The Scottish Government: “we are not aware”

This report, written by Marion Scott, was recently printed in the Sunday Mail:

Why paid, and to who (6-9-15)

The Cabinet Minister for Health, Wellbeing and Sport, is quoted as saying:

We are not aware

I was surprised by this Scottish Government statement.

Open and transparent from omphalos on Vimeo.

For the last four years, in research for my petition to the Scottish Parliament for a Sunshine Act, I have collected evidence and have shared this with the Scottish Government. This can all be read here.

Scottish Government Guidance (HDL 62), which is now 12 years old, is widely being ignored by NHS Health Boards across Scotland. There is no public transparency on how much of this £41 million went to Scottish doctors last year.

41 million

Whilst the Scottish Government are “not aware” it is reassuring that young folk of today, such as medical Students, are:

Educating future drs on industry pressures

Royal College of Psychiatrists: relationships with pharmaceutical and other commercial organisations

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 15:17

Dr Gordon
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.

Yours sincerely
Nick Craddock

Professor Nick Craddock
Treasurer
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.

Forefront 2015

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.”

Old Age March 2015 RCPsych

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.”

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”.

CR148 cover

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.

CR148 principles

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.

debate-as-set-out (2)

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 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.

40 million

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?

CR148 Registers of members interests

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:

HDL-62

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.

Probity statement SOAR Appraisal (Jan 2014)

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

Yours sincerely

Peter signature
Dr Peter J. Gordon

Copied to:

  1. Professor Sir Simon Wessely, President Royal College of Psychiatrists, 21 Prescot Street, London, E1 8BB
  2. Vanessa Cameron, Chief Executive, Royal College of Psychiatrists, 21 Prescot Street, London, E1 8BB
  3. Chris Fitch, Acting Head of Policy, Royal College of Psychiatrists, 21 Prescot Street, London, E1 8BB
  4. Niall Dickson, Chief Executive and Registrar, GMC, Regent’s Place, 350 Euston Road, London NW1 3JN.

Royal College of Psychiatrists and conflicts of interest

The Chief Executive of the General Medical Council (GMC) recently confirmed, in response to a recent BMJ article, that it “takes very seriously the issue of conflicts of interest”:start-with-GMC

We know that in the course of a year, in the United Kingdom:40 million

Currently, it is almost impossible to find out anything other than the overall figure.

NHS registers of interest are not functioning. Yet doctors are asked to sign this at annual Appraisal:Probity-statement-SOAR-ApprAll Appraisals are then scrutinised by senior NHS managers to be “signed off”:

The BMJ make this charge:failure of regulation

However should we be asking if our Royal Colleges are also failing?

For several years I have written to the Royal College of Psychiatrists about conflicts of interest. This post is based on the latest correspondence which was prompted by the recent announcement of this International Conference:

change-my-practice

The Co-chairs give this welcome note:welcome-by-co-chairs

It is almost certain that a significant proportion of the £40 million goes to: KOLs2

The Conference organisers have made it clear of the “exhibition opportunities” provided at this event:exhibition-opportunities

What is less clear is whether the speakers or those involved in workshops or seminars have any conflicts of interest.

This is why I have written to:Board-RCPsych

My most recent letter to the above, copied to the Chief Executive of the GMC, asks for transparency ahead of the Conference in this important area:Craddock-letter

 

 

 

 

 

 

“A probity issue and may lead to a failure to revalidate”

Here is a submission to the BMJ by S. Musheer Hussain, Consultant & Hon Professor of Otolaryngology, Ninewells Hospital & University of Dundee Medical School:
CropperCapture[1]
Here is relevant communication with NHS Tayside on a register of interests

NHS Boards are not following existing guidance

The Petitions Committee of the Scottish Parliament are to meet on Tuesday 27th January 2015 to give further consideration of my petition for a Sunshine Act, PE1493. I lodged this petition in September 2013. What follows below is the full transcript of a letter of update to the Committee:

Friday, 23rd January 2015

To: Sigrid Robinson
Assistant Clerk
Public Petitions Committee
The Scottish Parliament
petitions@scottish.parliament.uk

Dear Ms Robinson
Scottish Parliament Public Petition PE1493 on a Sunshine Act for Scotland

Thank you for informing me that my petition is to be considered by the Public Petitions Committee at its meeting on Tuesday 27th January 2015.

