OPINION
NATURE MEDICINE VOLUME 19 | NUMBER 3 | MARCH 2013 261
The pharmaceutical industry was once among the most admired
industries on the planet. Today, it is heavily criticized and distrusted,
with only 12% of people in the US believing that drug companies are
generally honest and ethical, according to a Harris poll published
late last year. Countless experts have raised this problem before, and
drug companies have attempted numerous remedial strategies to
address bioethical concerns and repair trust deficits. Nonetheless,
the mistrust persists, arguably weakening the effectiveness of these
important institutions. Is there something new that companies can do
to demonstrate the quality of their processes and genuinely earn back
our trust? I believe there is.
The drug industry should voluntarily implement a bioethics
accreditation, certification or rating system to help companies assess
and improve the quality of their services and organizational processes.
Such a system would also increase transparency, accountability and
awareness of best practices, as well as appropriately improve public
confidence where merited.
Accreditation systems originated close to 100 years ago to aid
surgeons in maintaining safe working conditions in hospitals. Today,
these and other rating systems often improve and help to demonstrate
the quality of schools, foods, toothpastes and home goods (think
Good Housekeeping Seal) and can serve as indicators of a product’s
general environmental impact. In a similar vein, through the nonprofit
Bioethics International and in tandem with the Edmond J. Safra Center
for Ethics at Harvard University (with funding from the Susan G.
Komen Foundation and the Raskob Foundation), I am working to pilot
such a system for the pharmaceutical industry to address prominent
bioethical concerns.
To take the complex ethical process of drug discovery, development,
marketing and delivery and translate these things into to a pass-fail or
gold-star rating system, one can follow a common process for creating
such evaluation programs. This involves cataloging stakeholders’ main
bioethical concerns about companies, compiling standards that can
address those primary concerns and developing methodologies to
evaluate how a company aligns its practices with those standards.
The bioethical concerns drug companies need to tackle to receive
high regard in today’s marketplace fall within four categories: the
design and management of clinical trials, the fate of trial results upon
study completion, corporate marketing strategies and the accessibility
of medicines. Accreditation and rating standards that addresses these
four categories of concern can evaluate each company’s processes
and outcomes either according to what is already expected of it or
according to higher expectations that the industry and rating agency
sets internally. For example, to address concerns that companies
suppress and manipulate unfavorable trial results or publish them in
a misleading fashion, baseline standards would ask that companies
follow Benjamin Franklin’s maxim, “to study, to finish [and] to
publish.” In other words, companies should, at the very least, register
trials and disclose trial results in a timely fashion, as required by federal
regulations in the US. Standards can also be culled from the codes of
conduct of the industry’s own trade association, the Pharmaceutical
Research and Manufacturers of America, from other prominent
guidelines and from corporate best practices. GlaxoSmithKline, for
example, committed last month to the higher standard of publishing
all clinical study reports for approved or discontinued drug candidates.
Herein lays a great impasse between critics and the industry. On the
one hand, many companies report that they are consistently meeting or
exceeding current standards and that violations are outliers or issues of
the past. On the other, critics follow the contradictory evidence, such
as a 2009 study
1
showing that less than half of surveyed trials were
adequately registered and a 2012 study
2
showing that only one in five
trials subject to mandatory reporting had met the obligations to post
results on sites such as ClinicalTrials.gov. Accreditations, certifications
and rating systems can go a long way in addressing this impasse by
discouraging deficiencies and recognizing genuine quality processes
and performance.
A suitable program for the pharmaceutical industry, described
in broad strokes, would probably involve two steps. First, drug
companies would complete self-assessment applications rating how
they perceive themselves to be meeting standards and providing
evidence of implementation. This includes listing all employees
responsible for implementing each standard, from the supervisory
and board levels through the operational and execution levels.
Second, companies would undergo on-site and internal reviews in
which employees and possibly external third parties are interviewed
and surveyed to ascertain whether the companies are indeed doing
what they say they are doing in the self-assessment applications. If the
companies satisfactorily pass both evaluations, they are then awarded
an accreditation and the use of a ‘seal’ for a period of time, renewable
upon review every three years.
The seal may signal to stakeholders that a drug company has
reasonably and transparently addressed prominent bioethical concerns
and met certain quality standards. This ‘proof point’ can be a powerful
communication tool for companies as well as a powerful choice or
information tool for stakeholders. At a time when the industry is facing
increased risks of regulation and sanctions along with a steady decline
in public trust, the need for such a reliable metric has never been higher.
I am now actively seeking (and in dialogue with) industry members
interested in joining efforts to refine, promote and pilot this innovative
program. For the good of the industry and the good of public health, I
hope pharma executives will see the benefit of actively implementing
a robust bioethics rating system.
Jennifer E. Miller is president of Bioethics International and a
residential fellow in the Edmond J. Safra Center for Ethics at
Harvard University in Cambridge, Massachusetts, USA.
e-mail: jmiller@ethics.harvard.edu
1. Mathieu, S., Boutron, I., Moher, D., Altman, D.G. & Ravaud, P. JAMA 302, 977–984
(2009).
2. Prayle, A.P., Hurley, M.N. & Smyth, A.R. BMJ 344, d7373 (2012).
Bioethical accreditation or rating needed to restore
trust in pharma
Jennifer E Miller
After years of decline in the public eye, drug companies should implment a bioethics accreditation or rating
program to help appropriately restore the industry’s good name and improve its effectiveness in advancing
global health and new treatments.
Jennifer Miller
npg
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