Patricia M. Surdyk, Ph.D.
Senior Project Manager
Accreditation Council for Graduate Medical Education
515 N. State Street
Chicago, IL 60610
Dear Dr. Surdyk:
Cop out. There is no other way to describe the ACGME draft Principles to Guide the Relationship between Graduate Medical Education and Industry. The draft Principles are an at-times eloquent description of the massive conflicts that attend the growing relationship between industry and medical education programs. But when it comes time for the draft Principles to actually delineate what is and is not acceptable, the raison d’etre for these Principles, the draft document simply evades the issue.
The essence of the cop out appears on page 5, line 154:
Programs and sponsoring institutions must determine through policy, which contacts, if any, between residents and industry representatives may be suitable, and exclude occasions in which involvement by industry representatives or promotion of industry products is inappropriate.
Actually, the primary purpose of this document should have been to determine what those policies should include. Instead, the document offers the weakest possible recommendation: that someone else should come up with the policies. Of course, this implicitly allows these policies to vary from location to location and does not even establish a floor for acceptable policies.
Elsewhere the document is equally vague. On page 6, line 170, the ACGME suggests that residents learn “how promotional activities can influence judgment in prescribing decisions and research activities.” What is really needed is to school residents in how to resist the largesse and sometimes misleading representations of industry. On line 185, the Guideline states that “These policies must clarify the differences between education and promotion.” A more useful Principle would actually outline on what basis such a distinction might actually be made, particularly because many items provided by pharmaceutical companies are primarily promotional, rather than educational (Stryer D, Bero LA. Characteristics of materials distributed by drug companies. An evaluation of appropriateness. J Gen Intern Med. 1996;11:575-83.). Similarly, the admonition that “Resident curricula should include discussion and reflection on managing encounters with industry representatives” is very weak and lacking in any specificity.
The draft document concludes by stating that “inappropriate activities must not be allowed to continue where they exist.” Yet the document has provided no guidance whatsoever on what these inappropriate activities might be. Given the strong case that the draft Principles have made for the corrupting influence of industry, we believe that it is most in the interests of patients for residents to simply be precluded from interacting with industry. This means no industry-sponsored free lunches, no samples, no dinners, no movies, no concert tickets, no presence in the clinics or wards, no detailing, etc. Anything less will make the ACGME’s purported concern about the “irreconcilable difference” between the responsibilities of industry (to stockholders) and physicians (to patients) seem hollow.
Peter Lurie, M.D., M.P.H.
Sidney M. Wolfe, M.D.
Public Citizen’s Health Research Group