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The ICJME also requires registration of clinical trials as a condition for publishing in member journals. Most IRBs further confirm registration of trials. Additionally, the contracts between research sites and sponsors (federal or private) often specifically require that the study will be registered. Clinical Trials, “FDAAA 801 Requirements,” available at <http://clinicaltrials.gov/ct2/manage-recs/fdaaa#OtherFDAAA801Requirements> (last visited June 24, 2013).+(last+visited+June+24,+2013).>Google Scholar

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It is worth noting that the investor fee model was significantly less profitable than the current conflicted model of credit rating agencies.Google Scholar

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There are conflicting opinions about the merits of revolving door theories. For example, Toni Makkai and John Braithwaite, of Australian National University, conclude when speaking about revolving door theories, “that there is limited analytical merit in a conception of capture as an enduring unitary character trait that is structurally determined by a history of interest group affiliations.” Rather they show that capture “is instead a situational problem that requires situational solutions. Constraining the free movement of the revolving door by restricting regulatory appointments from or to the regulated industry is an example of a flawed policy grounded in an overdrawn structural determinism.” See Makkai, T. Braithwaite, J., “In and Out of the Revolving Door: Making Sense of Regulatory Capture,” Journal of Public Policy 12, no. 1 (1992): 61–78. Brody, Howard, a medical doctor and professor at the University of Texas Medical Branch, points to anecdotal evidence that this strategy was at play in Billy Tauzin's decision to resign from his position as a Louisiana congressman, a position he held from 1980 to 2005, to run PhRMA (a position he was named to in December of 2004). Brody reports that Tauzin had “been a key architect in the House of Representatives of the Medicare prescription drug benefit passed at the end of the 2003,” a law that purportedly had many secret features that favored the industry, “most notably the provision that prohibited Medicare from using its volume purchasing power to negotiate drug price discounts.” Brody argues that “to critics, this sweetheart deal looked like the classic political payola – congressman writes the sort of bill the industry wants; industry rewards congressman with well-paid sinecure from which he can proceed to lobby his former colleagues on behalf of the industry.” See Brody, H., Hooked: Ethics, the Medical Profession, and the Pharmaceutical Industry (Lanham: Rowman & Littlefield Publishers, 2007): at 238.Google Scholar

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On the other hand, Dieter Helm of New College in Oxford highlights three arguments for why one may not want to prohibit the revolving door phenomena within regulatory agencies: “first, only industry experts can do command-and-control regulation effectively and revolving doors facilitate this; second, ex-regulators might improve the behavior of regulates; and, third, salaries for regulators are (politically) capped, and hence the quality of regulators will fall if there is not the incentive of ex post rewards.” See Helm, D., “Regulatory Reform, Capture, and the Regulatory Burden,” Oxford Review of Economic Policy 22, no. 2 (2006): 169–185, at 183.CrossRefGoogle Scholar

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