New Entrant Report U.S. Office of Government Ethics; 5 C.F.R. part 2634 Form Approved: OMB No. (3209-0001) (January 2018) Executive Branch Personnel Public Financial Disclosure Report (OGE Form 278e) Filer's Information Best, Daniel Sr. Advisor to the Secretary for Drug Price Reform, FDA, Department of Health & Human Services Date of Appointment: 04/01/2018 Other Federal Government Positions Held During the Preceding 12 Months: None Electronic Signature - I certify that the statements I have made in this form are true, complete and correct to the best of my knowledge. /s/ Best, Daniel [electronically signed on 02/11/2018 by Best, Daniel in Integrity.gov] Agency Ethics Official's Opinion - On the basis of information contained in this report, I conclude that the filer is in compliance with applicable laws and regulations (subject to any comments below). /s/ Olesh, Stanley, Certifying Official [electronically signed on 04/12/2018 by Olesh, Stanley in Integrity.gov] Other review conducted by /s/ Olesh, Stanley, Ethics Official [electronically signed on 04/12/2018 by Olesh, Stanley in Integrity.gov] U.S. Office of Government Ethics Certification Best, Daniel - Page 1 Data Revised 04/12/2018 Data Revised 02/20/2018 Data Revised 02/15/2018 Data Revised 02/14/2018 Data Revised 02/13/2018 Comments of Reviewing Officials (public annotations): PART # REFERENCE COMMENT N/A N/A General (04/12/2018, Olesh, Stanley): 4/2/18 - rec'd signed EA -- SO N/A N/A General (04/12/2018, Olesh, Stanley): 4/10/18 - rec'd final divestiture confirmation -- SO Best, Daniel - Page 2 1. Filer's Positions Held Outside United States Government # ORGANIZATION NAME CITY, STATE ORGANIZATION TYPE POSITION HELD FROM TO 1 CVSHEALTH Woonsocket, Rhode Island Corporation VP Trade Relations 5/2011 3/2018 VALUE INCOME TYPE INCOME AMOUNT Salary/Bonus $502,776 2. Filer's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF 1 CVSHEALTH N/A 2 CVSHEALTH, stock options N/A $50,001 $100,000 None (or less than $201) 3 CVSHEALTH, restricted stock N/A $250,001 $500,000 None (or less than $201) 4 CVSHEALTH Deferred Compensation Plan (single-fund plan) Yes $250,001 $500,000 None (or less than $201) 5 CVSHEALTH, anticipated bonus N/A $50,001 $100,000 None (or less than $201) 6 CVSHEALTH N/A $100,001 $250,000 Dividends $2,501 - $5,000 7 CVSHEALTH, ESPP account N/A $1,001 - $15,000 Dividends $201 - $1,000 8 Amazon N/A $15,001 $50,000 None (or less than $201) 9 Appian N/A $1,001 - $15,000 None (or less than $201) 10 Celgene Corp N/A $1,001 - $15,000 None (or less than $201) See Endnote Best, Daniel - Page 3 # DESCRIPTION EIF VALUE INCOME TYPE 11 ESRX - Express Script Holding Co. N/A $1,001 - $15,000 None (or less than $201) 12 KERX - Keryx Biopharmaceuticals Inc N/A $1,001 - $15,000 None (or less than $201) 13 KMI - Kinder Morgan Inc N/A $15,001 $50,000 14 TLND - Taland S.A. N/A $1,001 - $15,000 None (or less than $201) 15 CSJ - iShares 1-3 yr Credit Bond ETF Yes $15,001 $50,000 $201 - $1,000 16 IEMG - iShares Core MSCI Emerging Mkts ETF Yes $15,001 $50,000 $201 - $1,000 17 IUSG - iShares Russell 3000 Growth Index ETF Yes $1,001 - $15,000 None (or less than $201) 18 IAU - iShares Gold Trust Yes $15,001 $50,000 19 EFA - iShares MSCI EAFE ETF Yes $15,001 $50,000 $201 - $1,000 20 SCZ - iShares MSCI EAFE small Cap ETF Yes $50,001 $100,000 $1,001 - $2,500 21 IWM - iShares Russell 2000 ETF Yes $15,001 $50,000 $201 - $1,000 22 PFF- iShares US Preferred Stock ETF Yes $1,001 - $15,000 $201 - $1,000 23 XLI - Industrial Select Sector SPDR ETF Yes $1,001 - $15,000 $201 - $1,000 24 XLF - Financial Select Sector ETF Yes $15,001 $50,000 $201 - $1,000 25 XLP - Consumers Staples Select Sector SPDR ETF Yes $1,001 - $15,000 $201 - $1,000 Dividends INCOME AMOUNT $201 - $1,000 Best, Daniel - Page 4 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 26 VNQI - Vanguard Global ex-US Real Est ETF Yes $15,001 $50,000 $2,501 - $5,000 27 BIV - Vanguard Interm-Term Bond ETF Yes $15,001 $50,000 $1,001 - $2,500 28 BCOSX - Baird Core Plus Bond Inv Yes $1,001 - $15,000 29 FMIJX - FMI International Fund Yes $15,001 $50,000 $201 - $1,000 30 OAKIX - Oakmark International Investor Yes $15,001 $50,000 $201 - $1,000 31 TIIRX - TIAA-CREF Growth & Income Retail Yes $50,001 $100,000 32 USAIX - USAA Income Yes $15,001 $50,000 33 VEMAX - Vanguard Emerging Mkts Stock Idx Adm