You suggested that I might like to make a short written submission for the meeting of the Committee informing me that this would be published online with the other evidence that the Committee have gathered for Petition PE1493.

Before I offer a brief summary, a year on almost to the day from my last written submission, I would like once again to thank the Committee, and supporting staff, for continuing to explore how the people of Scotland might benefit from a Sunshine Act.

I understand from your communication of the 20th January 2015 that the Committee, “despite numerous reminders,” has received no response from the Scottish Government. I am disappointed to hear this, particularly as the summary produced by the Scottish Government, in their letter of 17 April 2014, would appear to demonstrate wide failings in NHS Scotland’s Compliance with HDL (2003) 62. Given these failings, in December 2014 I contacted all 14 regional NHS Boards for further clarification and in the hope of progress. I have so far had reply from only 2 NHS Boards.

NHS Forth Valley and NHS Tayside now have a central register of interests for all staff. Both have now made these registers publicly accessible.

NHS Forth Valley: the current register includes the names of only 7 staff and all the other entries are by designation only. NHS Forth Valley’s register is therefore not complete in that it does not consistently identify individual staff. The Director of Education for NHS Forth Valley, confirmed last year in writing that he was “not aware” of HDL (2003) 62. The Director of Education also confirmed that Forth Valley’s “learning Centre” has no budget that pays for educational meetings”.

NHS Tayside: is the only other Health Board to reply to my recent request for an update and provided the public link to their Register. The register begins in 2011 and records 16 entries, and each without any identifying name. Ms McLeay, Chief Executive, stated in her reply of the 30th December 2014 “I agree that this public record of sponsorship is not complete and accurate at this point”.

NHS Lothian: I have had no reply to my recent communication on HDL (2003) 62. The situation as recorded in FOI reply from NHS Lothian dated 6th May 2013 stated: “There are no other [apart from Board members] centrally held registers available within NHS Lothian and any such register would not necessarily identify payments to staff”.

NHS Greater Glasgow: I have had no reply to my recent communication on HDL (2003) 62. Following my original FOI request (before I lodged this petition in September 2013) NHS Greater Glasgow attached a register that covered 5 years and had entries for 27 separate employees. NHS greater Glasgow is the largest health board in the United Kingdom, serving 1.2 million people and employing 38,000 staff. This NHS Greater Glasgow register for “all staff” is not available to the public.

NHS Ayrshire and Arran: have promised to reply to my recent communication on HDL (2003) 62 stating that “turnaround times are proving challenging”.  NHS Ayrshire and Arran stated in June 2013 “discussions are ongoing to create a register to encompass the whole organisation … we are in the process of updating our Model Publication Scheme to include this register which will be published on our public website.” I can today find no such register (other than for Board Members only) for NHS Ayrshire and Arran.

NHS Lanarkshire: I have had no reply to my recent communication on HDL (2003) 62. However previously (15th May 2014) Dr Iain Wallace, the Medical Director for NHS Lanarkshire, wrote to me stating: “I can advise that it is not the intention of NHS Lanarkshire to publish a register of interests for all staff”.

NHS Grampian: I have had no reply to my recent communication on HDL (2003) 62. However in relation to my original FOI request, I was informed in July 2013: “…no such register is maintained and therefore a copy is unable to be provided to you….In all of the circumstances therefore, NHS Grampian is unable to provide a register to meet your requirements.”

From the 6 other regional NHS Boards I have had no reply to my recent communication on HDL (2003) 62. I have not made further contact with the 7 special NHS Boards since my original FOI request. My understanding however is that HDL (2003) 62 applies equally to the special boards.

To remind the Committee, here is the relevant section of HDL(2003) 62:

HDL-62

On the 17th May 2014 the Herald reported: “The Health Secretary has asked officials to urgently investigate why some NHS boards have not put in place registers as covered by the 2003 circular. Alex Neil believes the guidance is clear that this action should have been taken, and we are looking for clarification on why some boards have not acted.”

