Consider the following scenario: You have a child in high school. She has been accepted to a prestigious university. Well before she sets foot on campus, she is asked to prove that she received each of the vaccines on a school-provided list.

Especially if the school happens to be in a blue state, that list likely includes one of the Covid-19 shots. If you have any questions about how the school came to require the Covid jab, or any of the other vaccines for that matter, and you ask enough questions, eventually someone will tell you: “Well, we get our guidance from the American College Health Association.”

That situation was laid out for me in a phone interview with Pamela Popper, a vocal critic of the health-care industry and founder of Wellness Forum Health, a business that promotes “informed medical decision making.” Popper and critics like her suggest that contrary to the American College Health Association’s (ACHA) image as an organization of experts concerned solely with the health and wellness of college students, the organization’s financial ties to pharmaceutical companies and the Centers for Disease Control and Prevention (CDC) raise potential conflict-of-interest concerns and illustrate how connections between private, public, and nonprofit actors shape American life.

The ACHA, founded in 1920 as the American Student Health Association, has long positioned itself as “the voice for student health and wellness.” According to the organization’s website, the ACHA represents more than 800 institutions, 20 million students, and 5,500 professionals. Their vision is “[t]o be the recognized voice of expertise in college health,” and their mission is “[t]o serve as the principal leadership organization for advancing the health of college students and campus communities through advocacy, education, and research.”

Universities that wish to benefit from the ACHA’s knowledge and research on matters related to student health and wellness can find copious materials available for free through the organization’s website. They can also become an ACHA member or hire an ACHA consultant. Membership affords universities with more direct access to webinars, mentoring, membership seals, and the ability to directly participate in the organization.

After schools shut down in response to Covid-19, the ACHA developed several sets of guidelines for reopening and managing campuses for different periods of the pandemic. They began offering Covid-specific consulting services to “provide guidance and external review for campus pandemic response plans.”

The ACHA’s American College Health Fund (ACHF), which was established to fund “projects and activities that would not otherwise be funded through traditional revenue sources” and partners “with non-profit organizations, foundations, and corporations to create a series of materials to benefit students and college health professionals,” lists Pfizer among its “Partners for Wellness.”

Among the ACHF’s listed partner-supported resources are educational brochures on Meningitis B (“MenB”) and the MenB vaccination, as well as social-media kits encouraging human papillomavirus (HPV) vaccination. Those items were developed in partnership with Pfizer and Merck, respectively. Also among the ACHF’s partner-supported resources are a Pfizer-funded report on campus vaccine requirements and coverage as well as a description of an in-progress program funded by GlaxoSmithKline, intended as an “educational campaign…in outbreak prevention and response” that entailed the development of webinars and workshops on topics like vaccine coverage and vaccine best practices.

In the view of critics like Pamela Popper, these relationships—often unknown to college students and their families—constitute major conflicts of interest and amount to “paid advertising and advocacy.” The most egregious example, Popper said, was the ACHA’s response to Covid-19.

In the early months of 2020, as institutions of higher education across the country prepared for possible disruptions to campus operations in the wake of Covid-19’s arrival, the ACHA, with support from the ACHF, assembled a Covid-19 task force to develop guidelines, which the ACHA released on March 3, 2020. These guidelines were intended to help college health staff and administrators prepare for the virus’s arrival and plan for contingencies like an on-campus surge in Covid cases or a school-wide closure.

The ACHA has since released several updated sets of guidelines that draw heavily from CDC guidance. The two most comprehensive sets of guidance were released on December 29, 2020, and May 25, 2021, discussing the reopening of campuses in the spring and fall semesters of 2021, respectively. Together, the two missives covered virtually all aspects of campus operations. The December 29 document emphasized the importance of testing, contact tracing, and isolation and quarantine. The May 25 document emphasized the central role of near-universal Covid vaccination in returning campuses to pre-pandemic normalcy.

A separate ACHA announcement from April 2021 likewise emphasized the importance of Covid vaccination: “[The] ACHA recommends COVID-19 vaccination requirements for all on-campus college and university students for fall semester 2021 [emphasis in original],” the announcement stated.

A subsequent ACHA announcement released in June 2021 denounced state-level opposition to college vaccine requirements, claiming such opposition endangered public-health infrastructure, economic security, and students’ mental health. Another missive from August 2021 claimed restrictions on universities’ ability to require Covid-19 vaccination and other Covid-mitigation efforts “threaten the health and safety of students, faculty, staff, and neighboring communities [emphasis in original].”

Yet the independence of the ACHA can be called into question. It’s not clear that their guidelines and recommendations were developed free of any conflicts of interest. In addition to its standing financial ties to drug companies, the ACHA had received more than $2.4 million from the CDC.

In the spring of 2021 the ACHA received a $450,000 grant from the CDC to support its Higher Education Covid-19 Community of Practice (HECCOP) program, intended to encourage behavioral changes related to Covid mitigation. This grant was awarded in addition to the $2 million the ACHA received from the CDC to support its Campus Covid-19 Vaccine Initiative (CoVAC), the explicit goals of which were to increase vaccine confidence and uptake by college students, combat vaccine hesitancy and misinformation, and build trust in public-health resources.

Through HECCOP and CoVAC, the ACHA was essentially acting as a marketing firm for the CDC. Marketing materials developed through HECCOP and CoVAC endorse the use of peer-ambassador programs and social media. Among the peer-ambassador materials are detailed guides for program development and the creation of communication plans and workshops for student ambassadors once they are recruited.

To help institutions of higher education develop their student-ambassador programs and carry out behavior-modification and vaccine-confidence campaigns, the ACHA awarded a series of $2,200 and $3,000 mini-grants through HECCOP and CoVAC, respectively. A total of 70 institutions received funds through these programs.

The March 2022 “Lessons Learned” documents for HECCOP and CoVAC reveals the programs that grant recipients funded with their awards, including the creation of peer-ambassador teams, the distribution of branded masks and hand sanitizer, and the creation of physical and digital marketing materials. The CoVAC document mentions funded programs like the distribution of wearable “vaccine confidence visibility items,” attempts to “prompt people to action,” and efforts to “norm vaccination as a protective behavior for the communal good.”

The fact that the CDC gave the ACHA more than $2.4 million to promote CDC Covid policy raises questions about the ACHA’s independence and objectivity in its consultation with schools and the development of its guidance. On several of its Covid-related pages, the ACHA does post the disclaimer, “Program content is solely the responsibility of ACHA and does not necessarily reflect the official views of CDC.” However, the substance of the ACHA’s Covid guidance never seems to meaningfully depart from that of the CDC.

Many college students and their families surely want to know how the ACHA resolved disputes between the CDC and dissenting opinions or contradictory evidence on matters like masking, testing, and Covid vaccination. Yet the ACHA’s multiple guidelines, announcements, and updates offer little insight into how such conflicts were resolved, or whether opinions or research at variance with CDC policy or guidelines were even taken into consideration.

I reached out to the ACHA and members of their Covid-19 task force several times asking for comment on these matters. Only one member of their task force responded to these requests. The individual was unable to speak with the press due to a university policy restricting interactions with the media.

Daniel Nuccio is an independent journalist and Ph.D. student in biology. His work has been published by The American Conservative, the Federalist, the College Fix, and the Brownstone Institute.