Good publication practice for communicating company sponsored medical research: the GPP2 guidelines

BMJ 2009; 339 doi: http://dx.doi.org/10.1136/bmj.b4330 (Published 30 November 2009)
Cite this as: BMJ 2009;339:b4330

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I am disappointed in the reply, "Debating good publication practice" (January 12, 2010) from Chris Graf, lead author of the GPP2 guidelines, and the GPP2 coauthors.

Their reply goes to great lengths to emphasize that all authors should be noted as authors. The reply states, "'Who did the work?' should be answered by an honest list of all authors and acknowledged contributors. All qualifying authors and contributors should be listed, including contributing individuals employed or contracted by the sponsor."

Thus, this reply restates that one of the characteristics of integrity, according to the GPP2 article's checklist for articles and presentations, is "honest attribution of authorship."

But the GPP2 authors do not address the criticisms from Roy M. Poses, MD, and from me, which are based in part on the following from the GPP2 article: "Professional medical writers, depending on the contributions they make, may qualify for authorship. For example, if a medical writer contributed extensive literature searches and summarised the literature discovered, and by doing so helped define the scope of a review article, AND IF HE OR SHE IS WILLING [emphasis added] to 'take public responsibility for relevant portions of the content' [ICMJE; www.icmje.org] then he or she may be in a position to meet the remaining ICMJE criteria for authorship."

Furthermore, I pointed out that Mr. Graf stated in an ISMPP teleconference about the GPP2, "if they [medical writers] can be [authors] MAYBE THEY SHOULD BE [emphasis added]." Again, the reply from Mr. Graf and the GPP2 coauthors does not reply to Mr. Graf's stated contradiction with the rest of the GPP2 guidelines.

So according to the GPP2 guidelines and Mr. Graf, should medical writers who qualify for authorship be included as authors? I encourage Mr. Graf and the GPP2 coauthors to reply to the internal inconsistency of the GPP2 guidelines and to Mr. Graf's answer this question.

It seems to me that GPP2 guidelines and Mr. Graf in his separate statement would have it either way. Consequently and regrettably, the GPP2 guidelines fail as good publication practice guidelines. The explanation of the development of the GPP2 guidelines demonstrates a well-thought procedure.

Competing interests: I am a medical writer-editor who provides services to individuals and organizations.

Michael S. Altus, PhD, ELS, Medical writer-editor

Intensive Care Communications, Inc.?

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Regardless of the specifics of Dr. Wilmshurst’s situation and the number of publication-related guidances that exist, there are regrettably still a number of parties or individuals that are not aware of or have not adopted all of the elements of best publication practices today. However, in response to Dr. Wilmshurst’s final question, we believe these situations should neither undermine the need for guidelines to exist nor serve to suggest that we think that the existence of guidelines alone creates a state of utopia. Rather, we stand by the purpose of the GPP2 publication, an updated set of guidelines for publishing pharmaceutical research, in serving as another key step in the ongoing effort that needs to be made in raising publication standards.

As highlighted in a table in the GPP2 guidelines (1), 16 different organizations have issued new codes or updated existing documentation since 2003. Progress has been made, and that progress should not be overlooked. In the United States, Senator Grassley’s office recently issued a report calling for full transparency in medical publications. We endorsed this call to our members but did point out that the report was missing some of the more recent references to current best practice documentation. At the same time, we recognize that we must continue our efforts in education and advocacy to encourage all parties, not only the pharmaceutical industry but all parties involved in the publishing process, including authors, whether industry authors or academicians, and publishers, in adopting and consistently adhering to best publication practices to protect the integrity of medical research and the interests of the public and patients.

1. Graf C, Battisti WP, Bridges D, Bruce-Winkler V, Conaty JM, Ellison JM et al. Good publication practice for communicating company sponsored medical research: the GPP2 guidelines. BMJ 2009;339:b4330.

Competing interests: I am employed by ISMPP, the non-profit organization affiliated with the GPP2 guidelines

Competing interests: None declared

Kimberly J Goldin, Executive Director

ISMPP, PO Box 2523, Briarcliff Manor, NY 10510 USA

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These guidelines differ little from the existing standards, which are honoured more in the breach than in observance by researchers, sponsors and journals.

