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Appendix F: Model for Broader Disclosure
Pages 384-391

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From page 384...
... Krughoff, and George Loewenstein We believe that the recommendations in Chapter 3 regarding disclosure of financial relationships or conflicts of interest would be greatly improved if they explicitly called for more extensive and standardized public disclosure by researchers, physicians, and senior officials of institutions. We believe that -- with the help of interpretation by the press, public-interest groups, researchers, health care consultants, patient representatives, and other information intermediaries -- expanded disclosure would provide important information for physicians, patients, researchers, health plans, regulators, policy makers, financial donors, and others who rely on research, practice guidelines, educational programs, and the quality and efficiency of medical care.
From page 385...
... We envision the broader-disclosure model working as follows: • The first time that a person was required to report information on financial relationships or conflicts of interest to an institution, he or she would register on the secure national online database system; create a profile with name, location, and other nonconfidential information; select a permanent ID; and get a confidential password. The system would have procedures for verifying the person's identity.
From page 386...
... • The centralized nature of the system would make it easier to update reporting requirements for everyone involved if future consensusdevelopment processes deemed it important to include different types of information in standard reports. • The model would allow persons who might rely on information on financial relationships or conflicts of interest to obtain it when they want it -- for example, before enrolling in a continuing medical education program or long after participating in one, or when meeting with family and friends before or after meeting with a surgeon rather than in the brief time with the surgeon.
From page 387...
... We conclude that greatly expanded requirements for public disclosure would create incentives and monitoring tools that would reduce the risk posed by some of the conflicts that it might not be practical to eliminate. As documented throughout this report, there are serious limitations in the accuracy, completeness, comparability, and timeliness of conflict of ­ interest information reported to institutions and to the public -- for e ­ xample, as conflicts are shown in National Guideline Clearinghouse documentation of practice guidelines or as conflicts are reported by speakers in continuing medical education programs.
From page 388...
... There are numerous examples of public reporting of financial information currently in effect that have not been shown to have substantial adverse consequences or to discourage people from participating in the institutions or programs that require reporting -- for example, the required public disclosure of salaries of government employees, the public disclosure of individual contributions to political candidates, the public disclosure (on Internal Revenue Service Form 990) of salaries of higher-paid employees of most tax-exempt nonprofit organizations, and, most pertinent, the currently required public accessibility, under state freedom of information laws, of financial relationships or conflicts of interest reported to state universities and health care systems.
From page 389...
... proposal for the disclosure of physician-ownership interests in health care facilities would provide information about conflicts of interest that are more likely to influence physician decisions about patient care. A second concern of the committee majority involved intrusions on privacy if physicians and researchers were required to make public the additional information that they disclose to academic medical centers and other institutions.
From page 390...
... For example, the proposed unified database would require that the additional disclosures be approved for integration into a federally mandated and overseen database of company-reported payments, or, alternatively, some party would have to create and manage an integrated, secure private database. Either would involve additional costs for creating, maintaining, updating, and correcting the integrated database and maintaining security.
From page 391...
... The likely burdens on individuals and institutions of an expanded publicdisclosure system beyond that proposed in Recommendation 3.4 or already in place in accordance with other public or private policies are disproportionate to any benefits from the marginal amount of additional information that would be provided.   According to Recommendation 3.3, consistency in institutional disclosure requirements and formats would increase and reporting burdens would decrease for people who must make disclosures to multiple institutions.


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