Yes $50,001 $100,000 34 VEIRX - Vanguard Equity Income Adm Yes $15,001 $50,000 35 VAIPX - Vanguard Inflation - Protected Secs. Adm Yes $1,001 - $15,000 36 VWILX - Vanguard International Growth Adm Yes $15,001 $50,000 37 VFSUX - Vanguard Short Term Inv-Grade Adm Yes $50,001 $100,000 38 SWVXX - Schwab Value Adv. Money Fu Yes $15,001 $50,000 39 Cash N/A $15,001 $50,000 40 VSCPX - Vanguard Small Cap Index Inst. Plus (CVS 401k plan) Yes $250,001 $500,000 $201 - $1,000 None (or less than $201) Best, Daniel - Page 5 3. Filer's Employment Agreements and Arrangements # EMPLOYER OR PARTY CITY, STATE STATUS AND TERMS DATE 1 CVSHEALTH Woonsocket, Rhode Island Received options under employee incentive program; will exercise options within 60 days, sell resulting stock, and forfeit any unvested options . 5/2011 2 CVSHEALTH Woonsocket, Rhode Island Received Restricted stock under employee incentive program; Will sell vested shares and forfeit remaining shares within 60 days 5/2011 3 CVSHEALTH Woonsocket, Rhode Island Deferred compensation plan; Upon my resignation from CVS the full amount will be paid in cash in one lump sum, after which my interest in the plan will terminate. 1/2013 4 CVSHEALTH Woonsocket, Rhode Island Bonus to be paid March 2018 under standard company policy. Performance-based, partially based upon individual performance and partially on company financial performance; however, fully based upon 2017 performances, so calculation of final amount will not be affected by any future matters. 1/2011 5 CVSHEALTH Woonsocket, Rhode Island Empoyee Stock Purchase Plan; will terminate participation and sell all CVS stock upon separation. 1/2012 6 CVSHEALTH Woonsocket, Rhode Island CVS 401(k) defined contribution plan - underlying holdings reported in Part 2; I intend to roll over this 401k plan into an independent IRA as soon after separation as possible. 5/2011 4. Filer's Sources of Compensation Exceeding $5,000 in a Year # SOURCE NAME CITY, STATE BRIEF DESCRIPTION OF DUTIES 1 CVSHEALTH Woonsocket, Rhode Island VP for Trade Relations Best, Daniel - Page 6 5. Spouse's Employment Assets & Income and Retirement Accounts # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 1 University Hospital (Hospital System), Case Western Reserve Univ., Cleveland, OH N/A salary $34,698 2 DFSTX - DFA US Small Cap Yes $100,001 $250,000 3 AAPL - Apple Inc N/A $15,001 $50,000 Dividends $201 - $1,000 4 IWM - iShares Russell 2000 ETF Yes $1,001 - $15,000 None (or less than $201) 5 IWR - iShares RUssell Mid Cap ETF Yes $1,001 - $15,000 None (or less than $201) 6 GTLLX - Glenmede LArge Cap Growth Yes $1,001 - $15,000 $201 - $1,000 7 VeiRX - Vanguard Equity Income Adm Yes $1,001 - $15,000 None (or less than $201) 8 VFSUX - Vanguard Short Term Inv Grade Adm Yes $1,001 - $15,000 9 SAMFX - Virtus Seix total Return Bond I Yes $1,001 - $15,000 10 Cash N/A $1,001 - $15,000 6. Other Assets and Income # DESCRIPTION EIF VALUE 1 ANET - Arista Networks Inc N/A $1,001 - $15,000 INCOME TYPE INCOME AMOUNT None (or less than $201) Best, Daniel - Page 7 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 2 EFA - iShares MSCI EAFE ETF Yes $1,001 - $15,000 $201 - $1,000 3 IWB - iShares Russell 1000 ETF Yes $50,001 $100,000 $1,001 - $2,500 4 XLY - Consumer Discret Sel Sect SPDR ETF Yes $1,001 - $15,000 $201 - $1,000 5 VUG - Vanguard Growth ETF Yes $15,001 $50,000 $201 - $1,000 6 VFIAX - Vanguard 500 Index Admiral Yes $15,001 $50,000 $201 - $1,000 7 VWIUX - Vanguard Inter-Term Tax Exempt Fund Yes $1,001 - $15,000 $201 - $1,000 8 Cash N/A $1,001 - $15,000 None (or less than $201) 9 CSCO - Cisco Systems, Inc N/A $1,001 - $15,000 Dividends $201 - $1,000 10 MA - Mastercard, Inc N/A $15,001 $50,000 Dividends $201 - $1,000 11 IWB - iShares Russell 1000 ETF Yes $50,001 $100,000 $201 - $1,000 12 VTV - Vanguard Value ETF Yes $1,001 - $15,000 $201 - $1,000 13 VGHAX - Vanguard Health Care Adm Yes $15,001 $50,000 $201 - $1,000 14 VWIUX - Vanguard Inter-Term Tax Exempt Fund Yes $1,001 - $15,000 $201 - $1,000 15 VIMAX - Vanguard Mid Cap Index Adm Yes $50,001 $100,000 $1,001 - $2,500 16 snps - Synopsys, Inc N/A None (or less than $1,001) None (or less than $201) 17 IJR - ishares Core S&P Small Cap ETF Yes $1,001 - $15,000 None (or less than $201) Best, Daniel - Page 8 # DESCRIPTION EIF VALUE 18 SWPPX - Schwab S&P 300 Index Yes $1,001 - $15,000 