SUMMARY:

  1. HDL (2003) 62 was issued 12th December 2003. It is more than a decade old. It asked Chief Executives to “establish a register of interest for all NHS employees and Primary Care Contractors.”
  1. The Scottish Government summary of the 17th April 2014 demonstrated widespread failure to comply with HDL(2003) 62. The updated evidence I have managed to gain indicates reasons to be more rather than less concerned.
  1. I have found no evidence, in any register of any sort, of declarations from “Primary Care Contractors”.

The Committee may recall that before I had submitted oral evidence for the petition the Association of the British Pharmaceutical Industry (ABPI) submitted a letter to the Committee. The ABPI plan to develop what they term a “Central Platform”: from the 1st July 2016 the intention is to collect and record data of individual payments to healthcare practitioners and record these on an open database. It is important to note that healthcare practitioners will be able to opt-out if they do not wish payments to be disclosed.

The General Medical Council (GMC), in reply to the Petition Committee confirmed that a “compulsory register would require legislative change.” This week the GMC sent this reminder to medical practitioners:

GMC Jan 2015 CoI

Despite reminders, NHS Boards are not following existing guidance. This strategy has failed for more than ten years. The disappointingly slow response of the Scottish Government to communication from the Committee only highlights the failure of the current approach. This strengthens my view that a new law would be a better way of focusing minds on a matter that may be having a significant impact on Scotland’s health. I would remind the Committee that I was first prompted to look into this when considering the widespread, off-label over-prescription of antipsychotic medications for Scotland’s elderly people. My experience was that the Pharmaceutical Industry financially supported the “education” of healthcare practitioners in this approach.

I hope this update is of some assistance to the Committee ahead of the 27th January 2015.  I wish to say that I am very grateful to the Committee members, and supporting staff, for all your help.

Yours sincerely,
Dr Peter J. Gordon

Full correspondence on NHS Registers of Interest can be followed here

CropperCapture[1]

The above post is by Chrys Muirhead. It can be accessed here. I have also re-posted it below:

Sunshine Act for Scotland Petition Goes Before Parliament a 3rd Time

January 23, 2015

In Scotland petitions are a direct way for people to raise national issues with their Parliament, a request for action.  Dr Peter J Gordon, consultant psychiatrist, first lodged a petition on the Scottish Parliament website, PE01493: A Sunshine Act for Scotland, 29 September 2013:

“Calling on the Scottish Parliament to urge the Scottish Government to introduce a Sunshine Act for Scotland, creating a searchable record of all payments (including payments in kind) to NHS Scotland healthcare workers from Industry and Commerce.”

Peter J Gordon is a man of many parts: a qualified doctor and landscape architect, husband and father, a family man whose interests include philosophy, sociology, ethics, evidence-based medicine, neuroscience, horticulture, sculpture, poetry, local history,  photography and film-making.  He writes on Hole Ousia (whole being) and has 269 films, at the latest count, on Omphalos.

spshotsunshineactpetOn 12 November 2013 the Public Petitions Committee at parliament took evidence from Dr Gordon in respect of his Sunshine Act for Scotland petition.  (See video, 25 minutes in)  Here is part of my comment on the video, now disabled but on my Google+ profile:

“The points about the marketing potential of education versus scientific objectivity demonstrate the need for regulation of drug industry payments, or in kind rewards, made to or received by health care professionals.  To hear the figure of £40million gifted by drug companies to UK health workers and about £4million of that going to Scottish workers is quite astonishing.”

— Herald Scotland article 13 November 2013: ‘Doctor calls for drug payments register‘.

In addition to petitioning Scottish Parliament, Dr Gordon has been diligently raising Freedom of Information requests in respect of Registers of Interests in every Scottish health board area.  Scottish Government brought out a directive, NHS Circular HDL (2003) 62, instructing health boards to set up Registers of Interest so that staff could declare payments from pharmaceutical companies.  For the sake of transparency.  The health boards have not been complying with this government call to action.

Herald Scotland article 17 May 2014: ‘Urgent review as nearly half of health boards ignore pharma disclosure rule‘ and quote “The Health Secretary has asked officials to urgently investigate why some NHS boards have not put in place registers as covered by the 2003 circular. Alex Neil believes the guidance is clear that this action should have been taken, and we are looking for clarification on why some boards have not acted.”

