More than seven years have now passed since I put together this blog post [copied in full below]: It is fair to conclude that reassurances offered by the College in relationship to transparency have largely been false. Indeed, it is my understanding that the College has not responded to the Cumberlege Review: First Do No Harm which includes, as one of its recommendations, the need for the UK to introduce Sunshine Legislation.
In response to my letter to the Royal College of Psychiatrists regarding relationships with pharmaceutical and other commercial organisations I received this e-mail from Professor Nick Craddock, Treasurer of the Royal College of Psychiatrists:
From: Nicholas Craddock
Sent: 13 March 2015
Thank you for your letter of 15th February concerning the revision of CR148 “Good Psychiatric Practice: Relationships with pharmaceutical and other commercial relationships”. The current report along with all other College reports is available on the College’s website.
This report has been reviewed initially by the Committee on Professional Practice and Ethics. Their draft has been sent for comment to the Psychopharmacology Committee and to representatives from the Academic Faculty including myself. The document will then be further revised in the light of comments received before being finally approved by the Policy and Public Affairs Committee. If you would like to submit any written comments perhaps you could send these to the Chair of the Policy and Public Affairs Committee as soon as possible.
The declarations of interests for speakers at the forthcoming International Congress will appear on the Congress App which is available to all delegates. If you are not able to come to Birmingham I can arrange for this to be sent to you. Declarations are currently being collected.
The declarations of interests for speakers at the Old Age Conference will be available to all conference delegates. I can also make these available to you if you are not intending to attend this conference.
Professor Nick Craddock
Royal College of Psychiatrists
21 Prescot Street
London E1 8BB
Here is the reply I have sent to the Royal College of Psychiatrists dated 14th March 2015:
Dear Professor Craddock
Thank you very much for your e-mail of the 13th March 2015 which is most helpful. It is particularly welcome to hear that, in terms of the forthcoming CPD-approved Royal College of Psychiatrists Conference that “the declarations of interests for speakers at the forthcoming International Congress will appear on the Congress App which is available to all delegates.” As I am not coming to this conference I would be most grateful to accept your offer to arrange for this to be sent to me.
I would also like to accept this further offer: “the declarations of interests for speakers at the Old Age Conference will be available to all conference delegates. I can also make these available to you if you are not intending to attend this conference.”
I remain of the view, as articulated in my letter of the 14th February 2015, that The College should have no more difficulty in having a tab on the homepage of these Conferences with declarations of all involved than they do in having a tab on the homepage for “Exhibition opportunities.”
I am also most grateful to be appraised about the process and timescale of the revision of CR148 “Good Psychiatric Practice: Relationships with pharmaceutical and other commercial relationships” which was first approved in January 2008. I note that CR148 contained a “due for review: 2011”.
You have invited me to make comments on this revision to CR148 and to forward these “as soon as possible” to the Chair of the Policy and Public Affairs Committee. I hope this letter will suffice and I will forward it to the Acting Head of Policy as you suggest. I have not been party to any of the considerations to date and for this reason I would like to comment on the existing guidance, CR148, issued January 2008.
The research that I have undertaken across the UK over the last few years, in preparation for advocating a Sunshine Act to the Scottish Parliament, has led me to conclude that this guidance is not being fully followed.
The “principles” of CR148 have a basis on “transparency” and “full declaration of relationships with commercial organisations”. When I was a speaker at the RCPsych Autumn Conference in Durham I was the only speaker to declare my interests in the programme. At the Conference itself, Professor Clive Ballard, one of the other speakers, did not declare any interests at all. Another speaker, Professor Allan Young, a key Opinion Leader in Affective disorders, appeared to belittle transparency regarding the need to declare financial interests. There was no declaration of his extensive financial interests in the programme.
This leads me to my FIRST QUESTION in relation to the proposed revisions of CR148: What consequences will there be for an individual who does not follow the guidance?
CR148 states “psychiatrists should avoid accepting inducements that might compromise the independence of their professional judgement and practice”. We know from ABPI figures that in a calendar year at least £40 million has been paid to UK health professionals by the pharmaceutical industry.
The ABPI have recently introduced a “Central Platform” which will form a central register of individual financial payments to healthcare workers. This will not start reporting till 2016. However the main problem with this register is that individual healthcare workers can opt-out of disclosing payments. Given that the Royal College of Psychiatry is not alone in having struggled to govern its own existing guidance, it is reasonable to have concern that this ABPI “Central Platform” will share such difficulties.
Thus, my SECOND QUESTION: What role, if any, will the ABPI “Central Platform” have in the revised CR148?
The research I have undertaken in NHS Scotland has confirmed that local registers are generally not being maintained and are generally not open to the public.
The Scottish Government has confirmed that the guidance issued on this in 2003, HDL 62, has not been followed. HDL 62 asked the following of Chief Executives:
At annual appraisal all doctors are asked to sign a Probity statement similar to the screenshot below. In this, each doctor confirms that he or she has followed paragraphs 56-76 of Good Medical Practice and complied with local mechanisms of declaring interests. In Scotland, I have evidence that in terms of “transparency” that there are widespread discrepancies here and I fear that public trust in our profession may suffer if we do not take action.
To conclude, my view is that the simplest, most effective, consistent and evidence-based way to ensure transparency regarding financial conflicts of interest would be to have UK legislation that seeks a central, single, open, searchable register that is updated on a regular basis and which is tied to professional accountability and GMC governance. Ideally this would include not just psychiatrists, but pharmacists, academics, allied health professionals and indeed charities. My final question then is what discussions have taken place between the Royal College of Psychiatrists and the GMC on revisions to CR148
- Professor Sir Simon Wessely, President Royal College of Psychiatrists, 21 Prescot Street, London, E1 8BB
- Vanessa Cameron, Chief Executive, Royal College of Psychiatrists, 21 Prescot Street, London, E1 8BB
- Chris Fitch, Acting Head of Policy, Royal College of Psychiatrists, 21 Prescot Street, London, E1 8BB
- Niall Dickson, Chief Executive and Registrar, GMC, Regent’s Place, 350 Euston Road, London NW1 3JN.