Independent · non-commercial · publishes on a quarterly cycle|Current cycle 2026 Q3
Compound Evidence InstituteEvidence synthesis · established 2023Graded assessments of compounds, trials, methods and supply
Document set current to 30 July 2026
Public comment period · §2

Draft citation policy — submissions

The 9 submissions received, published in full with declared interests and secretariat responses.

Document identifier
CEI-CP-012/2
Series
Public comment period
Version
1.0
Published
05 Oct 2024
Last reviewed
05 Oct 2024
Next review
05 Oct 2025
Identifier
10.71829/cei.cp.12
Certainty
Not rated
Cycle
2024 Q3
Window
24 Jul 2024 – 18 Sep 2024
Status
Closed
Submissions
9

§2Submissions and responses

9 submissions were received. Each is published in full below with its declared interest, the secretariat response and the disposition. The Institute publishes submissions it did not accept in the same form as those it did.

Dr Oswin Yorkstone, PhD (Pharmacology) Hospital microbiology and endotoxin testing service
DRAFT-CITATION-POL/008 received 26 Jul 2024

The position of a contributor who withdraws consent is not stated

The respondent states that consent to be named is obtained at submission and that the policy is silent on what happens if it is later withdrawn, which leaves both the Institute and the contributor without a rule.

The respondent proposes that the position be stated in advance and be the same for everyone.

Declared interest. Employed by a health technology assessment body that has issued guidance on a compound named in the draft.
Secretariat responseAccepted12 Oct 2024

The secretariat accepts this submission. A rule made at the point of the first withdrawal is a rule made about a particular person.

The policy now states that a contributor may withdraw from the register at any time and that the register entry is removed, while a signed submission already published remains published, because the consultation record is a record of what was said and by whom. The position is stated at the point consent is given.

Dr Quentin Whitmarsh-Obi, MD, FRCS Academic peptide-chemistry group
DRAFT-CITATION-POL/001 received 03 Aug 2024

Point estimates are given without an interval

Several estimates in the draft appear as single figures. The respondent states that a point estimate without an interval invites a precision the underlying data do not support, and that the effect is worst where the estimate is drawn from a small contributing set.

The respondent proposes that no point estimate appear anywhere in the document set without its interval, including in summary tables and in the abstract.

Declared interest. No financial or non-financial interest to declare in relation to the subject of this consultation.
Secretariat responseAccepted in part12 Oct 2024

The secretariat accepts this submission in part. Intervals are added wherever the source reports one. The proposal is declined for figures the source published without an interval, because the Institute will not compute an interval a source did not report.

Every estimate now carries its interval where the source reported one, and where it did not, the estimate is annotated as reported without an interval rather than left to appear as a precise figure.

Dr Ludmila Castellanos-Reid, MD, FRCP Independent evidence-synthesis consultancy
DRAFT-CITATION-POL/006 received 12 Aug 2024

The document set should be published in translation

The respondent notes that the assessments concern compounds supplied internationally and that publishing only in English restricts access to the assessment to readers who work in it.

The respondent proposes machine translation of the document set as an interim measure, with human review of the certainty language.

Declared interest. No financial interest. Has published a systematic review reaching a different conclusion from the draft, which the respondent declares as a non-financial interest.
Secretariat responseNot accepted10 Oct 2024

The secretariat does not accept this submission, and records that the underlying point is sound and that the proposed remedy is the difficulty.

A translation whose certainty language has drifted is a different assessment carrying the Institute's name, and the Institute cannot review translations it does not have the capacity to review. The documents remain in English. The submission is published in full because the access problem it identifies is real and unresolved.

Dr Valentin Castellanos-Reid, MD, FRCP Independent evidence-synthesis consultancy
DRAFT-CITATION-POL/009 received 14 Aug 2024

Anonymous submissions should be accepted where the respondent risks employment consequences

The respondent states that people in a position to identify a defect in a manufacturer's documentation are frequently employed by that manufacturer, and that requiring a signature excludes exactly those submissions.

The respondent proposes an anonymous route with verification held by the secretariat and not published.

Declared interest. Has received consultancy fees from a supplier named in the Institute's supplier assessment set within the preceding two years.
Secretariat responseNot accepted04 Oct 2024

The secretariat does not accept this submission, and records that the exclusion it identifies is real.

The Institute publishes no anonymous submission, because a submission whose author is not published cannot be weighed against a declared interest and the declaration is the mechanism the whole surface rests on. Material bearing on a factual defect may instead be submitted to the evidence log, where it is assessed on the document and the submitter is named only with consent. The submission remains published in full.

Dr Kamila Ubertini, PharmD, BCPS Regulatory affairs, generic medicines sector
DRAFT-CITATION-POL/007 received 16 Aug 2024

Whether external reviewers are paid is not stated

The respondent states that payment or its absence bears on who is able to review and on what the Institute may expect of them, and that the policy does not address it.

The respondent proposes that the position be stated and that any payment be disclosed at the level of the individual document.

