particular case or type of case can enable other institutions to learn about more and less effective practices and adjust their own policies and behaviors accordingly.

Accountability

Accountable individuals and institutions explain and take responsibility for their conduct and decisions. Thus, just as a physician explains the rationale for clinical decisions to patients and researchers explain the rationale for research and research procedures, so too will leaders of accountable institutions explain their policies and their application to the individuals who are directly affected and respond to questions and suggestions.

Taking responsibility for the consequences of individual or institutional actions and decisions may involve offering apologies or compensation to those harmed by these actions and acknowledging the appropriateness of penalties when a representative of the institution has acted improperly or illegally. To demonstrate that it is accountable, an institution not only will develop explicit conflict of interest policies and procedures for implementing its policies but also will devise ways to communicate how they are applied in practice. Institutional leaders will be prepared to explain how judgments about conflicts of interest are reasonably consistent across similar cases and why, for example, they determined that it was sufficient to require only the disclosure of a relationship in one case but appropriate to manage or prohibit the relationship in another case. Finally, institutional leaders will be ready to respond to questions about their own interests and impartiality. As discussed in Chapter 8, leaders should establish procedures for dealing with the conflicts that their own institutions may have.

Public engagement is often important for accountability. For example, accountability is generally enhanced if public representatives serve on institutional panels that review individual relationships that may present conflicts of interest. To cite a somewhat parallel situation, federal regulations require institutional review boards to include at least one member not affiliated with the institution. Also, as part of a commitment to openness and accountability, organizations may invite public comment on their conflict of interest policies and may take seriously suggestions for revisions. Public participation can enhance the credibility and trustworthiness of decisions about individual cases as well as more general policies.

A final aspect of accountability is a commitment to improving conflict of interest policies and their implementation. Setting benchmarks for performance and tracking outcomes can stimulate quality improvement activities, as has been demonstrated with other activities in health care organizations.



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