going to experimental drug centers paid for use of their bodies with "as little as $25 per day or as much as $6,900 for seven months," according to Bloomberg reporters Evans and Michael Smith For the low-income families who were to take part in the EPA's proposed
CHEERS: $970, a free video camera, a T-shirt and a framed certificate of appreciation

IG Farben "daughter" companies like Bayer have worked with the German government to set up a compensation fund for survivors of concentration camp medical experiments, but some survivors have experienced difficulty getting the money owed to them.

SFBC: Three test subjects who revealed the details of the potentially exploitative experimental drug test industry to the media were threatened with deportation, unless they signed statements denying the validity of the resulting articles.

New York City ACS: Though openly denying wrongdoing, ACS officials have both analyzed their own records for information on the extent and ethics of the experimental AIDS drug tests on foster children and contracted the Vera Institute of Justice to conduct an independent review.

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