I was the principal cardiologist and co-principal investigator in the Migraine Intervention with STARFlex© Technology (MIST) Trial.[1] NMT Medical sponsored the trial. The resulting paper was published in Circulation, the premier journal of the American Heart Association (AHA). Circulation requires authors to sign a declaration that largely accords with the proposed guidelines. Authors are required to sign that they have approved the final version of the paper; that they have had sufficient access to the data to verify the manuscript’s scientific integrity; that they have made a significant contribution to conception and design of the research, data acquisition and analysis, drafting the manuscript, etc; that those who contributed to the research are appropriately acknowledged and that nobody whose contribution should be acknowledged is omitted; and that they assign copyright to the AHA. The copyright transfer specifically states that the authors should be the sole authors of the work and publication does not infringe the copyright, proprietary or personal rights of a third party.

I sent an email to the other members of the steering committee saying that I could not in conscience sign the declaration because:
1. Individuals involved in this research and instrumental in its conception, design, execution, analysis and writing have been omitted in favour of individuals who had less involvement.
2. The paper contained errors.
3. I could not in conscience agree to be an author of an article which stated that “THE AUTHORS HAD FULL ACCESS TO THE DATA AND TAKE RESPONSIBILITY FOR ITS INTEGRITY” because we did not have full access.

Another member of the steering committee, Dr Simon Nightingale, also refused to sign the declaration.

Circulation did not question why two authors named in an earlier version had disappeared from the final version and published the paper in March 2008. I immediately wrote to the editor expressing my concerns. I provided Circulation with hundreds of pages of documents to support a case for publishing a correction. Eventually a 700 word correction, a four page data supplement and a new version of the paper were published in September 2009. I know that the new version of the paper still has errors. I accept that discussion of these errors may be controversial and that the BMJ may be concerned about a libel action, so let us consider some unquestionable facts.
1. One of the authors, Dr Rickards, died in May 2004.[2] He was not on the trial design group and the protocol was not finished when he died. The first author of the paper, Dr Dowson, was recruited to be my co-principal investigator in August 2004. Ethics approval was obtained in November 2004 and patient recruitment started soon afterwards. Dr Rickards obviously did not sign the author declaration. It is difficult to see how he qualifies as an author. The correction still bears his name, although Circulation knew at the time that he had died well before the trial commenced. His death in May 2004 did not prevent his name appearing as an author of a response to a letter about the trial early in 2009.[3] Why did Circulation knowingly allow an individual to be an author when he did not satisfy the journals authorship requirements?
2. The published paper and the amended version each mention the roles played by the trial design group and the steering committee, but the members of those committees are not named. The members of the trial safety committee are named, though they had a less demanding role than the other two committees. I was on the trial design group, but not one of the authors was a member. Dr Nightingale and I were 2 of the 5 clinical members of the steering committee. Two other members were from the sponsoring company, and they are both acknowledged in the paper. Failure to acknowledge our roles might prevent questions about why Dr Nightingale and I were not authors. Dr Nightingale and I worked at the centre that did the most patient visits in the trial - over 600 out of 2000 - more than 30% of all patient visits. Dr Nightingale and I wrote an early draft of the paper and contributed to subsequent drafts. Some “authors”, who had no role in conception, design, management, data analysis or writing did as few as 8 patient visits to qualify as an author. Not surprisingly, some authors had no idea about the controversy within the steering committee over inaccuracies in the paper, which were subsequently confirmed by publication of the correction. When Circulation has a stated policy on acknowledgement of contributions, why has the journal failed to ensure adequate acknowledgement of the roles of Dr Nightingale and me in the corrected version?
3. Circulation has failed to respond to my communications since the correction was published. Is that an appropriate way for an ethical journal to behave?
4. I have provided Circulation with incontrovertible evidence that I also wrote part of the protocol for another trial sponsored by NMT Medical, the BEST Trial. My contribution to that trial has not been acknowledged.[4]

What value is there in guidelines when they are ignored, unless their sole purpose is to mislead the public into believing that publication of research has integrity?

References

1. Dowson A, Mullen MJ, Peatfield R, Muir K, Khan AA, Wells C, Lipscombe SL, Rees T, De Giovanni JV, Morrison WL, Hildick-Smith D, Elrington G, Hillis WS, Malik IS, Rickards A. Migraine Intervention with STARFlex Technology (MIST) Trial: a prospective, multicenter, double-blind, sham- controlled trial to evaluate the effectiveness of patent foramen ovale closure with STARFlex septal repair implant to resolve refractory migraine headache. Circulation 2008;117:1397-1404.

