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Draft Policies for NHMRC Committees and Working Groups Developing Guidelines Submission

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The NHMRC document has covered most of the practical issues related to Conflict of Interest.

There is an issue with language. It may be preferable to use a term such as competing interests for declaring interests that could possibly then constitute a conflict of interest. This highlights that there is nothing wrong with having other interests unless under specific circumstances there is and actual conflict.

There should be a time limitation on competing interests and although the document suggests declaring financial interests over 3 years I believe that 2 would be more practical. There should even be some discretion relating to this in that an individual who gives up a commenting interest to participate in guidelines for example should be considered for participation.

The examples of conflicts are weighted to financial conflicts. Some professional inducements (presentations of data at meetings, authorship on papers, being PI on pivotal studies) may be more problematic. I also find problematic the setting of specific monetary amounts which have to be declared. A competing interest is such irrespective of the actual amount and should be declared. Whether it constitutes an actual COI may be determined by amounts involved.

The document highlights the issue of membership of expert groups and the need to restate COI at each meeting, however there may be a particular agenda item within a meeting for which a member may need to withdraw because of COI that would not preclude participation in the rest of the meeting.

There is an underlying issue which should be specifically addressed and that is those situations when mere transparency of competing interests is not enough. For example in guidelines it is the actual recommendations which involve interpretation and are designed to influence practice which must be free from bias. (For example a new drug displaying a statistically significant survival advantage but with an actual difference of few weeks and a different toxicity spectrum may not necessarily be recommended ads the new standard of care) and this determination cannot be made by anyone close the development of such a treatment.

Finally there are procedural issues within expert committees such as guideline committees which may reduce the chance of a COI actually influencing the outcome and they include, for example, the whole committee having to agree on each recommendation which lessens the chance of any individual on such a committee having too much influence on outcomes.

Lastly, I reiterate that flexibility is required in interpreting in COI guidelines in specific situation to allow the best experts to be utilised without biasing the results.


Page reviewed: 5 November, 2012