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Draft Policies for NHMRC Committees and Working Groups Developing Guidelines Submission

ID: 
11
Personal Details
Organisation Name: 
The Australian Lung Foundation
C. Additional Information
Please identify the best term to describe the Organisation: 
Other
E. Submission
Submission options: 
Section 1 – Policies Document
Section 2 – Key Elements and Flow Chart
Section 1 – Policies Document
1. Are there any gaps in the issues addressed in this document?: 

The document appears comprehensive with clear guidance on the circumstances which may preclude or enable the appointment of a prospective Committee member due to a potential conflict of interest.  There is discussion of the type of disclosures necessary.  There is also a clear process outlined for the decision as to whether to appoint members of Committees due to a potential conflict of interest and any conditions to be applied.  It is also clearly outlined what the ongoing process for managing conflicts of interest is.

2. Does the document strike the right balance between ensuring adequate expertise is available to be deployed on the committee and creating a framework to ensure conflicts are managed appropriately? : 

It is important that in developing guidelines, experts in the relevant field are appointed to committees to inform the guideline.  It is likely that many of these experts will have some potential conflict of interest due to the receipt of honorarium, research funding etc. and so having a process in place to ensure these people are not automatically excluded from committees and can provide the benefit of their expertise is vital.  The Policies Document gives due consideration to this.

3. Do you have any suggestions for further guidance on matters to be declared?: 

No further suggestions made.

4. Is there anything that should be declared which has not been included in this section?: 

No further suggestions made.

5. Is the amount to trigger a declaration of interests reasonable?: 

The amount of $1000 or more per year and $3000 or more over the past three years appears reasonable when compared with the UK National Institute for Health and Clinical Excellence (2007)’s requirement that “Non-personal interests involving less than £1000 from all sources in the previous year need not be declared”.

Section 2 – Key Elements and Flow Chart
1 - Are there any gaps in this section in relation to the guidance for the responsible Senior Officials at the Office of NHMRC to apply their judgement in how to manage any conflicts?: 

Examples of the disclosures which may give rise to a conflict of interest are clearly stated as are the circumstances in which a committee member may be appointed or precluded from appointment.  There is also a clear process for the Senior Officer to follow in considering the appointment of a committee member.

2. Is the flow chart an adequate representation of the proposed process?: 

Yes

Page reviewed: 5 November, 2012