None (or less than $201) 19 VFINX - Vanguard 500 Index Investor Yes $1,001 - $15,000 None (or less than $201) 20 VT - Vanguard Total World Stock ETF Yes $1,001 - $15,000 None (or less than $201) 21 AET - Aetna N/A $15,001 $50,000 22 ANTM - Anthem, Inc N/A $1,001 - $15,000 23 BIVV - Bioverativ, Inc N/A None (or less than $1,001) 24 CVS - CVS Health Corp N/A $50,001 $100,000 25 DBVT - DBV Technologies S.A. N/A $1,001 - $15,000 None (or less than $201) 26 DODFX - Dodge & Cox International Stock Yes $15,001 $50,000 $201 - $1,000 27 HUM - Humana Inc N/A $15,001 $50,000 28 PPRTF - Passport Potash, Inc N/A None (or less than $1,001) None (or less than $201) 29 PRMSX - T. Rowe Price Emerging Markets Stock Yes $15,001 $50,000 $201 - $1,000 30 RAD - Rite Aid Corporation N/A $1,001 - $15,000 None (or less than $201) 31 VFSVX - Vanguard FTSE All-Wld ex-US Small Cap Inx Inv Yes $15,001 $50,000 $201 - $1,000 32 VWIGX - Vanguard International Growth Inv Yes $15,001 $50,000 $201 - $1,000 See Endnote See Endnote INCOME TYPE INCOME AMOUNT None (or less than $201) Dividends Dividends $1,001 - $2,500 $201 - $1,000 Best, Daniel - Page 9 # DESCRIPTION EIF VALUE INCOME TYPE INCOME AMOUNT 33 WAL - Western Alliance Bancorporation N/A $15,001 $50,000 Dividends $201 - $1,000 34 Utah 529 -- 100% in Age-Based Aggressive Global portfolio Yes $100,001 $250,000 $2,501 - $5,000 35 Condominium, Avon, OH N/A $100,001 $250,000 None (or less than $201) 7. Transactions (N/A) - Not required for this type of report 8. Liabilities # CREDITOR NAME TYPE AMOUNT YEAR INCURRED RATE TERM 1 Chemical Bank Mortgage (investment/ren tal property) $50,001 $100,000 2012 4% 30 year fixed 9. Gifts and Travel Reimbursements (N/A) - Not required for this type of report Endnotes Best, Daniel - Page 10 PART # ENDNOTE 2. 4 Single fund tracking basket of five international funds:Templeton Foreign Equity Fund (TFEQX); American Funds EuroPacific Growth Fund (RERGX); Vanguard International Growth Fund (VWILX); Vanguard Total International Stock Index Fund (VTPSX); and (VDIPX) Vanguard Developed Market Index 6. 23 All stock bought by Sanofi in March 2018-- SO 6. 28 Stock has no value. Best, Daniel - Page 11 Summary of Contents 1. Filer's Positions Held Outside United States Government Part 1 discloses positions that the filer held at any time during the reporting period (excluding positions with the United States Government). Positions are reportable even if the filer did not receive compensation. This section does not include the following: (1) positions with religious, social, fraternal, or political organizations; (2) positions solely of an honorary nature; (3) positions held as part of the filer's official duties with the United States Government; (4) mere membership in an organization; and (5) passive investment interests as a limited partner or non-managing member of a limited liability company. 2. Filer's Employment Assets & Income and Retirement Accounts Part 2 discloses the following: ● ● Sources of earned and other non-investment income of the filer totaling more than $200 during the reporting period (e.g., salary, fees, partnership share, honoraria, scholarships, and prizes) Assets related to the filer's business, employment, or other income-generating activities that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in income during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents) This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's business, employment, or other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF). 3. Filer's Employment Agreements and Arrangements Part 3 discloses agreements or arrangements that the filer had during the reporting period with an employer or former employer (except the United States Government), such as the following: ● ● ● ● ● Future employment Leave of absence Continuing payments from an employer, including severance and payments not yet received for previous work (excluding ordinary salary from a current employer) Continuing participation in an employee welfare, retirement, or other benefit plan, such as pensions or a deferred compensation plan Retention or disposition of employer-awarded equity, sharing in profits or carried interests (e.g., vested and unvested stock options, restricted stock, future share of a company's profits, etc.) Best, Daniel - Page 12 4. Filer's Sources of Compensation Exceeding $5,000 in a Year Part 4 discloses sources (except the United States Government) that paid more than $5,000 in a calendar year for the filer's services during any year of the reporting period. The filer discloses payments both from employers and from any clients to whom the filer personally provided services. The filer discloses a source even if the source made its payment to the filer's employer and not to the filer. The filer does not disclose a client's payment to the filer's employer if the filer did not provide the services for which the client is paying. 