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Draft Policies for NHMRC Committees and Working Groups Developing Guidelines Submission

Personal Details
Organisation Name: 
Australian Medical Association
C. Additional Information
Please identify the best term to describe the Organisation: 
E. Submission
Submission options: 
Section 1 – Policies Document
Section 2 – Key Elements and Flow Chart
Make general comments
Section 1 – Policies Document
1. Are there any gaps in the issues addressed in this document?: 


The document does not address what happens if an individual fails to disclose, or misrepresents, an interest. To maintain public confidence that the NH&MRC will act appropriately under these circumstances, it’s important for the NH&MRC to indicate what processes are in place to address the failure to disclose, or the misleading disclosure, of relevant interests, as well as the procedures for recourse by the accused individual.

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

The document addresses the identification and management of current interests but does not acknowledge in any detail relevant past or future interests that can also play an important role in the perception, or actual development, of a conflict of interest. The NH&MRC’s earlier Discussion Paper entitled NHMRC consideration of disclosure of interests and management of conflicts of interest in NHMRC activities raised the issue of length of time of interest and identified whether or not it is important to declare past (eg., past 3 years) or future (eg., next 12 months) interests as well as current interests. In response, the AMA supported the declaration of both past and future (as well as current) interests as being important for purposes of disclosure. The NH&MRC should reconsider this issue.


Thank you for providing the Australian Medical Association (AMA) with the opportunity to comment on the document Identifying and Managing Conflicts of Interest: Draft Policies for NHMRC Committees and Working Groups Developing Guidelines.

The AMA believes the NH&MRC serves a vital role in the community by supporting health and medical research and guidance in Australia. In order for the NH&MRC to carry out its work, it’s essential that the public maintain trust and confidence in the integrity of the NH&MRC processes. The development and promotion of policies on identifying and managing conflicts of interest for NH&MRC committees and guideline development working groups is an important factor in this.

Page reviewed: 5 November, 2012