When my melanoma specialist learned what I do for a living during a recent checkup (five years NED—no evidence of disease—and counting, thank you very much!), he immediately asked if there was anything to be done about the endless requests for disclosures of potential conflicts of interest he was asked to submit. Being the clinical director of the Massachusetts General Melanoma & Pigmented Lesion Center and the director of the Melanoma Genetics Program, he’s a sought-after faculty member, but the piles of paperwork involved is, well, ridiculous.

Hopefully, by the time you read this, the Alliance for Continuing Education in the Health Professions will have its national disclosure system—that I first wrote about a year or so ago—up and running. The system is designed to standardize conflict-of-interest disclosure data elements, and provide a uniform online collection tool and a searchable national data repository. If the central disclosures repository takes off, it could make life easier for both CME providers who have to hound docs for the disclosures, and for people like Dr. Tsao who have to comply with all those requests.

But, even assuming it gets near-universal buy-in, will it be enough? Just when I thought we were starting to get a handle on the disclosure dilemma, I listened to J. David Haddox, DDS, MD, vice president, Health Policy, Purdue Pharma LP, who opened the 23rd Annual Conference of the National Task Force on CME Provider/Industry Collaboration, held in October in Baltimore, with this line:

"I am human. Therefore I am biased."

And, much as I hate to open that can of worms, he’s right. There are so many things outside of financial relationships that could potentially cause bias, though that currently is the bar set by the Accreditation Council for CME. For example, Haddox pointed out, what about a surgeon who touts a device that has his name on it? Or his friend’s name? Or the name of someone she doesn’t care for? What about those who espouse preferences for what they’ve been using for years over what the evidence shows is best? What about those who are in it for the ego boost of getting their 15 minutes of fame? What about those who are looking to get an uptick in their referrals by setting themselves up as experts? His own résumé could be construed as hinting at his potential for bias, he said, listing everything from his current position to his being the past president of a pain-management association. "Conflicts are so pervasive—they can't be avoided," he said.

And should they be? He talked about a medical society that asked him to speak about extended-release/long-acting opioid Risk Evaluation and Mitigation Strategy at its meeting, but later rescinded the offer because it couldn’t allow a person employed at a pharmaceutical company to speak at its meeting, even though the ACCME says it’s OK in the case of REMS..  But who better to talk about it, Haddox asked? “Opioid REMS focus on brand names and specific products, and there’s intricate stuff in there that could cause errors of omission or commission. Who knows the product safety profiles best? I know my products better than the FDA does.”

As he pointed out, it’s easy to judge financial relationships, but even the best disclosure system isn’t going to reveal all the nonfinancial potential conflicts of interest we have just because we’re human. While I find it hard to imagine there’s a disclosure system that could make all possible conflicts transparent, I do think it’s an important factor to consider when bringing on faculty. What’s really in it for them, and how could that potentially sway what they say? Is it enough to follow ACCME rules and say that’s all that we reasonably can do? Are the bias-detection systems we all have hard-wired into our brains sharp enough to alert us to these nonfinancial, often subtle COIs? We may not have the answers, but it’s important that we at least ask the questions.