HeraldEditorial18may14On 18 May 2014 the Herald Scotland Editor gave his support for the Sunshine Act petition and greater transparency, saying “Simply hoping that NHS Boards enforce existing guidance is a strategy that has failed for more than ten years.  A new law would be a better way of focusing minds on this important matter.”

Nearly a year to the day after Dr Gordon gave his evidence, on 11 November 2014, his Sunshine Act petition was considered by the Public Petitions Committee at its meeting in the Robert Burns Room of Scottish Parliament.  I was there to hear the proceedings, punctuated by a Remembrance Day commemoration in the Garden Lobby of parliament at 11am, and then at around 12 noon the topic came up.  It took two minutes mention of contacting Scottish Government to ask about the NHS Circular HDL (2003) 62 (Registers of Interest) progress.  My thoughts?  Swingball.  Pass the buck.  See blog post I wrote following the meeting.

On Monday this week a notification arrived to say that Dr Peter Gordon’s petition will be considered, again, by the Public Petitions Committee on 27 January 2015 in the Robert Burns Room of Scottish Parliament.  Meeting starts at 10am and the agenda item containing the Sunshine Act should start at around 11.15am, subject to change.  I have booked a ticket and plan to observe the proceedings from the Public Gallery.  Live broadcasts can be viewed at this link.  Videos after the event here plus links to business papers and reports.

I am hoping this time around in the Rabbie Burns room for more than 2 minutes worth of talk and no direct action.  A Sunshine Act for Scotland makes sense economically and ethically.  Doctors in their drug prescribing should be free from conflicts of interests.  The pharmaceutical industry is primarily a money making concern.  Patients deserve to know that their medical treatment is for them and not for profit.

“While Europe’s eye is fix’d on mighty things,
The fate of Empires and the fall of Kings;
While quacks of State must each produce his plan,
And even children lisp the Rights of Man;
Amid this mighty fuss just let me mention,
The Rights of Woman merit some attention.”

— Robert Burns, The Rights of Woman, 1792

 

 

 

Transparency in drug company payments to doctors

In a BMJ “briefing” Rebecca Coombes sums up the new UK system for public disclosure of payments from drug companies to doctors

Published the 2nd January 2015 in The BMJ, here follows the full article:

Transparency-in-drug-compan

I have met Andrew Powrie-Smith of the ABPI several times. He has made it a personal mission to improve transparency for the Pharmaceutical Industry and I applaud his efforts. My concern is that the medical profession may not yet quite agree with Powrie-Smith that transparency is a “societal expectation”. I say this as (1) the voluntary register Who pays this doctor? has not exactly been burdened with declarations, and (2) my research into Registers of interest for all staff employed in NHS Scotland has evidenced very poor compliance with Scottish Government Guidance (HDL 62).

The new database, set up by the ABPI, is a most positive development. We should however be aware that it only applies to the pharmaceutical industry and not other areas of commerce: such as device makers, nutritional supplements, digital technologies etc. It is my understanding that the ABPI Register also only applies to doctors. Do we not also need to consider academics, managers, commissioners, pharmacists, nurses, AHPs, charities all of whom could be paid to “educate” us about a specific condition and a product or test for this. Or to commission a service for it.

Surely however, the main issue with this new ABPI code is that it has no legal underpinning. Doctors can opt out of declaring any financial payments and they so they will not be named.

This is why I have petitioned the Scottish Government for a Sunshine Act (or clause). America has this legislation as do several other countries.

Opt-out

 

NHS Lothian – Register for all staff

As petitioner for the Sunshine Act I undertook Freedom of Information Requests to all 22 NHS Boards in Scotland to establish if Boards had  Registers of Interest for ALL staff. The findings revealed that most Boards did not.

HDL-62

The above guidance, HDL 62, was issued by the Scottish Government in 2003:

“Chief Executives are asked to establish a register of interest for all NHS employees and Primary Care contractors”. 

