examples of what supporting organizations can do. Many involve collecting and making public information about which institutions have adopted and applied the recommended policies. The committee expects that the prospect of such reporting would motivate institutions to close the gaps and loopholes in their conflict of interest policies or to provide a vigorous justification of why their policies depart from the recommendations.

If voluntary measures to deal with conflicts of interest are perceived to be weak or ineffectual, then calls for additional legislation or regulation or the more intrusive or punitive enforcement of existing laws will likely grow. The opportunity to preempt sweeping and potentially burdensome legal requirements should give a sense of urgency to voluntary efforts to establish and implement conflict of interest policies that reassure the public and those who make public policy. Government directives and prohibitions can be blunt instruments for dealing with conflict of interest problems, which often call for subtle judgments of risks and benefits and which involve many uncertainties. They also may not be as sensitive as voluntarily adopted measures to the administrative burdens of compliance or the possibility of unintended adverse consequences. This caution should not be interpreted as an endorsement of lax agency oversight or the lax application of existing conflict of interest rules.

Building the Evidence Base for Policy Improvement

As has been observed throughout this report, little systematic information about conflict of interest policies is available. This lack of information extends from basic descriptive information about policies to evaluations of the effects of different kinds of policies and implementation strategies.

RECOMMENDATION 9.2 To strengthen the evidence base for the design and application of conflict of interest policies, the U.S. Department of Health and Human Services should coordinate the development and funding of a research agenda to study the impact of conflicts of interest on the quality of medical research, education, and practice and on practice guideline development and to examine the positive and negative effects of conflict of interest policies on these outcomes.

Within the U.S. Department of Health and Human Services, NIH, the Agency for Healthcare Quality and Research, and the Food and Drug Administration should be involved in defining a research agenda that addresses questions and concerns about implementing, enforcing, and possibly refining conflict of interest policies. The research agenda not only should investigate government policies, however, but also should investigate the



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