Principles, Policies, and Process
(Revised January 2009)
The American Society of Hematology (ASH) is dedicated to
advancing the specialty of hematology. To accomplish this mission, ASH provides support for a variety of
activities in the areas of research, education, training, and advocacy. The integrity of ASH and the activities it
undertakes depends on the avoidance of conflicts of interest, or even the
appearance of conflicts, by the individuals involved with those activities.
ASH has adopted eight
principles that underscore its commitment to managing real/perceived conflicts
of interest, as well as eight policies that lay out specific ways in which the
Society safeguards the integrity of the programs and activities in which its
membership is engaged. People involved in ASH activities should review the ASH Conflict-of-Interest Policy below and submit their disclosures online.
I. Principles
Principle 1: The integrity of ASH
and the scientific, educational, and advocacy activities it undertakes depend
on the avoidance of bias arising from conflicts of interest, or from the
appearance of such conflicts, by the individuals involved with those
activities. Personal financial considerations must never be allowed to cloud
physicians’ and scientists’ decisions on care of patients, safety of drugs or
devices, or proper conduct of biomedical research. Continuing medical education (CME) provided
to physicians by ASH must be free of bias devolving from financial arrangements
or considerations.
Principle 2: A conflict of
interest exists when an individual has material interests, regardless of value
or dollar amount, outside of ASH that could influence or could be perceived as
influencing his/her decisions, actions, or presentations. These interests, which include employment,
consultancy, equity, research funding, honoraria, patents and royalties,
speakers bureau involvement, advisory committee or board of directors
membership, expert testimony, and financial support for the costs of travel to
the ASH annual meeting, are relevant if they occurred in the past 24 months for
the volunteer, partner, or spouse. Conflicts of commercial interest may involve either an agent or device
as the subject in question or an agent or device that might be in competition
with the subject in question.
Principle 3: The atmosphere ASH
desires is one where people are comfortable asking questions relating to
conflict of interest without feeling awkward or accusatorial and where recusing
one’s self from participation in discussions that might be perceived as
constituting a conflict is the norm rather than the exception.
Principle 4: Having a member of
ASH with a conflict of interest does not necessarily preclude participation in
ASH activities. In fact, such external
relationships may enhance the value of that member to the Society.
Principle 5: ASH subscribes to
the view that research and development sponsored by the biomedical industry
play an important role in biomedical research and that academic-industrial
relationships have developed useful and life-saving products.
Principle 6: The mission of ASH
does not include marketing of pharmaceutical or biomedical products. While opportunities do exist for purchase of
space for commercial displays at the ASH annual meeting and while Blood sells
advertising pages, the revenues generated are devoted to the support of the
Society’s mission. To this end, strong
firewalls have been designed to insulate ASH from inappropriate commercial
influence.
Principle 7: The ASH policies are
congruent with the positions of the Accreditation Council for Continuing
Medical Education (ACCME) that state: (a) commercial support for CME must be acknowledged, (b) no employees or
staff consultants in the interested company can be involved in the development
of the CME activities, and (c) attendees be encouraged to report on their
perceptions of any possible bias.
Principle 8: The considerations
of conflict of interest are relevant not only to clinical research but may extend
to all phases of biomedical research, including pre-clinical research. In pre-clinical research, financial conflicts
of interest are particularly apt to lead to bias if the work is “reasonably
anticipated; (a) to be a component of an Investigational New Drug application (IND) submission or (b)
to progress to research involving human subjects within the coming 12 months.”
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II. Policies
The requirements of ASH apply to all persons who:
- Are employees of
ASH;
- Seek to make
presentations at any ASH meeting or to submit material for any ASH publication;
or
- Serve on the
Executive Committee or other committees, or otherwise serve in an official
service capacity on behalf of the Society.
Policy 1: Some individuals
serve as expert witnesses, officers, directors, or members of scientific
advisory boards of companies, participate in company-sponsored speakers’
bureaus, or accept subsidies for the costs of travel to the ASH annual
meeting. All of these activities
represent conflicts of interest.