2. Anthony Francis Rickards – Obituary. BMJ 2004;329:234.

3. Dowson A, Mullen MJ, Khan AA, Rickards A, Peatfield R, Muir K, Wells C, Lipscombe SL, Hildick-Smith D, Rees T, De Giovanni JV, Morrison WL, Elrington G, Hillis WS, Malik IS. Response to letter regarding article, “Migraine Intervention with STARFlex Technology (MIST) Trial. Circulation 2009;119:e194.

4. Mullen MJ, Hildick-Smith D, De Giovanni JV, Duke C, Hillis WS Morrison WL, Jux C. BioSTAR Evaluation Study (BEST). A prospective, multicentre, phase 1 clinical trial to evaluate the feasibility, efficacy, and safety of the BioSTAR bioabsorbable septal repair implant for the closure of atrial-level shunts. Circulation 2006;114:1962-7.

Competing interests: I was co-principal investigator in the MIST Trial. I refused to be an author of the resulting publication in Circulation, because it was inaccurate and because important information had been omitted. Circulation subsequently published a 700 word correction, a four page data supplement and a new version of the paper. I maintain that the correction is incorrect. I am currently being sued for libel by NMT Medical Inc, the sponsor of the trial, for speaking about my concerns about the trial. I am defending the action.

Competing interests: None declared

Peter T Wilmshurst, Consultant Cardiologist

Royal Shrewbury Hospital, SY3 8XQ

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GPP2’s recommendations [1], when considered in their entirety and in conjunction with GPP2’s checklists, will help authors, contributors and sponsors to collaborate responsibly and appropriately.

GPP2 agrees with Poses [2], Jacobs and Baldwin [3] that guest and ghost authors are unacceptable. GPP2 requires “Honest attribution of authorship” [1]. ‘Who did the work?’ should be answered by an honest list of all authors and acknowledged contributors. All qualifying authors and contributors should be listed, including contributing individuals employed or contracted by the sponsor. Contributorship statements to describe exactly who did what should be used.

We disagree with Poses that the GPP2 guidelines “obfuscate who is responsible and accountable for a clinical trial.”

GPP2 states “Authors … are responsible for how medical research is interpreted and communicated” [1]. GPP2 reflects ICMJE guidance that “Each author should have participated sufficiently in the work to take public responsibility for appropriate portions of the content” [4]. GPP2 recommends that investigators as well as “members of the study steering committee and the protocol development team” [1] (i.e. the principal investigators or individuals who designed the study) should comprise the publication steering committee. GPP2 states “members of the publication steering committee may become authors, but membership of the committee does not automatically confer authorship” [1] because authorship should depend on actual contributions made to the publication.

GPP2’s recommendation for a named “guarantor” reflects ICMJE guidance [4]. One of the principal investigators would likely be guarantor and probably lead author on at least the primary publication(s) from a study.

In the US, Europe and elsewhere sponsors are now legally required or obliged to post clinical trial results on a publicly-accessible internet registry regardless of outcome [5,6]. Particularly for these trials GPP2 recommends “Making public or publishing results regardless of outcome” [1]. Sponsors should endeavour to publish, to avoid publication bias from unpublished negative results.

References

1. Graf C, Battisti WP, Bridges D et al. Good publication practice for communicating company sponsored medical research: the GPP2 guidelines. BMJ 2009;339:b4330

2. http://www.bmj.com/cgi/eletters/339/nov27_1/ b4330#226987

3. http://www.bmj.com/cgi/eletters/339/nov27_1/ b4330#227612

4. International Committee of Medical Journal Editors. Uniform requirements for manuscripts submitted to biomedical journals. www.icmje.org.

5. Food and Drug Administration Amendments Act of 2007.
www.fda.gov/RegulatoryInformation/Legislation/Federal FoodDrugandCosmeticActFDCAct/SignificantAmendmentsto theFDCAct/FoodandDrugAdministrationAmendmentsActof2007 /default.htm

6. International Federation of Pharmaceutical Manufacturers and Associations, European Federation of Pharmaceutical Industries and Associations, Japan Pharmaceutical Manufacturers Association, Pharmaceutical Research and Manufacturers of America. Joint position on the disclosure of clinical trial information via clinical trial registries and databases. Updated November 10, 2009.
http://clinicaltrials.ifpma.org/fileadmin/files/pdfs/EN/ November_10_2009_Updated_Joint_Position_on_the_Disclosure _of_Clinical_Trial_Information_via_Clinical_Trial_ Registries_and_Databases.pdf

Competing interests: The authors' competing interests are disclosed in full in GPP2 (BMJ 2009;339:b4330).

