POLICY ON TRANSPARENCY AND THE MANAGEMENT OF CONFLICTS OF INTEREST (August 2012)

Aim

The aim of this policy is to protect both the National Clinical Effectiveness Committee (NCEC) and individual members from any real or perceived conflicts of interest (COI).

This policy applies to the committee members of the NCEC, and any subgroups of the committee.

What are conflicts of interest?

The Institute of Medicine define COI as ‘a set of circumstance that creates a risk that professional judgement or actions regarding a primary interest will be unduly influenced by a secondary interest’

Other descriptions include:

·  ‘A divergence between an individual’s private interests and his or her professional obligations such that an independent observer might reasonably question whether the individual’s professional actions or decisions are motivated by personal gain, such as financial, academic advancement, clinical revenue streams, or community standing’

·  ‘A financial or intellectual relationship that may impact an individual’s ability to approach a scientific question with an open mind’

·  ‘Intellectual COIs are academic activities that create the potential for an attachment to a specific point of view that could unduly affect an individual’s judgment about a specific recommendation’

In the context of the work of the NCEC, a COI is any interest that could result in bias in the work or decision making processes of the NCEC.

A conflict of interest may include:

·  Participation in the development or endorsement of a clinical guideline being considered by NCEC

·  Research interests, funding or intellectual property rights associated with a clinical guideline under consideration by NCEC

·  Employment, consultancy, ownership of shares or receipt of gifts or bursaries from any body with a commercial interest in a clinical guideline under consideration by NCEC

·  Any other interest that an individual considers could be a conflict in the work or decision making processes of the NCEC.

Why do conflicts of interest matter?

The NCEC accepts that a COI may exist and that to avoid or eliminate them entirely is unlikely to be possible for the NCEC. However, if they are not managed effectively and the NCEC is seen or perceived to be abusing its influence in the endorsement of national clinical guidelines, the consequence will be serious, including loss of confidence by healthcare professionals and the public. COI that are identified, acknowledged and appropriately managed will ensure transparent and good decision making by NCEC.


NCEC Management of Conflicts of Interest

The NCEC has developed this policy to protect both the National Clinical Effectiveness Committee (NCEC) and individual members from any real or perceived conflicts of interest (COI). This policy has not been adopted or adapted from international policies, rather, it has been developed following review of national and international work and consideration of the context of Irish healthcare delivery. The policy will be reviewed and may evolve over time with experience and changing requirements of the healthcare system.

1. The declaration of interests

All members are required to declare their interests in connection with their role in the committee.

The declaration of interests needs to be updated:

·  At each NCEC meeting

·  When a member identifies a change in their conflicts of interest

·  When a new clinical guideline or audit is being considered

2. Recording of interests

Interests will be recorded on the committee’s register of interests, which will be maintained by the committee’s administrative support.

3. Managing a declared conflict of interest

The chair of the NCEC is responsible for managing COI. The chair should have no COI. Where the chair of the committee has a COI in relation to a particular item and/or decision, an alternate chair will be nominated by the committee for that item and/or decision. There will be a tiered approach to the actions required upon declaration of a conflict of interest by a member. This will be based on the risk that professional judgement or actions of the member will be unduly influenced by the COI.

Response to COI includes:

·  Exclusion of interested member from all discussion

·  Exclusion of interested member from decision making

·  Disclosure and recording of COI


DECLARATION

Date: <deadline submission date>

Name of clinical guidelines being considered:

<list all received guidelines corresponding to above submission date

(please circle the statement that relates to you)

1. I declare that I DO NOT have any conflicts of interest.

2. I declare that I DO have a conflict of interest.

Details of conflict (Please refer to specific clinical guideline)

______-______

(append additional pages to this statement if required)

Signature

Printed name

Registration number (if applicable)

Date

The information provided will be processed in accordance with data protection principles as set out in the Data Protection Act. Data will be processed only to ensure that committee members act in the best interests of the committee. The information provided will not be used for any other purpose.

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