In order for the AAO-HNS/F to operate most effectively to further its mission and purposes, it is important that AAO-HNS/F decisions and actions not be unduly influenced by any special interests of individual members. Therefore, it has always been and continues to be important to identify potential or actual conflicts of interest that might improperly affect AAO-HNS/F activities. The AAO-HNS/F has adopted a formal system for the disclosure, review, evaluation, resolution, and publication of actual and potential conflicts of interest.
In many cases, disclosure of the potentially conflicting interest will itself suffice to protect the integrity of AAO-HNS/F operations. In other words, once such an interest is fully disclosed to the other participants in any related AAO-HNS/F activity, those other participants will generally be able to evaluate and adjust for the possible influence of the disclosed interest. However, it is important to bear in mind that in certain situations, adequate protection of the interests of the AAO-HNS/F may require scrupulous avoidance of even the appearance of conflict of interest, abuse or impropriety. In those situations where mere disclosure does not appear adequate to deal with actual or potential conflicts, additional action may be necessary.
The Financial and Intellectual Relationship Disclosure Forms from Academy/Foundation volunteers will be forwarded to the appropriate chair/leader for review. If necessary, that person will forward to the Ethics Committee Chair those disclosure statements that appear to present actual or potential conflicts that could prevent the member from serving, along with any relevant observations or recommendations of the chair.
The Ethics Committee Chair, or a sub-group of the Ethics Committee, will review the disclosure statements submitted and forward those that require further review to the Executive Committee (EC).
The Ethics Committee will review and initiate any request for further information and promptly prepare a report to the EC regarding its findings. The EC will report to the Boards of Directors on any items found by the EC to be of special significance.
Chairs of councils, committees, ad hoc task forces, task forces, and work groups are required to make a statement in the summation reports of any relevant financial and intellectual relationships that have been expressed by a volunteer during a meeting or conference call. Volunteers are also required to verbally disclose and update any relevant relationships that may occur during a conference call or meeting that do not already appear on the disclosure form. They must also update their form when any change has occurred.
As noted above, some situations involving actual or potential conflicts of interest may call for action beyond disclosure. In some cases, there may be a need for the Ethics Committee or the EC to further discuss a potential conflict of interest and determine whether the issue rises to the level where the volunteer may speak to the issue but not vote or may be asked to recuse him or herself from the discussion and voting. In extreme cases, a volunteer may be asked to step down from a council,
committee, task force, or working group. Significantly, the decision on how to address an actual or potential conflict of interest rests with the AAO-HNS/F Board of Directors and not the individual. The basic authority and procedures established by corporate law and the AAO-HNS/F bylaws will be available to deal with any substantial conflict of interest problems. As to the officers and directors themselves, they continue to be subject to basic legal constraints arising out of the fiduciary nature of their relationships with the AAO-HNS/F, and in appropriate circumstances, the Boards of Directors can deal with misconduct in office or seek court intervention.
Because proper disclosure by each individual, member volunteer or AAO-HNS/F leader is essential if the system is to function satisfactorily, it is important for everyone involved in the work of the AAO-HNS/F to approach with the proper perspective the question of what types of circumstances call for disclosure. The purpose of the procedure is not to discourage all involvement by Academy members in outside activities that might produce actual or potential conflicts with interests of the AAO-HNS/F. Neither is the objective to intrude into aspects of an individual’s professional or personal life that are, realistically, unlikely to have any significant bearing on AAO-HNS/F activities. Common sense should guide all decisions about what to disclose, and one reasonable test is whether a particular circumstance, interest or relationship, if made known to the full membership of the AAO-HNS/F or to the general public, would be likely to create the perception of impropriety, cause embarrassment for the AAO-HNS/F and/or the individual involved, or evoke suspicion about the motives behind any AAO-HNS/F action.
Standing Rule Regarding Disclosure of Interests by Participants in Debate at an AAO-HNS/F Membership Meeting. As suggested by the terms of the rule, its basic purpose is to inform the members of aspects of a speaker’s personal or professional circumstances that might affect significantly the speaker’s attitude or judgment regarding the particular matter under consideration.
In order for the members in attendance at an AAO-HNS/F membership meeting to evaluate properly statements and arguments presented during debate, it is important that the participants be informed of any aspect of a speaker’s personal or professional circumstances that might affect significantly the speaker’s attitude or judgment regarding the particular matter under consideration. Therefore, during any debate at a meeting, the presiding officer will ask each speaker participating in the discussion of a particular issue to introduce himself or herself by name and professional position and to identify any aspect of the speaker’s personal or professional circumstances that might reasonably be expected to affect significantly the speaker’s views on the subject under discussion. Any participant who refuses to provide such information will be denied the opportunity to address the membership during the debate on that particular issue. Written notice of this rule is to be included with membership meeting notices, and the rule is also to be announced at each meeting by the presiding officer.
Standing Rule Regarding Disclosure of Interests by Participants in Continuing Medical Education Activities. As a CME provider accredited by the Accreditation Council of Continuing Medical Education (ACCME), the AAO-HNS/F has established policies and procedures to identify and resolve conflicts of interest for all individuals in a position to control the content of an education activity. This includes, but is not limited to, planning committee members, coordinators, faculty, moderators, peer reviewers, and staff. This rule is intended to bring possible bias to the attention of the participants so that they can evaluate the program content accordingly. Written notice of this rule is to be shared with all coordinators of, and prospective faculty for any Foundation education activity whether it be live or enduring, and this rule is to be made known as part of the education activity.
Approved May 13, 2014