NHS Lothian has  NO Register of Interests for all staff. This was confirmed in this Freedom of Information reply dated 6th May 2013:

May2013

The former Cabinet Minister for Health & Wellbeing, Alex Neil, referring to HDL 62 “made it clear” the responsibilities enshrined in it to all Health Boards since it was issued in 2003 (this in the letter below, dated 31st October 2013):

Alex-Neil-on-Reg-of-Interes

This week Professor David Taylor is giving an “educational” talk to NHS Lothian. The Continuing Professional Development (“CPD”) talk he gave earlier this year to NHS Forth Valley was on the basis of a paid honorarium. It was sponsored by the Pharmaceutical Company Janssen. As NHS Lothian have NO Register of Interests this financially sponsored education will have no formal record. It is important to note that Professor David Taylor may be talking about his “prescribing guidelines”.

The British Medical Journal have recently covered this issue (19th July 2014):

BMJ-cover-19-July-2014---me

The Editor of the Sunday Herald shares the concerns of the British Medical Journal:

Herald-Editorial18-May-2014

It's-time-patients-knew-Mgt

NHS Lanarkshire – Register of Interest for all staff

As petitioner for the Sunshine Act I undertook Freedom of Information Requests to all 22 NHS Boards in Scotland to establish if Boards had  Registers of Interest for ALL staff. The findings revealed that most Boards did not.

HDL-62

The above guidance, HDL 62, was issued by the Scottish Government in 2003:

“Chief Executives are asked to establish a register of interest for all NHS employees and Primary Care contractors”. 

The former Cabinet Minister for Health & Wellbeing, Alex Neil, confirmed this in a letter dated 31st October 2013:

Alex-Neil-on-Reg-of-Interes

The British Medical Journal have recently covered this issue (19th July 2014):

BMJ-cover-19-July-2014---me

The Editor of the Sunday Herald shares the concerns of the British Medical Journal:

Herald-Editorial18-May-2014

The Medical Director for NHS Lanarkshire, Dr Iain Wallace, stated in writing on the 15th May 2014:

 “I can advise that it is not the intention of NHS Lanarkshire to publish a register of interests for all staff”

It's-time-patients-knew-Mgt

Continuing Medical Education and its entanglement with the Pharmaceutical Industry

Yesterday I sent the e-mail (at the foot of this post) to Alex Neil, Cabinet Secretary for Health and Well-being for the Scottish Government. It should be self explanatory.

My timing of this letter is based on 8 separate areas. Areas that I hope present as close to a whole picture as I am best able to do:

(1) Freedom of Information (FOI) returns have now been received from all 22 Scottish NHS Boards on the subject of how they record payments to healthcare workers from the Pharmaceutical Industry and if these are open and transparent to all. The results are worse than disappointing.

The summary database is here: https://docs.google.com/spreadsheet/ccc?key=0ApF86-MCSbZzdGlVd2ZPYWhyN1ZUbkliNlFpTGxtMFE#gid=0

Full communication and register files (if available) are here: https://www.whatdotheyknow.com/user/peter_j_gordon/requests

(2) The USA, since five days ago, has a SUNSHINE ACT: look here and see what such statute-based transparency is beginning to reveal (that had previously been kept in the dark) http://projects.propublica.org/docdollars/

In case you think that this could not affect Scotland, well as just one example, Henry A. Nasrallah came to NHS Forth Valley and gave sponsored education on Risperdal in July 2009. He is in the top ten educators earning from the Pharmaceutical Industry with at least $647,341 changing hands.

(3) Scotland (and the UK) do NOT have a Sunshine Act. What we have is the Guidance on Joint-Working between NHS-Scotland and the Pharmaceutical Industry: A Common Understanding 2012 – Working Together For Patients. As guidance it was brought into effect in November 2012 and the Guidance was developed under the Chairmanship of Ian Mullen who was involved in this at the same time as he was Chairman of NHS Forth Valley. Despite this and the fullsome promises in the foreword by Ian Mullen, NHS Forth Valley has never had a functioning register of any joint-working other than the listed Interests of Board members. The FOI returns across all 22 NHS Scottish Boards have since evidenced that NHS Forth Valley, in this failing, was closer to the norm rather than the exception.

