Draft funding and sponsorship policy — submissions
The 10 submissions received, published in full with declared interests and secretariat responses.
§2Submissions and responses
10 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.
A reader who acted on a document is not told when it is corrected
This submission addresses funding and sponsorship policy from the standpoint of an outside body that would have to rely on it.
Corrections are published in a log. Nobody who read the original page is notified, and the corrected page carries the correction in a form that a reader arriving fresh will read past.
The respondent proposes that a corrected document carry a visible notice at the point of the correction for a stated period, in addition to the log entry.
The secretariat accepts this submission. A correction filed where only the diligent will find it is a correction the reader who needs it will miss.
A corrected passage now carries an inline notice for twelve months from the date of correction, naming the log entry, in addition to the entry itself.
There is no route to challenge a disposition
Having read the draft of funding and sponsorship policy, the respondent puts one point to the secretariat.
The respondent states that a submission not accepted receives a reason and nothing further, and that a respondent who considers the reason mistaken has nowhere to go.
The respondent proposes a review of disposition by a person who did not make it.
The secretariat accepts this submission. A disposition that cannot be challenged is a decision without a check.
A disposition may now be referred for review to a member of the assessment committee who did not author the response, once per submission, with the referral and its outcome published alongside the original disposition whether or not it changes.
The terms on which the documents may be reused are not stated
The respondent submits on funding and sponsorship policy.
The respondent states that the site carries no statement of reuse terms and that an assessment which cannot be quoted with confidence will be paraphrased instead, which is worse for accuracy.
The respondent proposes an explicit reuse statement.
The secretariat accepts this submission. An unstated position on reuse is a position that will be guessed at.
The reuse terms are now stated explicitly on the legal page and in the document footer, permitting quotation and reproduction with attribution and the document version, and requiring that any reproduction carry the certainty rating that accompanied the quoted statement.
The Institute publishes no telephone number and no messaging channel
The respondent read funding and sponsorship policy in draft and has confined this submission to one clause.
The respondent states that a body inviting submissions ordinarily provides a channel for questions about the process, and that the written address alone is a high barrier for a first-time respondent.
The respondent asks that a route for procedural questions be provided.
The secretariat notes this submission. The written route is the only route and that is a deliberate constitutional position rather than an omission.
No amendment arises. The Institute holds no telephone number and uses no messaging channel, because a submission made in writing is a document that can be published with its response and an oral exchange is not. Guidance on making a submission has been expanded so that the written route requires no prior enquiry to use.
References should carry a persistent identifier for every cited source
The respondent’s comment on funding and sponsorship policy is made from the standpoint of a person who might be affected by a decision taken under it.
Several references in the draft carry a journal, a year and a volume but no persistent identifier. The respondent states that retrieval of such a reference is materially slower and that identifiers should be supplied throughout.
The respondent asks in the alternative that where an identifier exists but is not carried, the omission be explained rather than left as a gap the reader must interpret.
The secretariat accepts the second limb of this submission and declines the first. Identifiers are supplied wherever the Institute holds one. Where the Institute does not hold an identifier it will not supply one, because a reconstructed identifier that resolves to the wrong record is a worse defect than an absent one.
Every reference without a persistent identifier now carries an explicit statement that the identifier is not held by the Institute, so that its absence is a recorded fact rather than an apparent oversight.
No term limit applies to membership of the assessment committee
This is a submission on funding and sponsorship policy, from a respondent representing readers rather than practitioners.
Members are appointed and the document does not say for how long. A body whose membership does not turn over converges on a settled view and stops noticing that it has one.
The respondent proposes a fixed term, renewable once, with the appointment date published against each member.
The secretariat accepts this submission.
Members are appointed for a four-year term renewable once. Appointment and expiry dates are published in the register of members.
A four-week window is too short for a respondent without institutional support
The draft of funding and sponsorship policy was read for what it obliges the Institute to do rather than for what it says the Institute intends.
An organisation with staff can answer a consultation in four weeks. An individual reading in their own time, particularly one who needs the document explained before they can respond to it, generally cannot.
The respondent proposes a minimum of eight weeks for any consultation on a document of general application.
The secretariat accepts the principle and adopts a shorter minimum than proposed.
The minimum window is now six weeks for a document of general application and four for a document-specific draft. A respondent who asks for more time before a window closes is given it, and that is now stated in the policy.
Whether external reviewers are paid is not stated
The respondent notes that funding and sponsorship policy governs situations that will arise rarely and matter greatly when they do, and submits accordingly.
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.
The respondent notes submission 006 above and does not repeat the ground it covers.
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.
The same concept is given three different names in one document
The respondent submits on funding and sponsorship policy. Governance documents are read by very few people and relied on by everyone who reads anything else the Institute publishes.
The draft refers to the same quantity as a response rate, a responder proportion and a categorical outcome in different sections. The respondent, who works in health-technology assessment, states that a reader cannot tell whether the three refer to one thing or to three.
The respondent proposes that the glossary term be used at every occurrence and that the glossary entry be linked at first use in each section rather than only at first use in the document.
The secretariat accepts this submission. The variation was stylistic and its cost to the reader exceeds any benefit.
A single term is now used throughout for each defined concept, and the glossary entry is linked at first use within each section rather than once per document.
The policy does not say what happens to a document the Institute is asked to remove
The respondent has read funding and sponsorship policy in draft and makes one submission.
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.
The respondent’s submission overlaps with submission 003 and was prepared without sight of it.
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.
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.
- 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.