5. Spouse's Employment Assets & Income and Retirement Accounts Part 5 discloses the following: ● ● ● Sources of earned income (excluding honoraria) for the filer's spouse totaling more than $1,000 during the reporting period (e.g., salary, consulting fees, and partnership share) Sources of honoraria for the filer's spouse greater than $200 during the reporting period Assets related to the filer's spouse's employment, business activities, other income-generating activities that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in income during the reporting period (e.g., equity in business or partnership, stock options, retirement plans/accounts and their underlying holdings as appropriate, deferred compensation, and intellectual property, such as book deals and patents) This section does not include assets or income from United States Government employment or assets that were acquired separately from the filer's spouse's business, employment, or other income-generating activities (e.g., assets purchased through a brokerage account). Note: The type of income is not required if the amount of income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF). Amounts of income are not required for a spouse's earned income (excluding honoraria). 6. Other Assets and Income Part 6 discloses each asset, not already reported, that (1) ended the reporting period with a value greater than $1,000 or (2) produced more than $200 in investment income during the reporting period. For purposes of the value and income thresholds, the filer aggregates the filer's interests with those of the filer's spouse and dependent children. This section does not include the following types of assets: (1) a personal residence (unless it was rented out during the reporting period); (2) income or retirement benefits associated with United States Government employment (e.g., Thrift Savings Plan); and (3) cash accounts (e.g., checking, savings, money market accounts) at a single financial institution with a value of $5,000 or less (unless more than $200 of income was produced). Additional exceptions apply. Note: The type of income is not required if the amount of income is $0 - $200 or if the asset qualifies as an excepted investment fund (EIF). 7. Transactions Best, Daniel - Page 13 Part 7 discloses purchases, sales, or exchanges of real property or securities in excess of $1,000 made on behalf of the filer, the filer's spouse or dependent child during reporting period. This section does not include transactions that concern the following: (1) a personal residence, unless rented out; (2) cash accounts (e.g., checking, savings, CDs, money market accounts) and money market mutual funds; (3) Treasury bills, bonds, and notes; and (4) holdings within a federal Thrift Savings Plan account. Additional exceptions apply. 8. Liabilities Part 8 discloses liabilities over $10,000 that the filer, the filer's spouse or dependent child owed at any time during the reporting period. This section does not include the following types of liabilities: (1) mortgages on a personal residence, unless rented out (limitations apply for PAS filers); (2) loans secured by a personal motor vehicle, household furniture, or appliances, unless the loan exceeds the item's purchase price; and (3) revolving charge accounts, such as credit card balances, if the outstanding liability did not exceed $10,000 at the end of the reporting period. Additional exceptions apply. 