presentations, but these connections could also have negative effects on the careers of his teaching assistants and the collegial culture of the institution. In view of such possible consequences, the fact that an individual has a right to engage in an activity should not be allowed to obscure the equally important fact that his or her actions may affect the rights of colleagues and students. The claim of an individual right by a professional does not preclude the possibility that this right may be regulated.

Finally, the seriousness of the possible harm depends in part on the extent of accountability. In general, a conflict of interest is more serious when the level of accountability of the physician, researcher, or educator to his or her peers, institution, licensing board, or similar entity is less extensive. If accountability for decisions is bolstered by an independent review of those decisions by colleagues or other authorities, there is generally less potential for harm and less cause for concern. However, the reviewers must be and must be viewed as being effective and independent and must have no conflicts of interest of their own. Accountability is also greater to the extent that sanctions for serious violations of policies are significant and imposed in a timely fashion, and it is further enhanced if the results of the disciplinary proceedings are regularly disclosed.

In summary, an overall assessment of whether a financial relationship constitutes a conflict of interest and, if so, how severe it is and how it should be managed depends on several considerations: the importance of the financial or other relationship for furthering primary medical values, the likelihood and seriousness of possible harm to those primary values, and the availability of measures that can reduce the likelihood or severity of harm. Chapter 3 discusses such measures and also the procedures applied by universities and other institutions to identify, limit, and manage conflicts of interest.

HOW CAN CONFLICT OF INTEREST POLICIES BE EVALUATED?

The discussion above focused on several questions and factors that should be considered in assessing the severity of a conflict of interest in financial relationships. They are intended to provide guidance for the formulation of the content of policies for controlling conflict of interest, for example, the specification of the information needed from individuals that will be sufficient to evaluate financial relationships, assess the severity of conflicts of interest, and guide responses to identified conflicts. Additional criteria are needed to evaluate the implementation or actual operation of the policies (Table 2-2). Even if policies are well formulated, they must also be well administered.



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