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4 Opportunities to Build Trust
Pages 65-90

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From page 65...
... On the whole, this National Academies of Sciences, Engineering, and Medicine (the National Academies) committee believes the current selection process -- identifying individuals and creating a diverse panel -- can reasonably lead to the appointment of a fair and balanced Dietary Guidelines Advisory Committee (DGAC)
From page 66...
... This National Academies committee used these five values of an "ideal" selection process to assess the current DGAC selection process. The discussions in the following sections describe that assessment, recognizing that each characteristic does not necessarily apply to every step of the process.
From page 67...
... For example, the membership balance plan for the 2015 DGAC states that its members would be balanced across many dimensions, including diversity across geographic areas, academic institutions, gender, race, ethnicity, and disability. However, this National Academies committee's review of previous DGACs found a preponderance of DGAC members from the northeast, while noting inclusion of several members from the midwest and south.
From page 68...
... ENHANCE TRANSPARENCY DURING CANDIDATE REVIEW "Conduct a review of nominations and propose a slate of candidates" (see step 3 in Figure 2-1) is inherently the most subjective step in the current DGAC selection process.
From page 69...
... . This National Academies committee deliberated three options for improving the openness of this step.
From page 70...
... Candidate Review Option 2 One way to reduce the bias and perceived influence of political interests in the DGAC is to remove the selection process entirely from USDA and HHS. This would involve finding a third party that could identify and review all candidates and develop and appoint a balanced panel of experts.
From page 71...
... Although it is uncommon for other organizations to conduct all the steps and not be the final appointing authority for a federal advisory committee, the National Vaccine Advisory Committee may provide a model for a more limited third party role in committee selection. In this case, the legislation states that the National Academy of Sciences (NAS)
From page 72...
... There is no absolute guarantee that a third party will reduce bias; there is no evidence to say that a third party would not come up with the same exact committee of experts as assembled by the current process. Additionally, the secretaries of USDA and HHS remain the appointing authorities under this option.
From page 73...
... At a minimum, this National Academies committee believes divorcing the screening process from the appointment authority would improve perception that the DGAC process is more neutral than it currently is. The committee believes the proposed separation of the processes also has the potential to actually reduce bias.
From page 74...
... Additional criteria for considering candidates ought to include willingness to serve; minimal financial and nonfinancial conflicts of interest (see Boxes 3-2 and 3-3) ; biases that can be balanced with those of other members; and prior experience working on advisory committees or panels.
From page 75...
... DGAC COMPOSITION As described in Chapter 2, in accordance with FACA, agencies are required to consider candidates from all backgrounds who are "directly affected, interested, and qualified, as appropriate to the nature and functions of the advisory committee." Advisory committees providing technical guidance should also include people with "demonstrated professional or personal qualifications and experience relevant to the functions and tasks to be performed."3 The 2015 DGAC membership balance plan identifies a set of 17 specialty areas to be represented, ranging from osteoporosis to nutrition-related systematic review methodology. However, 3Federal Advisory Committee Act of 1972, 41 C.F.R.
From page 76...
... These are interdependent steps, but one must come before the other. The current process relies on the DGAC to develop priority topics for review rather than for an a priori process to identify which updates and reviews are most critically needed, thus influencing the expertise needed on the DGAC.
From page 77...
... ADDITIONAL PUBLIC COMMENT PERIODS As discussed in Chapter 2, the current selection process seeks public comment through a call for nominations in the Federal Register and relevant online mailing lists (USDA/HHS, 2016a)
From page 78...
... Two models were considered for receiving additional public comments based on a review of other processes. Public Comment Period Option 1 In addition to a public call for nomination, some agencies request public comments on qualified candidates.
From page 79...
... Use of multiple public comment periods would help minimize scrutiny as to why one person was originally listed as an alternate if the alternates are never turned to. It also reduces the burden on DGAC alternates by eliminating the need for these individuals to provide their entire history of potential conflicts of interest and reduces the possibility of unwarranted attacks.
From page 80...
... For the purpose of improving transparency, this National Academies committee did discuss posting public comments about each candidate, as well as explanations by USDA and HHS regarding why each primary and/or alternate candidate was or was not selected to serve on the DGAC. Candid information from the public about proposed members is critical for a deliberative process.
From page 81...
... The literature broadly supports the notion that disclosure and management of conflicts of interest is a necessary part of establishing public trust and increasing transparency in guideline development (Barrow and Conrad, 2006; Gessner et al., 2010; Rowe et al., 2009, 2013; Schünemann et al., 2006, 2015)
From page 82...
... . Specific studies of authors' financial relationships with guideline recommendations were found to be limited in the following areas: •  ositive associations between authors' financial conflicts of interest and P guideline recommendations.
From page 83...
... The review found that all relevant individuals should disclose any potential conflicts of interest. If no conflicts exist, individuals should serve on the committee as planned, and should disclose anything that arises during their course of service that could be a potential conflict (Graham et al., 2015)
From page 84...
... This National Academies committee believes the OGE Form 450 adequately covers financial conflicts of interest, but it did not find any explicit, formal steps for DGAC candidates to disclose nonfinancial conflicts or biases. To enhance transparency, a form should be developed and used for the disclosure of nonfinancial conflicts of interest and biases.
From page 85...
... The executive branch of the federal government relies on its ethics officers and the OGE to make determinations about potential financial conflicts. However, assessment of biases and nonfinancial conflicts are more difficult to make.
From page 86...
... Recognizing these risks, how biases and conflicts of interest are managed is critical, and rigorous policies ought to be followed. Transparent Process for Assessing Bias and Conflict of Interest The current selection process for the DGAC requires members be screened for financial conflicts of interest and attend ethics training.
From page 87...
...  ertifying that a federal ethics officer independently C reviewed and judged the advisory committee's biases and conflicts of interest; d.  ocumenting how conflicts of interest were managed in D the Dietary Guidelines Advisory Committee report.
From page 88...
... 2014. Conflicts of interest and clinical recom mendations: Comparison of two concurrent clinical practice guidelines for primary immune thrombocytopenia developed by different methods.
From page 89...
... 2011. Conflicts of interest in cardiovascular clinical practice guidelines.
From page 90...
... 2015. Author financial conflicts of inter est, industry funding, and clinical practice guidelines for anticancer drugs.


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