9. Gifts and Travel Reimbursements This section discloses: ● ● Gifts totaling more than $390 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period. Travel reimbursements totaling more than $390 that the filer, the filer's spouse, and dependent children received from any one source during the reporting period. For purposes of this section, the filer need not aggregate any gift or travel reimbursement with a value of $156 or less. Regardless of the value, this section does not include the following items: (1) anything received from relatives; (2) anything received from the United States Government or from the District of Columbia, state, or local governments; (3) bequests and other forms of inheritance; (4) gifts and travel reimbursements given to the filer's agency in connection with the filer's official travel; (5) gifts of hospitality (food, lodging, entertainment) at the donor's residence or personal premises; and (6) anything received by the filer's spouse or dependent children totally independent of their relationship to the filer. Additional exceptions apply. Best, Daniel - Page 14 Privacy Act Statement Title I of the Ethics in Government Act of 1978, as amended (the Act), 5 U.S.C. app. § 101 et seq., as amended by the Stop Trading on Congressional Knowledge Act of 2012 (Pub. L. 112-105) (STOCK Act), and 5 C.F.R. Part 2634 of the U. S. Office of Government Ethics regulations require the reporting of this information. The primary use of the information on this report is for review by Government officials to determine compliance with applicable Federal laws and regulations. This report may also be disclosed upon request to any requesting person in accordance with sections 105 and 402(b)(1) of the Act or as otherwise authorized by law. You may inspect applications for public access of your own form upon request. Additional disclosures of the information on this report may be made: (1) to any requesting person, subject to the limitation contained in section 208(d)(1) of title 18, any determination granting an exemption pursuant to sections 208(b)(1) and 208(b)(3) of title 18; (2) to a Federal, State, or local law enforcement agency if the disclosing agency becomes aware of violations or potential violations of law or regulation; (3) to another Federal agency, court or party in a court or Federal administrative proceeding when the Government is a party or in order to comply with a judge-issued subpoena; (4) to a source when necessary to obtain information relevant to a conflict of interest investigation or determination; (5) to the National Archives and Records Administration or the General Services Administration in records management inspections; (6) to the Office of Management and Budget during legislative coordination on private relief legislation; (7) to the Department of Justice or in certain legal proceedings when the disclosing agency, an employee of the disclosing agency, or the United States is a party to litigation or has an interest in the litigation and the use of such records is deemed relevant and necessary to the litigation; (8) to reviewing officials in a new office, department or agency when an employee transfers or is detailed from one covered position to another; (9) to a Member of Congress or a congressional office in response to an inquiry made on behalf of an individual who is the subject of the record; (10) to contractors and other non-Government employees working on a contract, service or assignment for the Federal Government when necessary to accomplish a function related to an OGE Government-wide system of records; and (11) on the OGE Website and to any person, department or agency, any written ethics agreement filed with OGE by an individual nominated by the President to a position requiring Senate confirmation. See also the OGE/GOVT-1 executive branch-wide Privacy Act system of records. Public Burden Information This collection of information is estimated to take an average of three hours per response, including time for reviewing the instructions, gathering the data needed, and completing the form. Send comments regarding the burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Program Counsel, U.S. Office of Government Ethics (OGE), Suite 500, 1201 New York Avenue, NW., Washington, DC 20005-3917. Pursuant to the Paperwork Reduction Act, as amended, an agency may not conduct or sponsor, and no person is required to respond to, a collection of information unless it displays a currently valid OMB control number (that number, 3209-0001, is displayed here and at the top of the first page of this OGE Form 278e). Best, Daniel - Page 15