Policy 2: ASH holds its
members serving in governance positions to certain standards with regard to
conflict of interest. Specifically, when
an ASH member has a conflict, s/he will not:
- Take any action on
behalf of ASH concerning the subject in conflict or any issue relevant to the
subject in conflict;
-
Participate in
discussions on the subject without full disclosure;
-
Participate in
decision-making discussions or cast a vote;
-
Imply that he/she is
acting on behalf of ASH when discussing the relevant subject with third
parties;
-
Fail to clarify with
third parties with whom he/she deals on the relevant subject that he/she is not
acting on behalf of ASH; or
-
Share confidential
information, including disclosure of embargoed abstract data which would break
laws relating to insider trading.
Policy 3: ASH has the right to
take action regarding individuals who have exhibited biased behavior or
action. These actions may include:
- Requiring an
individual to choose between the competing activities.
-
Prohibiting an
individual from playing a decision-making role in ASH relevant to the conflict.
-
Prohibiting an
individual from presenting at ASH-sponsored events.
-
Exclusion from
publishing in Blood or other ASH publications.
-
Exclusion from
participating in ASH committees.
-
Revocation of
membership in ASH.
Policy 4: No donor, commercial
or otherwise, can select speakers or awardees or be involved in the production
of educational and/or scientific content.
Policy 5: Commercial support
for CME must be acknowledged and no employees or staff consultants of the
interested company can be involved in the development of the content of CME of
ASH. Meeting attendees are provided with
a formal opportunity to report on their perceptions of any possible bias in
their review of the sessions for CME credit.
Policy 6: ASH considers
certain clearly defined types of academic consulting and fees exempt from its
definition of reportable financial interests, e.g., fees received for serving
on grant application review groups (study sections) and fees given as honoraria
(less than $2,500 per event) by another academic institution for an academic
activity, such as seminars and grand rounds.
Policy 7: Special precautions are taken to safeguard against a
potential conflict of interest with regard to the Clinical Research Training
Institute, which is targeted at helping trainees (fellows and junior faculty)
who are early in their careers and wish to obtain the skills needed to design
and conduct studies involving human subjects. More specifically, there are no corporate exhibits or handouts, no
corporate contributions have been sought for funding, and it is the firm
position of ASH that none will be solicited at any time in the future. From time to time, speakers who work for a
pharmaceutical company are included as faculty because of their knowledge of
the drug development process. These
individuals are chosen solely for their knowledge of the subject matter, and
they do not make promotional presentations of any kind at the Clinical Research
Training Institute.
Policy 8: From time to time, ASH will sponsor an
activity designed to develop evidence-based clinical guidelines. Any candidate for membership on a guideline
writing panel who has a financial relationship with a company whose drugs or
devices might be included in the guideline will be excluded from
consideration. The guideline writing
panel will gather data from a wide variety of sources, including the relevant
company and scientists or physicians who are actively working with that
company. This is critical because the
guideline writing panel will need input from those most knowledgeable about the
subject. The guideline writing panel
will then apply evidence tests to the information gathered to determine how
much it can be relied upon in formulating the guideline. As is the case with all ASH committees, the
guideline writing panel will have a Conflict of Interest Compliance Officer
assigned who will monitor any potential conflicts of interest that could
influence the guideline.
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III. Process
Appropriate disclosures must be completed by anyone
involved in ASH activities – committee members, annual meeting organizers and
speakers, program planners for CME programs, and/or anyone involved in Blood and other ASH publications. As an ACCME-approved provider, ASH fully
complies with the CME rules regarding meeting program design and speaker
disclosure. ASH continues to separate corporate-sponsored symposia from the
official ASH annual meeting and now prohibits anyone who participates in a
corporate program from being invited as an ASH speaker in the same year. ASH has put enforcement mechanisms in place
to ensure that oral and poster presentations fully disclose conflicts of
interest; ASH has also increased the number of hematologists who formally
review educational and special speaker presentations – as well as
corporate-sponsored symposia – for any bias or the appearance thereof. A centralized system tracks speakers who fail
to comply with conflict of interest requirements; the system is being expanded
to allow Web-based management of the process.
ASH policies apply generally to all types of conflicts, not
just financial. More often, the bias of
conflicts are institutional and personal ties that must be managed in ASH
committee meetings and study sections.
All Conflict-of-Interest disclosures must be submitted online.
Questions and comments
regarding the ASH conflict of interest principles and policies can be directed
to the ASH Chief Operating Officer, Matthew Gertzog
at mgertzog@hematology.org.
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