A common Understanding

(4) There is also the UK-wide ABPI Code (The Association of the British Pharmaceutical Industry): latest version is here: “The Code of Practice for the Pharmaceutical Industry Second 2012 Edition”  http://www.abpi.org.uk/our-work/library/guidelines/Pages/code-2012.aspx

The ABPI code was reported in the BMJ on its launch in an article by Clare Dyer entitled “Collaboration with drug industry won’t affect clinical decisions, says new guideline”

ABPI promoted

This report of the new ABPI code stirred a vigorous response in BMJ rapid-responses: http://www.bmj.com/content/344/bmj.e2489?tab=responses

One of these responses was subsequently published 24 April 2012 as a letter entitled: “Guidance offers little in the way of ethics or transparency” It was written by Rogers, Zutlevics, Raven & Jureidini:

ABPI Guidance - one response

The above article as per original publication may not be very clear so I have re-pasted the body of the text here (highlights are mine)

deeply-disappointing

In February 2013 the Lancet withdrew its support of document on collaboration between doctors and drug industry http://www.bmj.com/content/346/bmj.f770 I will reprint some of the text here:

Falling-out-with-Pharma

(5)  I have been collecting over the last 3 months all details of Pharmaceutical Sponsored Education that comes my way. I do not see Pharmaceutical Reps and so this will most likely be urepresentative sample of the wider picture. Have a look and form your own opinion:http://pinterest.com/peterjgordon/pharmaceutical-sponsored-medical-education/

Pharmaceutical Sponsored Education

(6) Last year £40 million was paid in total to healthcare workers in the UK from the Pharmaceutical Industry. Whatever proportion went to Scotland, it certainly is not represented in what few returns have been made by doctors to their NHS Boards. So much for transparency. And what then of the ‘probity’ section all doctors sign as part of mandatory GMC regulations for Appraisal and Revalidation?

£40 million

(7) An area of legitimate concern must relate to academics and doctors that have been termed as “Key Opinion leaders” and whose joint-working with the Pharmaceutical Industry can be considerable . I must confess that I had not been especially aware of this until the recent UK-wide discussion on dementia diagnosis was raised in leading journals. I have always advocated for the timely, personalised and holistic diagnosis of dementia pointing out that considerable harms may be associated with the prevailing imperative of ‘early diagnosis’. I was a lead in this debate before just about any other. I was thus concerned when the Key Opinion Leaders in dementia in their reply to the Open letter that I had joined with Grassroots Doctors on this subject http://grassrootsgp.org/category/dementia-screening/  made no declarations of interest. Not one. I knew this was incorrect.

Grassroots GP

Dr Martin Brunet in The Binscome Doctor Blog, as one of the Grassroot doctors made the same observation: http://binscombe.net/blog/?p=639

“Our letter was initially published as a rapid response, where it triggered a reply from an eminent group of doctors who declared that they had no competing interests. The letter was subsequently published as an Observation article, and a further reply came from many of the same authors, several of whom decided on this occasion to declare interests, including financial support from pharmaceutical companies and appointments related to the field of dementia. These conflicts are not wrong in themselves, and do not invalidate their comments, but neither are they unimportant, nor did they arise in the intervening three-month period between the letters. What changed? A prick of the conscience? A word from the editor? Or perhaps the fact that the BMJ tightened its wording about conflicts of interests in January 2013 – between the two submissions.

CropperCapture[2]

Even a robust policy on this matter is insufficient, however. The BMJ has very clear guidance on what should be declared, but there is very little the editors can do when proper declarations are not made – with retraction of the article being their most draconian punishment. Retraction may have repercussions in the scientific community, but it is rarely reported on in mainstream media.”

Since this time I have collected the declarations made by all the Key Opinion Leaders, at least those of whom I am most aware that educate us on dementia, whether it be in  practice, prescribing or policy. My absolute determination is to look at this as a group and thus I would wish no doctor to be singled out. This is not about reputations, or simply conflicts of interest, it is about transparency and that goal that we surely all share: the quest for scientific objectivity.

