Challenges of Assessing Disclosure Accuracy—All We Have Is Our Integrity

Abstract

Financial interests of any magnitude have been shown to influence physician behavior, with potentially significant impacts on clinical practice. Over the last decade, scientific and medical societies, journals, and medical research organizations have devoted a great deal of effort to promoting transparency with regard to financial conflicts of interest (COIs). A consensus has emerged in the biomedical community that transparency (buyer beware) should be the minimal standard observed to ensure that consumers of research, practice guidelines, and other professional output are aware of potential biases on the part of authors. Some recommendations go further, positing that in certain cases, researchers and authors should have no COIs.So it would appear disappointing that, as Nyugen et al 1 report in JAMA Ophthalmology, based on a comparison with data published in the CMS Open Payments website, 2 a large percentage of the authors of 24 American Academy of Ophthalmology (AAO) clinical practice guidelines published between 2016 and 2020 failed to disclose their financial interests accurately or at all in connection with guideline development.The study authors point out that practice guidelines (AAO terms them preferred practice patterns) can directly impact patient care, making the importance of transparency on the part of guideline authors all the more critical.There are some important limitations to the study, however. AAO's COI policy 3 and the Council of Medical Specialty Societies Code for Interactions with Companies, to which AAO has signed on, require guideline authors to disclose direct financial relationships to AAO. Consistent with the Council of Medical Specialty Societies code, AAO's COI policy indicates that relevant financial interests will be identified, mitigated, and/or disclosed, depending on the nature of the activity and an individual's role. Notably, each of the AAO's published clinical practice guidelines states, "In compliance with the Council of Medical Specialty Societies' Code for Interactions with Companies…relevant relationships with industry are listed." 4,5 Therefore, one must infer that when a guideline author is listed as having no financial relationships to disclose, a determination was made that none of the guideline author's financial interests was relevant to the subject matter of the guideline. It is unknown whether some guideline authors failed to disclose any direct financial relationships with companies, even if they received payments as reported in the Open Payments website; whether the relationships that were disclosed to AAO were determined not to relate to the content of the guideline; or whether the relationships were judged de minimus and therefore not relevant. (Many COI policies set a minimum threshold for disclosure that is higher than the Open Payments data, which publishes payments over $10.