David Korn — Creating the First fCOI Policy for Harvard University

The March 2, 2011 seminar was presented by David Korn, Vice Provost for Research at Harvard University, and Professor of Pathology at Harvard Medical School. He discussed the Harvard University Conflict of Interest Policy, and participants explored some of the issues that are addressed by the policy, as well as the loopholes that are created by some of the more ambiguous aspects of the policy.

Participants opened the discussion by questioning the types of financial disclosures that doctors at Harvard are required to provide under the conflict of interest policy. While it does enact restrictions on certain types of activities, participants pointed out other possible types of influence that are not addressed by the policy. For example, there are ways that a pharmaceutical company could facilitate the publication of a book that would result in the physician receiving royalties. They haven't paid the money directly, but they have created a benefit which could influence the physician in favor of the pharmaceutical company. Other participants noted that simply having people report the money they receive does not allow one to distinguish between corrupting types of influence, and more random, benign interactions that are less likely to corrupt someone's behavior.

Besides concerns about how conflicts of interest affect individual researchers, participants also wondered about the ways in which conflicts of interest are addressed at the institutional level. The presenter noted that the university does not accept money that has "strings attached", but participants pointed out a variety of ways that a company could donate money with no strings attached, but still wield a strong influence through that money by using it strategically to distort the system. For example, when a pharmaceutical company donates money, there might be more research on newer drugs, but older drugs get neglected. There may not have been any strings attached to the initial donation, but it can have the effect of distorting the body of research in such a way as to serve the interests of the company.

Participants made a variety of suggestions for how to deal with these less obvious methods of creating bias. One participant asked whether one might plausibly create a committee at the university to examine which questions are not being investigated, and allocate money accordingly. Another participant asked whether it would be possible to restructure how the money gets distributed, so that researchers would not be aware of where their research funds are coming from, thereby alleviating the possibility of influence. Participants also questioned whether it would be feasible to put something in place that would allow for the continual revisiting and revising of the conflict of interest policy, given the likelihood that industry will constantly be looking for strategic ways to exploit loopholes in the existing policy. Dr Korn pointed out that the Financial Conflicts of Interest policy does create, and there has been convened, a Standing Financial Conflict of Interest committee, chaired by the Office of the Vice Provost for Research, that must review and approve each school's implementation plan, and is expressly charged with identifying features of the new policy that need adjustment or revision.

In conclusion, seminar participants considered the methods that industry may use to influence researchers in ways that do not technically violate a conflict of interest policy. They then contemplated a variety of means that universities could use to counteract those methods.

See also: David Korn, Seminars