Why I no longer consult for drug companies https://vimeo.com/72517101/settings

This film carries some of the words by Dr Peter J. Whitehouse in a paper that he wrote called “Why I no longer consult for drug companies” published in Culture, Medicine and Psychiatry, March 2008, Volume 32, Issue 1, pp 4-10

http://link.springer.com/article/10.1007%2Fs11013-007-9075-x#page-1

I wish to thank Dr Whitehouse for allowing me to use his words in this film.

I have made this film as I share Dr Whitehouse’s concern about the entanglement of pharmaceutical marketing/health industries with continuing medical education. I also share concern that when it comes to the Key opinion leaders in dementia that the talk of “transparency” is only talk. Last year £40 million was paid by Pharma to healthcare workers in the UK. Research into Scottish NHS Hospitality Registers evidences that payments from Pharmaceutical Industry are consistently not being declared in Registers (if indeed there is a functioning NHS register!) We are in the dark about this. Unlike USA we have no ‘Sunshine Act.’ The UK has a meaningless, one-sided, code called the ABPI code.

Why I no longer

89% of British Medical journal readers (999 out of 1128), in a poll of April 2013, agreed that drug companies should publish the names of doctors to whom they make donations. That is a striking consensus.

Donations poll

The Pinterest Board on Key Opinion Leaders in Dementia is here: http://pinterest.com/peterjgordon/opinion-leaders-in-dementia/ I was going to write about this but, for so many reasons, I find this very difficult. I am particularly concerned that I am simply a doctor, not an investigator (and do not wish to be). I hope that all readers of this realise that my only determination is to be fair to all, to follow evidence, ethics, professionalism and the humanity that I hope I have within me.

Key Opinion Leaders 'educating' us

(8) Before finishing this post with a copy of the e-mail that I sent to Alex Neil, Cabinet Secretary for Health and Well-being for the Scottish Government. I would like to post a couple of ‘slides’ that I have made from the current BMJ and the article “Everything you need to know about the Sunshine Act” (intended  for the USA readership) http://www.bmj.com/content/347/bmj.f4704

Sunshine-03

Sunshine-06

And finally some advice from Dr Ben Goldacre aimed at his fellow professionals. This is also in the form of a film that I have made called: “What Can You Do” (thank you to Dr Goldacre for agreeing to allow me to use the text from his book Bad Pharma) https://vimeo.com/68919466

Dr-Ben-Goldacre's-advice

Bad pharma 5

From: Gordon Peter (NHS FORTH VALLEY)
Sent: 07 August 2013 20:15
To: alex.neil.msp@scottish.parliament.uk
Subject:ADULT ADHD ACADEMY – sponsored education

7th August 2013.

Dear Cabinet Secretary for Health and Well-being,
Scotland’s 22 NHS Boards have now all replied to Freedom Of Information (FOI) enquiries regarding financial payments from Pharmaceutical Industry to NHS staff.

The results are most dismal. Have a look yourself

Summary database here: https://docs.google.com/spreadsheet/ccc?key=0ApF86-MCSbZzdGlVd2ZPYWhyN1ZUbkliNlFpTGxtMFE#gid=0 (any errors in summary will be mine)

Full communication here: https://www.whatdotheyknow.com/user/peter_j_gordon/requests

Could Scotland not lead here? Why can we not have full transparency on this in Scotland? A Sunshine Act. Like they now have in USA?

Like many others I am primarily concerned about science and objectivity (please see the views of Robert Merton in the slide below which are certainly not out of date)

Last year £40 million across the UK went to doctors (healthcare workers) . . . not much of this is showing up in returns given to Scottish NHS Boards (that is if the NHS Board has a Register.)

If Conflicts of Interest are not a worry to all, this lack of transparency on the part of doctors, most certainly is. Currently Consultants like myself have to Revalidate and as part of this and annual Appraisal we sign a section on ‘probity’.

Please do reply to this concern. I am grateful.

Yours sincerely,
Dr Peter J. Gordon

Consultant Psychiatrist for Older Adults,
 Clackmannan Community Healthcare Centre,
 Hallpark road,
 Sauchie.
 FK10 3JQ

Changing-system-of-producin

The text on this slide on SCIENTIFIC OBJECTIVITY and what MERTON CORRECTLY FEARED may happen, is from the book “Genes, Cells and Brains” by Hilary & Steven Rose