consequences of requiring additional public disclosure beyond company-reported payments. For example, the requirement would add to the risk that information from different sources might fail to match exactly because of technical errors or differences in reporting requirements, procedures, or periods.1 Some might seize on the lack of an exact match as evidence of misbehavior—that is, a deliberately incomplete or inaccurate disclosure—on the part of institutions or individuals, who then might have to respond to public accusations; this would distract from their primary responsibilities for research, education, or clinical care. Misinterpretation already may occur with the reporting of payments by companies to physicians; for example, reporters may treat scientific and promotional consulting as equivalent and deserving of the same criticism.

Overall, the majority of committee members thought that making public the information that physicians and researchers report to institutions was not supported by the principle of proportionality and that responses to conflicts of interest should be based on assessment of their severity. The likely burdens on individuals and institutions of an expanded public-disclosure system beyond that proposed in Recommendation 3.4 or already in place in accordance with other public or private policies are disproportionate to any benefits from the marginal amount of additional information that would be provided.


According to Recommendation 3.3, consistency in institutional disclosure requirements and formats would increase and reporting burdens would decrease for people who must make disclosures to multiple institutions.

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