Disclosure of Conflicts
Let me begin by pointing out that how I view the issue of disclosures may be affected by having received sizeable payments from industry (for speaking, research, and consulting).
A landmark article in JAMA Dermatology reported that authors of dermatology clinical practice guidelines did not fully disclose considerable payments from industry.1 Is the failure to disclose these payments a problem for guideline development?
My first thought when reading this article concerned the methodology; the study authors compared the guideline authors’ disclosures to public disclosures of information on the government’s Open Payments database.2 While the 2 did not match, the “undisclosed” payments to the guideline authors had been publicly disclosed. If disclosure is all that is needed to help assure that guidelines are not biased, the Open Payments system already provides it.2 The problem, if there even is one, is clearly not that the payments were not disclosed; the payments were disclosed, and the study authors, and everyone else, has public access to that information.2
Disclosure, however, does not solve the problem of conflicts of interest. Unexpectedly, biases can be increased by disclosure.3,4
The study authors suggested that perhaps guideline committees should include fewer people who have taken money from industry. Perhaps that would reduce the potential for appearance of bias, but it would also exclude from guideline development the people who best understand the ins and outs of new products, the clinical trial investigators who had firsthand experience with those products. Potentially, instead of those knowledgeable investigators, the committee might be left with financially untainted people who have a bias against industry and against new products, biasing guidelines away from approaches that might be most beneficial to patients.
I think our current system of dermatologic treatment guideline development is quite good already (having served on several such guideline development committees). I think the best controls against biased guidelines are already in place: the devotion of those committee members to patients’ best interest and the face validity of the guidelines that have been developed (along with layers of review and inclusion of physicians who have not taken any payments). If a biased dermatologic treatment guideline were ever promulgated, plenty of dermatologists would notice and speak up about it.
Steven R. Feldman, MD, PhD
Chief Medical Editor
Dr Feldman is with the Center for Dermatology Research and the Departments of Dermatology, Pathology, and Public Health Sciences at Wake Forest University School of Medicine in Winston-Salem, NC.
1. Checketts JX, Sims MT, Vassar M. Evaluating industry payments among dermatology clinical practice guidelines authors. JAMA Dermatol. 2017;153(12): 1229-1235.
2. Open payments. Centers for Medicare & Medicaid Services website. https://openpaymentsdata.cms.gov/. Accessed April 22, 2018.
3. Sah S, Fagerlin A, Ubel P. Effect of physician disclosure of specialty bias on patient trust and treatment choice. Proc Natl Acad Sci U S A. 2016;113(27): 7465-7469.
4. Loewenstein G, Sah S, Cain DM. The unintended consequences of conflict of interest disclosure. JAMA. 2012;307(7): 669-670.