Division of Medical Ethics Conflict of Interest Disclosure Policy

The Division of Medical Ethics strives for transparency in all facets of its research and scholarship, including disclosure about relationships with companies, organizations, and other institutions. However, division members cannot achieve such transparency by listing only an entity that one works with; without substantive information about the nature of that work, the disclosure seems inadequate. The division seeks to pioneer a form of more thorough disclosure that can be maintained and updated on a website available to anyone who wishes to see it.

For this reason, Division of Medical Ethics faculty are urged to adopt this broader concept of transparency by including in their statements:

  • all significant financial relationships (greater than $500), including sources of funding, honoraria, or any compensation for work, including travel-related expenses
  • affiliations with political, advocacy, legal, or similar organizations, if relevant to a member’s work, including work performed for organizations and compensation received from them
  • any other relationships that they may consider relevant

Such disclosures should include the nature of relationships. Stating that one is a consultant for a pharmaceutical company could imply several types of potential relationships while revealing very little. Instead, the type of work for or relationship with the company should be explained. For example, Division of Medical Ethics founder Arthur Caplan, PhD, doesn’t just state that he consults for Johnson & Johnson; his disclosure explains that he is the chair of a panel of patient advocates, bioethicists, and physicians that advises the company on how to allocate investigational agents on a compassionate use basis.

Disclosures can also be tailored to audiences. The author of a survey about pharmaceutical company malfeasance need not reveal ties to, say, Planned Parenthood, while the same author’s commentary about the United States Congress’s cuts to international family planning programs should. Similarly, work with a foundation trying to enact physician assisted dying or for a law firm filing class action suits for price fixing might merit disclosure.

As an example, see the following “beta” model for Dr. Caplan’s disclosure; instead of listing only company names, he explains the relationships he has with companies. Those viewing his web page (or his slides) can see that he is not merely an industry consultant but, in the case of Janssen, the creator of a panel that advises the company on compassionate use; or, in the case of the inhaler study, part of a data safety monitoring board whose creation was required by federal regulators.