Jean-Christophe Bélisle-Pipon, Louise Ringuette, and Bryn Williams-Jones describe a five-step approach for managing conflicts of interest in public health decision-making.
On a regular basis, shocking news filters into the media about conflicts of interest within public organizations that contribute to policy-making. When such allegations are proven true, public scepticism about whether public interests or commercial interests inform policy-making increases.
Public health decision-making, especially in areas of complex science, is generally supported by expert advice. One such area is publicly-funded immunization. In Canada, the National Advisory Committee on Immunization is an advisory body to the Public Health Agency of Canada, while the provinces and territories rely on advice from local expert advisory committees.
Members of immunization expert advisory committees have an important role to play in guiding public health decision-making, particularly with regard to the selection of vaccines and the scheduling of immunizations. Given this important role, independence and transparency are expected. One mechanism for promoting independence is a robust, publicly available conflict of interest policy.
We suggest a simple five-step approach for better managing conflicts of interest.
First, ask the right questions and identify red flags. What are the interests at stake and for whom?
For example, consider situations where one or more committee members receive(s) significant funding from industry. Are there external interests, as a result of this funding, that may influence the committee’s mandate and activities? This concern applies to private companies with products or business activities related to immunization, or with connections to certain advocacy or interest groups. Also, there may be concerns about the committee’s composition in terms of expertise and diversity, and about the committee’s governance structures. Could these lead to inadequate decision-making or divert committee members from their primary mandate?
Second, assess the nature and scope of conflicts of interest. Is the conflict of interest real or apparent? What is the nature and level of risk, and for whom? Is the conflict of interest manageable, and if so, how and by whom? If not, what resources can guide decision-making with regards to this situation/individual? Not all conflicts of interest are equal. Some may be evident and high-risk, such as an expert who has shares in a company and evaluates the pertinence of the company’s vaccines for a vaccination campaign. Other conflicts of interest may be less obvious and relatively low-risk, for example, an expert who presents at a scientific conference that receives funding from a vaccine manufacturer.
Third, ensure the independence of expert advisory committees. Make sure the membership is diverse, non-stagnant and ‘transparent’. This goal can be achieved by including not only methodological experts, but also non-physician experts, social-science related field experts, patient representative or community stakeholders. Together this group of members could provide a more nuanced view of any problem under study. It would also be important to publicly disclose members’ identity and conflicts of interest declarations, and to avoid including too many experts from the same institution (or trained in the same place or by the same people).
Fourth, do not reinvent the wheel. If the expert advisory committee has no official policies, draw on best practices in conflict of interest management to implement policies and procedures tailored to the needs of the organization. For example, university policies or procedures for conflict of interest management could be used. Conflict of interest policies should be assessed independently and externally. For example, the head of the committee should not be the only person responsible for conflict of interest management (especially if she has a conflict of interest!). Further, a credible and independent external resource should help arbitrate and handle complex and challenging situations.
Fifth, be proud of good practices. Make public and easily accessible all conflict of interest policies and procedures, demonstrating that these meet leading standards in the scientific community and that the organization has nothing to hide.
Conflicts of interest are endemic and sometimes unavoidable in the current context of knowledge production and in the development of recommendations. While conflicts of interest are problematic situations, they do not automatically constitute misconduct or a breach of scientific integrity. Broadly speaking, good conflict of interest management can take two forms: ‘describe’ (disclosure and education) or ‘diminish’ (prevention, independent review, sanctions).
The objective in managing conflicts of interest should always be to foster professional ethics and personal integrity of public health experts while ensuring support through practical institutional governance mechanisms. This represents the very basic environment in which valid and sound scientific advice can be produced, so that decision-makers can make informed decisions in the public interest, and which the general public can trust.