who has and who has not submitted the required financial disclosure forms. Usually, reminders should be sufficient for those who have not submitted forms, but penalties may also be needed, at least for blatant violations. Recent highly publicized incidents of significant underreporting of financial relationships to academic institutions call attention to the need for mechanisms to verify that the information disclosed is complete and accurate (e.g., through public reporting by industry of payments to physicians; see Recommendation 3.4). Again, sanctions may be appropriate for blatant cases of inaccurate disclosure. In addition, journal editors could take a stance more aggressive than they generally have thus far toward authors who violate their journals’ disclosure and conflict of interest policies.

When noncompliance is egregious, penalties such as public censure or the suspension of individuals from certain positions (e.g., a principal investigator or department chair) may be necessary. Even accrediting agencies such as the Joint Commission (formerly the Joint Commission on the Accreditation of Healthcare Organizations) that have shifted from using more negative strategies to using more positive and cooperative strategies (e.g., acknowledging high performers and helping struggling performers improve) retain a range of sanctions for use against persistent or egregiously poor performers. Sanctions are, however, neither sufficient nor desirable as the sole instruments of accountability. They must be combined with a more ambitious and effective compliance strategy that employs collaboration, consensus building, and positive incentives.

RECOMMENDATIONS

Creating Incentives for Institutional Action

As this report has described, some institutions that carry out medical research, education, clinical care, and practice guideline development have no or inadequate conflict of interest policies. Some institutions may not even fully meet the requirements of current federal regulations, and others fail to undertake monitoring and enforcement activities. This report has also described shortcomings in adherence by individual physicians and researchers to academic medical center, journal, and other conflict of interest policies.

Ideally, physicians, scientists, and medical institutions should voluntarily adopt conflict of interest policies as a matter of professional responsibility and professional ethics. A commitment to patient well-being, valid scientific research, and evidence-based education would naturally lead professionals to voluntarily adopt strong measures to minimize the negative impact of conflicts of interest on objectivity and trust. No doubt many professionals have such an attitude and act on it. Realistically, however, the committee



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