risk of undue influence. At the same time, the harmonization of disclosure requirements and procedures can reduce administrative burdens for researchers and physicians who must make multiple disclosures to different institutions for different purposes.

Disclosure does not resolve or eliminate conflicts of interest. Institutions must also evaluate and act upon the disclosed information. Actions might include the elimination of a relationship, further disclosure (e.g., to research participants, patients, or the public), or other types of management (e.g., restricting the participation of a researcher with a conflict of interest in the enrollment of study participants or analysis of study data).

  1. Conflict of interest guidelines and policies can be strengthened by engaging physicians, researchers, and medical institutions in developing policies and consensus standards.

    For conflict of interest policies to be truly effective, buy-in from physicians and researchers will be important, so that they regard conflict of interest policies as a means to help them fulfill their professional responsibilities and not as externally imposed nuisances. Furthermore, if those who are subject to conflict of interest policies participate in policy development, they may suggest how the policies can be framed to avoid unintended adverse consequences and undue administrative burdens. In several areas in which substantial policy variation or disagreement exists and greater agreement is needed, the report proposes the creation of consensus development panels with a broad range of participants, including consumer representatives. Two areas that are ripe for consensus building involve the standardization of information that physicians and researchers are required to disclose (Chapter 3) and the development of a new system of financing continuing medical education (Chapter 5).

  2. A range of organizations—public and private—can promote the adoption and implementation of conflict of interest policies and help create a culture of accountability that sustains professional norms and promotes public confidence in professional judgments.

    Institutions that carry out medical research, medical education, clinical care, and practice guideline development have the primary responsibility for addressing conflicts of interests in these activities. These institutions do not, however, act in isolation. Rather, they interact with many other organizations—including academic and trade membership associations, accreditation and certification bodies, patient advocacy groups, health plans, and federal and state agencies—that have a stake in reducing the severity of individual and institutional conflicts of interest. As discussed in Chapter 9, these organizations can create incentives to encourage institutions to adopt and implement policies that are consistent with the recommendations of this committee and other organizations, such as the Association of American Medical Colleges, the Association of American Universities, and the International Committee of Medical Journal Editors. Such incentives would

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