Declared interest. No interest to declare. The respondent is a graduate student and states that the submission forms no part of any assessed work.
Secretariat responseAccepted14 Oct 2024

The secretariat accepts this submission. Payment is an interest and the policy treats interests as facts to be published.

The policy now states whether external review is remunerated, records any payment made in respect of a document in that document's front matter, and treats a payment received from the Institute as a declarable interest in the same way as any other.

Dr Vasilisa Immelmann, PhD (Biostatistics) University department of medicinal chemistry
DRAFT-CITATION-POL/005 received 24 Aug 2024

The policy does not say what happens to a document the Institute is asked to remove

The respondent states that assessments of named parties will attract removal requests, and that a policy silent on them will be applied inconsistently under pressure.

The respondent proposes that the grounds on which a document may be withdrawn be stated in advance and be exhaustive.

Declared interest. Employed by a national competent authority. This submission is made in a personal capacity and does not represent the position of that authority.
Secretariat responseAccepted19 Oct 2024

The secretariat accepts this submission. A policy written after the first request will be written under the conditions least suited to writing it.

The grounds for withdrawal are now stated exhaustively, being a factual error that cannot be corrected in place and a legal obligation, a withdrawn document is replaced by a notice recording the fact and the ground rather than removed, and every withdrawal is recorded in the corrections log.

Dr Hortensia Larsson-Ekwueme, MSc (Regulatory Affairs) Public-sector clinical trials unit
DRAFT-CITATION-POL/004 received 29 Aug 2024

The materiality threshold for a declarable holding is set too high

The respondent states that the threshold in the draft excludes holdings a reader would regard as relevant, and that the cost of declaring a small holding is negligible against the cost of a reader discovering an undeclared one.

The respondent proposes that all holdings be declared regardless of size.

Declared interest. Employed by a university department that has received unrestricted research funding from a manufacturer of a compound in the class under assessment. The respondent had no role in that funding.
Secretariat responseAccepted in part04 Oct 2024

The secretariat accepts this submission in part. The threshold is lowered. Declaration of every holding without threshold is not adopted, because an undifferentiated list obscures the holdings that matter.

The materiality threshold is lowered and is now expressed as a proportion of the declarer's holdings as well as an absolute figure, so that a holding material to the person is declarable whether or not it is large in absolute terms.

Dr Delphine Trelawney, MSc (Regulatory Affairs) Public-sector clinical trials unit
DRAFT-CITATION-POL/002 received 09 Sep 2024

The search date is not on the face of the document

The draft carries a publication date and a review date but not the date on which the evidence was last searched. Those are three different dates and only the third tells a reader how current the assessment is. A document published in one quarter may rest on a search run two quarters earlier, and nothing on the page allows that gap to be measured.

The respondent proposes that the search date be printed adjacent to every certainty rating rather than in the methods section, on the ground that a reader who acts on a rating is unlikely to have read the methods section first.

Declared interest. Has received travel support to attend a scientific meeting from a manufacturer of a compound named in the draft.
Secretariat responseAccepted24 Sep 2024

The secretariat accepts this submission. The distinction between publication, review and search dates is real and the draft did not make it visible where it mattered.

The search date is now printed adjacent to every certainty rating and is carried in the document metadata, so that the interval between the search and the reading is visible without reference to the methods section.

Dr Ottoline Oppenheimer-Ade, MD, MPH Primary-care research network
DRAFT-CITATION-POL/003 received 18 Sep 2024

Funding should not be accepted from any party the Institute assesses

The respondent states that disclosure does not neutralise an incentive, and that accepting funding from an assessed party creates one whether or not it is acted on.

The respondent proposes an outright prohibition on funding from any assessed supplier or manufacturer.

Declared interest. Has received honoraria for educational lectures from a marketing-authorisation holder of a compound named in the draft, within the preceding three years.
Secretariat responseAccepted in part13 Oct 2024

The secretariat accepts this submission in part. Funding from an assessed party is not accepted for assessment work. A general prohibition covering all activity is not adopted, because it would extend to unrestricted contributions the Institute can accept without any assessment consequence.

The policy now prohibits funding from an assessed party for any activity bearing on that party's assessment, requires that any other relationship be published on the funding page and on every page it could bear on, and records the sums involved rather than the fact of a relationship alone.

References cited on this page

References are numbered in order of first citation in this document. Each superscript in the text links to its entry below.

  1. International Organization for Standardization. ISO/IEC 17025:2017 General Requirements for the Competence of Testing and Calibration Laboratories. ISO/IEC Standard 2017;3rd edition. identifier not held by the Institute

Identifiers are reproduced only where the Institute holds them. Where a digital object identifier or PubMed identifier is not shown, the Institute has recorded the journal and year and has not constructed an identifier.

Nothing published by the Institute is medical advice, a diagnosis, a prescription, a treatment recommendation or a purchasing recommendation. Compounds supplied for research use are not approved for human or veterinary use in any jurisdiction, and a favourable analytical assessment of a supplier is not a statement that any product is safe or effective. The Institute publishes certainty ratings and never recommendations. No telephone number, messaging handle or ordering channel appears anywhere on this site.