Disclosure Policies & Resources

NASS is dedicated to offering high quality programming that is of the highest standards of academic rigor, intellectual veracity and professionalism. In order to achieve this goal, NASS believes that it is important that those who participate in NASS’ activities are transparent about relationships they may have with ineligible companies (formerly commercial interests) or professional organizations.

NASS recognizes that relationships with ineligible companies are essential for development of new spinal technologies and medical advancement. We also understand that even the appearance that any member, volunteer or leader is in a position where financial considerations could potentially influence his or her professional behavior, is damaging and undermines public confidence in our profession. Accordingly, the goal of this policy is to create a uniform system that encourage disclosures of situations in which there is even the potential for bias, without any implications regarding actual bias.

It is further recognized that disclosure in and of itself is not an adequate remedy for conflicts, and may even in some cases serve to increase the potential harm (see AAMC, "The Science of Reciprocity"); even gifts as small as fountain pens and prescription pads have been proven to create a feeling of obligation in the recipient. Thus, this Policy also addresses how individuals within NASS’ work groups (e.g. Board of Directors, Committees, Councils, Sections, and Task Forces) need to manage conflicts of interest beyond disclosure. All NASS members are also expected to adhere to our Code of Ethics and Expert Witness Guidelines and certain leaders within NASS may also be expected to adhere to NASS’ Divestiture Policy.

In general, NASS’ disclosure policy applies to NASS Participants. In some situations, limited disclosure requirements also apply to audience members at NASS-related CME events. See Section III. NASS members or meeting attendees who are not further involved in any NASS-related activities beyond mere membership or attendance are encouraged, but not required, to make the disclosures called for in this policy.

A. Disclosure of the Existence of Certain Relationships: All Participants in any NASS-related activities must disclose any of the following relationships that (with the exception noted below in subsection (c)) existed at any point in time twenty-four (24) months prior to the date of disclosure:

a. Financial Relationships
b. Non-financial Relationships
c. Additionally, all Participants in any NASS-related activities must disclose any Relevant Financial Relationships, regardless of when the relationship existed.

Disclosure of Certain Details About Disclosed Relationships: Participants must disclose basic information about each relationship, such as: name of entity, the general nature of the relationship (e.g., employee, researcher, consultant, advisor, speaker, independent contractor, royalties or patent beneficiary, executive role, and ownership interest).

In order for others to assess the relationship and its potential for bias, Participants will also be asked to disclose the approximate value (in range format) for each relationship. Relationships still in the negotiation phase must still be disclosed and may be valued on the basis of estimated potential future value.

Additional details, of which may vary from time to time, may be required at the discretion of NASS’ Board of Directors.

Exceptions:

• For relationships involving stock/security, we recognize that those may – at times – be difficult to value in approximate dollar amounts. For this reason, those relationships may, be alternatively valued by noting the number of stocks owned or the percentage of ownership in the company the stocks represent.
• For relationships paid by salary, the existence of the salary should be disclosed, but not the amount.

B. Process for Making Disclosures

All disclosures must be made through NASS’ online module: spine.org/disclosure

In general, Participants must make disclosures on an annual basis, no later than April 1. In some cases, however, a Participant’s activity within NASS will require a disclosure on a more frequent basis. In such cases, NASS staff will contact you to let you know of your event-specific disclosure responsibilities. Disclosures must also be updated in the event of any material changes.

Each Participant’s disclosure will be published in conjunction with the NASS-activity to which he/she is participating. Additionally, all information submitted through NASS’ online disclosure module will be available for members’ on: The Annual NASS Disclosure Index.

Any audience member at a NASS-related CME event who volunteers a question and/or comment should, before proceeding with his/her question and/or comment, make an oral disclosure. Due to time constrains this disclosure may be limited to any Relevant Financial Relationships, or direct relationships to the topic of the activity.

You should be aware that your disclosure may be reviewed by NASS for compliance with this policy.

Individuals subject to, but in violation of, this policy may be sanctioned by NASS through its Professional Conduct and Ethics Committee and/or Education Council. Sanctions include, but are not limited to, suspension of membership, public letters of censure, and prohibitions from presenting at future meetings.

Use of NASS’ online disclosure module is the first, but not only, step in maintaining NASS’ high ethical standards. In addition to the disclosures required above on an annual basis, all members within the NASS Board of Directors, Councils, Committees, Sections or Task Forces or other decision-making bodies (collectively “work group”) must make further full disclosures of any potential conflict of interest relating to an issue before that work group.

Individuals with a conflict that relates to the work of the individual’s work group should recuse themselves from any deliberations and vote, unless the individual has special information of a technical nature that will help the work group better understand the issue. If this is the case, the individual can supply the information, but then must recuse himself/herself from the deliberations and decision.

As many of NASS’ work group meetings take place via telephone, recusal means either leaving the room or disconnecting from the telephone or video conference for the period of time during which the issue is discussed. Recused individuals cannot vote, nor witness the vote or be privy to the manner in which the votes were attributed. Any recusals, along with follow up responses per this policy, shall be documented for the work group by NASS staff.

Financial Relationships: Any proposed or actual financial remuneration from either: (a) ineligible companies, or (b) a professional medical association. Such financial relationships can include: employment, researcher, consultant, advisor, speaker, independent contractor, royalties or patent beneficiary, executive role, and ownership interest.

Ineligible Companies: Ineligible companies are those whose primary business is in producing, marketing, selling, re-selling or distributing health care products used by or on patients. Some examples include: device manufacturers, pharmaceutical companies or distributors, health-related wearable products, bio-medical startups, or any advertising companies related to any of these entities already listed. NASS also includes, within the definition of “ineligible companies”, insurance companies (in an employment capacity only) or any entities that are in the development stage for any of the aforementioned activities and devoting substantially all of its efforts to these tasks, regardless of if operations have not yet officially begun or have begun but without significant revenue.

Relevant Financial Relationships: Financial relationships of any dollar amount are considered Relevant Financial Relationships if the educational or scientific content is related to the business lines or products of the ineligible company.

Non-financial Relationships: Any proposed or actual influential office or role held with either: (a) ineligible companies (b) a professional medical association, even when no financial renumeration is exchanged. Such non-financial relationships can include: board of directors, scientific advisory board, officer, committee chair, or any other position that has influence within the organization.

Participant(s): An individual involved in any NASS-related activity, such as: those who serve in committee and leadership positions within the society, authors, including but not limited to abstracts, The Spine Journal (TSJ), SpineLine, Contemporary Concepts and Clinical Guidelines, speakers, faculty, moderators, panelists or reviewers for any NASS-related events.

Stock/Security: An interest based on an investment in a common enterprise, including: a note, stock, treasury stock, bond, debenture, evidence of indebtedness, certificate of interest or participation in a profit sharing agreement. It also includes private investments such as venture capital or investments in start-up companies which have undetermined future value potential. It does not include investments in diversified mutual funds.