Competing interests: None declared

Chris Graf, Lead author, GPP2 guidelines

Wendy P Battisti, Dan Bridges, Victoria Bruce-Winkler, Joanne M Conaty, John M Ellison, Elizabeth A Field, James A Gurr, Mary-Ellen Marx, Mina Patel, Carol Sanes-Miller, Yvonne E Yarker, Jane Moore, John Draper, members of ISMPP GPP2 Steering Committee

John Wiley & Sons, Wiley-Blackwell, Oxford OX4 2DQ

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We are pleased that the publication of GPP2 [1] has given further prominence to the importance of ethics in biomedical publications. We are particularly pleased that the guidelines recognise the role of professional medical writers and make clear the important distinction between professional medical writers, who have a legitimate and ethical role to play in publications, and ghostwriters, who do not. We believe that the guidelines contain much good advice that should help to promote high ethical standards.

However, there are two points in the new guidelines that give us cause for concern, and we would be grateful if the authors of GPP2 could clarify their intentions in those areas.

First, the original GPP guidelines [2] contained the recommendation “Companies should endeavour to publish the results from all of their clinical trials of marketed products.” This recommendation appears to be absent from GPP2. We believe strongly that both positive and negative results should be published to avoid the serious problem of publication bias. Do the GPP2 authors agree that it is still important to publish the results of all trials?

Second, the precise role of the publication steering committee as described in GPP2 seems unclear. The guidelines appear to allow for the possibility that employees of the sponsor company could be members of the publication steering committee without being authors of the publication. That sounds dangerously close to ghost authorship. Do the GPP2 authors agree that it is important to ensure that sponsor employees should either be named authors of a paper or, if they are not named authors, should have no influence on the content of the publication?

References

1. Graf C et al. Good publication practice for communicating company sponsored medical research: the GPP2 guidelines. BMJ 2009;339:b4330

2. Wager E, Field EA, Grossman L. Good publication practice for pharmaceutical companies. Curr Med Res Opin 2003;19:149-54

Competing interests: AJ and HB are both officers of EMWA, which represents professional medical writers throughout Europe. Their roles as press officer and president are both unpaid positions. For their day jobs, AJ is the director of Dianthus Medical Limited, and HB is the director of Scinopsis. Both Dianthus Medical Limited and Scinopsis provide professional medical writing services to pharmaceutical companies.

Competing interests: None declared

Adam Jacobs, Press Officer

Helen Baldwin, President, EMWA

EMWA, Petersfield, GU31 5AZ

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10 December 2009

We applaud Graf and co-authors for developing the GPP2 guidelines and The British Medical Journal for publishing them. By addressing the interests of all stakeholders and defining the roles and responsibilities of each, the guidelines provide clear instructions for exorcising the ghosts that have been haunting professional medical communication. For example, the GPP2 guidelines distinguish between ghostwriting, which is unethical, and professional medical communication. As stated by the Association of American Medical Colleges and as noted in GPP2, “Transparent writing collaboration with attribution between academic and industry investigators, medical writers, and/or technical experts is not ghostwriting” (1). This distinction is particularly relevant for authors in academic and health care settings where guidance on legitimate and ethical writing collaboration had previously been lacking. We urge all contributors to medical journal articles and presentations at scientific congresses to familiarize themselves with and adhere to the GPP2 guidelines.

1. Association of American Medical Colleges. Industry funding of medical education. Report of an AAMC task force. June 2008. Available at: http://services.aamc.org/publications/showfile.cfm? file=version114.pdf&prd_id=232

Competing interests: Thomas Gegeny is employed as a scientific team lead with Envision Scientific Solutions, a medical publications agency that works with pharmaceutical companies. Melanie Fridl Ross is Director/Sr Medical Writer-Editor at the University of Florida Health Science Center News & Communications. Mary Royer and Cindy Hamilton are freelance medical writers. Judith Pepin is an employee of The Procter & Gamble Co.

Competing interests: None declared

Thomas Gegeny, President

Melanie Fridl Ross, President-Elect; Cindy Hamilton, Immediate Past President; Mary Royer, Secretary; Judith Pepin, Treasurer American Medical Writers Association (www.amwa.org)

American Medical Writers Association

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These guidelines seem to obfuscate who is responsible and accountable for a particular clinical trial, and for articles written reporting on such a trial.

The guidelines ignore the time-honored concept of a "principal investigator" who is responsible for the entirety of a research project. Instead they allow for each manuscript arising from a clinical trial to have both a lead author and a "guarantor." The latter is envisioned as having "overall responsibility for the integrity of a study and its report." Then who appoints the guarantor? Who is responsible for the integrity prior to his or her appointment? When a trial generates more than one manuscript, would they necessarily have the same guarantor? If not, who would ultimately be responsible, and how would disagreements be resolved?

