policies and practices. Thus, even relatively recent overviews of conflict of interest policies may be somewhat out of date.


Disclosure—that is, revealing to others information that may otherwise be private or confidential—is a frequent response to concerns about conflicts of interest in various sectors of society. Disclosure by physicians and researchers to their academic or other institution is essential because institutional officials cannot evaluate and respond to individuals’ relationships with industry if they are not aware of them. Consistent with the conceptual framework outlined in Chapter 2, disclosures should provide sufficient information about the nature, scope, duration, and monetary value of relationships to allow institutions to assess the risk that secondary interests might unduly influence judgments about research, clinical care, education, or other primary interests.

The committee distinguished disclosure to the physician’s or researcher’s institution from disclosure beyond the institution, for example, to patients, research participants, or the public.5 One rationale for disclosure—especially public disclosure—is the deterrence of questionable or inappropriate relationships. As Supreme Court Justice Louis Brandeis (1914) famously expressed it, “sunshine is said to be the best of disinfectants.” In a similar vein, the code of ethics of the American College of Physicians suggests that physicians considering the acceptance of gifts or other relationships with companies should ask themselves what their patients, the public, or their colleagues would think about the arrangement (Snyder and Leffler, 2005; see also Chapter 6). The Nature publishing group urges authors to avoid “any undeclared competing financial interests that could embarrass you were they to become publicly known after your work was published” (NPG, 2008).

Disclosure should have beneficial consequences if it leads physicians to avoid gifts, the use of industry-controlled presentations, and other relationships that create a risk of compromising their decisions and their professional independence. It could also have harmful consequences if physicians or researchers react by avoiding relationships that promote im-


Some analyses refer to the provision of information to institutional officials as “reporting” and reserve the term “disclosure” for the revelation of information to members of the public (e.g., journal readers or patients) (see, e.g., AAMC [2001]). In contrast, some policies refer to reporting of information to external groups. This report follows the common usage (including in federal policies and guidance) and applies the term “disclosure” to the provision of information to internal parties as well as to external parties.

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