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In December 2021, the White House released the National Action Plan to Combat Human Trafficking (“National Action Plan”), which calls on agencies to “strengthen efforts to identify, prevent, and address human trafficking in product supply chains and ventures.” The National Action Plan’s emphasis on supply chains reflects lessons learned from COVID-19, echoing the National Strategy for a Resilient Public Health Supply Chain  (PDF) (“National Strategy”), published by the U.S. Department of Health and Human Services in July 2021. Among other objectives, the National Strategy aims to “ensure equitable labor conditions by promoting best practices and U.S. adherence to child labor and forced labor laws and regulations” in health supply chains. 

The goal of this information memorandum is for all stakeholders in the healthcare and anti-trafficking fields to better understand how the federal government has enforced forced labor laws through criminal prosecution, how health professionals who have experienced trafficking have used civil litigation to seek justice, and how federal courts have handled cases involving forced labor in healthcare settings.

This Information Memorandum (IM) is directed toward healthcare administrators, procurement professionals, suppliers, and other decisionmakers in the healthcare and public health (HPH) sector who may be positioned to address forced labor concerns in supply chains through product procurement and labor contracting practices. The IM explains how forced labor occurs in HPH supply chains, overviews relevant laws and regulations, and compiles relevant policy guidance and additional resources.

This Information Memorandum (IM) highlights the U.S. Department of Health and Human Services’ (HHS) contributions to human trafficking research, gaps in evidence, and open access policies.