The guidelines prevent understanding of who ought to be the authors of a manuscript, what their responsibilities should be, and how accountable they are for the manuscript. The distinctions among "contributors," "authors," "investigators," "sponsor employees," and "individuals contracted by the sponsor" are unclear.

In particular, the guidelines seem to condone ghost authorship. They would not prevent a professional medical writer from writing an initial outline, the first draft, and all subsequent drafts. including the final draft of a paper. Yet that writer would not necessarily be an author, since only if if he or she is willing to "take public responsibility for relevant portions of the content" then he or she may be in a position to meet the remaining ICMJE criteria for authorship. Of course, this would allow a professional writer to simply be unwilling to take such responsibility in order to avoid being listed as an author.

In my opinion, these guidelines do little to increase confidence in the integrity of commercially sponsored clinical research.

Note: the above was derived from a longer commentary on the blog Health Care Renewal (http://hcrenewal.blogspot.com) which is available here:

http://hcrenewal.blogspot.com/2009/11/how-industry- views-research-it -sponsors.html

Competing interests: None declared

Competing interests: None declared

Roy M Poses, President, Foundation for Integrity and Responsibility in Medicine

16 Cutler St, Suite 104, Warren, RI, 02885, USA

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The GPP2 states that if a medical writer is willing to “take public responsibility for relevant portions of the content” [ICMJE] then he or she may be in a position to meet the remaining ICMJE criteria for authorship.”

In a Nov. 30, 2009, blog post, “How Industry Views the Research It Sponsors” at Health Care Renewal (http://hcrenewal.blogspot.com), Roy M. Poses, MD, states, “Presumably, a professional writer could dodge authorship by simply being ‘unwilling’ to take such public responsibility. So the guidelines apparently condone nearly all functions commonly assumed to be those of an author to be performed by a professional writer paid directly by the sponsor, without the writer being listed as an author. The guidelines thus appear to condone ghost-[authoring] in its most pernicious form.”

In an ISMPP teleconference about the GPP2, I posted a question seeking a reaction to Dr. Poses’ comments from presenter Chris Graf, first author of the GPP2. The teleconference did not get to my question.

However, when Mr. Graf discussed the role of professional medical writers, he said, “if they [medical writers] can be [authors] maybe they should be.”

Sadly, “The guidelines thus appear to condone ghost-[authoring] in its most pernicious form.”

Competing interests: I am a medical writer-editor who provides services to individuals and organizations.

Competing interests: None declared

Michael S. Altus, PhD, ELS, Medcal writer-editor

Intensive Care Communications, Inc.®, Baltimore MD 21215 USA

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3 December 2009

I welcome the publication of GPP2 and congratulate the team on their work and, in particular, for achieving far wider consultation than we attempted for the original version.

When we started work on the first version of GPP (in 1999) many companies were unwilling to make a commitment to publish the results of all trials of their marketed products and many companies (and industry associations) were opposed to trial registration. Progress has been made towards ensuring comprehensive registration and results disclosure but concerns about transparency and responsible reporting remain.

In my contacts with pharmaceutical companies I often hear complaints that trust has been lost in company-sponsored publications. I suggest that one small step towards restoring that trust would be for companies to endorse GPP2 publicly. The next step would be to make sure they are following the guidelines.

Competing interests: I was an author of the original GPP guidelines

Competing interests: None declared

Elizabeth (Liz) Wager, Publications Consultant

Princes Risborough HP27 9DE, UK

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Congratulations to members of the GPP2 Steering Committee for having the expertise and endurance required to put GPP2 on the map. Will GPP2 alone prompt industry critics to say ‘you have arrived at your destination’ (ie, the ethical production of publications and presentations of industry-sponsored medical research)? No, nor should it. Even with a GPS system, the ignorant and the arrogant still get lost. We need to educate the ignorant about GPP2 and stop the arrogant from taking unethical routes to prepare presentations and publications. We can all do our part to support GPP2, but I really look forward to hearing from journal editors and congress organisers as to if and how they will actively support GPP2. I guess I’m asking for directions…

A/Professor Karen Woolley, PhD

Competing interests: My company provides medical writing training courses and services to academic, biotechnology, and pharmaceutical clients.

Competing interests: None declared

Karen L. Woolley, CEO

ProScribe Medical Communications, Queensland, Australia 4566

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