Conflicts of Interest Disclosure(s) related to Australian Evidence-Based Clinical Practice Guideline for Attention Deficit Hyperactivity Disorder

Waiting for an internal review by National Health and Medical Research Council of their handling of this request.

Dear National Health and Medical Research Council,

I request the Conflicts of Interest Disclosure(s) received by NHMRC in relation to

Australian Evidence-Based Clinical Practice Guideline for Attention Deficit Hyperactivity Disorder
Developer: Australasian ADHD Professionals Association
Date of Approval: 29/7/2022

as listed on https://www.nhmrc.gov.au/guidelinesforgu....

Time frame: 01/01/2018 to 30/7/2022

Yours faithfully,

Zack

NHMRC FOI, National Health and Medical Research Council

1 Attachment

OFFICIAL

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005

 

I refer to your request to the National Health and Medical Research
Council (NHMRC) under the [1]Freedom of Information Act 1982 (Cth) (FOI
Act) seeking:

 

…the Conflicts of Interest Disclosure(s) received by NHMRC in relation to

 

Australian Evidence-Based Clinical Practice Guideline for Attention
Deficit Hyperactivity Disorder

Developer: Australasian ADHD Professionals Association Date of Approval:
29/7/2022

 

as listed on
[2]https://aus01.safelinks.protection.outlo....

 

Time frame: 01/01/2018 to 30/7/2022

 

Below is some information about the processing of your request.

 

Timeframe for receiving your decision

The statutory timeframe for processing a request is 30 days, starting from
the day after the day on which your application was received. Therefore,
the due date for a decision on your request is 25 November 2025.

 

This timeframe may be extended where: 

·       charges are levied as prescribed by the [3]Freedom of Information
(Charges) Regulations 2019 (FOI Regulations) (see charges below)

o consultation with third parties is necessary (see consultation with
third parties below). 

 

Charges

Agencies may decide that an applicant is liable to pay a charge in respect
of a request for access to documents. These charges are set by the [4]FOI
Regulations and are for search and retrieval of documents, decision making
and provision of access (for example, copying and postage). 

 

If NHMRC decides to charge you in respect of this FOI request, we will
send you a preliminary assessment of the charges as soon as possible
following retrieval of any documents that may be relevant to your
request.  

 

Consultation with third parties

NHMRC may be required under the FOI Act to consult other parties (third
parties) where information relating to third parties arises in documents
sought by your request. The FOI Act prescribes a further 30 days
processing time for NHMRC to undertake this consultation. You will be
advised as soon as possible of any requirement to consult with a third
party.

 

Disclosure log

Please note that section 11C of the FOI Act requires agencies to disclose
documents released under the FOI Act in a disclosure log, which is made
publicly available. There are exceptions to this requirement, such as
where release of the documents or parts of them would involve the
unreasonable disclosure of your or another person’s personal or business
information. You may choose to express a view on this issue and to
identify personal or business information that in your view would be
unreasonable to publish. However, you should be aware that section 11C of
the FOI Act embodies a pro-disclosure policy which agencies are required
to follow, subject to any exceptions provided for under the FOI Act.

 

If you have any queries throughout the process, please contact the FOI
Unit at: [5][NHMRC request email]

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information
National Health & Medical Research Council
[6][NHMRC request email]

+61 (0) 2 6217 9000

[7]nhmrc.gov.au

 

                                             

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

OFFICIAL

show quoted sections

NHMRC FOI, National Health and Medical Research Council

1 Attachment

OFFICIAL

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005

 

I refer to your request to the National Health and Medical Research
Council (NHMRC) under the [1]Freedom of Information Act 1982 (Cth) (FOI
Act) seeking:

 

…the Conflicts of Interest Disclosure(s) received by NHMRC in relation to

 

Australian Evidence-Based Clinical Practice Guideline for Attention
Deficit Hyperactivity Disorder

Developer: Australasian ADHD Professionals Association Date of Approval:
29/7/2022

 

as listed on
[2]https://aus01.safelinks.protection.outlo....

 

Time frame: 01/01/2018 to 30/7/2022

 

Please see the below information about conducting third party consultation
for your FOI request. We are also seeking your agreement to extend the FOI
processing period.

 

Third party consultation

Through the processing of your request, NHMRC has identified a document
where the consultation provisions of the FOI Act (sections 27 and 27A)
apply – that is, where the document contains information concerning the
business, commercial or financial affairs of an organisation, or a
person’s business or professional affairs or personal information. NHMRC
is required to consult with the person or organisation concerned before
deciding on the release of the document.

 

Sections 27 and 27A of the FOI Act apply when it appears to the decision
maker, that the person or organisation concerned might wish to contend
that the document is exempt because its release would, or could reasonably
be expected to, unreasonably adversely affect their business or financial
affairs (section 27), or their personal privacy (section 27A).

 

More information about exemptions under the FOI Act is available on the
OAIC’s website: [3]www.oaic.gov.au/freedom-of-information

 

While any comments received from an individual or organisation that is
consulted will be taken into account, the final decision about whether to
grant you access to the documents you have requested rests with the
decision maker authorised under subsection 23(1) of the FOI Act.

 

In accordance with subsection 15(6) of the FOI Act, the period for
processing your request has been extended by an extra 30 days to allow
NHMRC time to conduct third party consultation. This places the due date
at 29 December 2025.

 

 

Extension request

In addition, NHMRC is seeking your agreement to extend the processing
period of your FOI request by a further 30 days (under section 15AA of the
FOI Act).

 

Please note that although the NHMRC office will be closed from 25 December
2025–1 January 2026 (inclusive), this time is still included in the FOI
processing period. A further extension of 30 days would allow NHMRC more
time to conduct third party consultation and process your request during
the December/January period.

 

If you agree to the additional extension, the due date for your request
would be 27 January 2026 (as the first business day following the
additional 30-day period).

 

Grateful if you could please email [4][NHMRC request email] by close of
business Friday 28 November 2025 to advise whether you agree to the
additional 30-day extension.

 

 

If you have any queries or would like to discuss, please contact the FOI
Unit by email at [5][NHMRC request email], or by phone at (02) 6217 9000.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[6][NHMRC request email]

+61 (0) 2 6217 9000

[7]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

OFFICIAL

From: NHMRC FOI <[8][NHMRC request email]>
Sent: Wednesday, 29 October 2025 3:15 PM
To: [9][FOI #13932 email]
Cc: NHMRC FOI <[10][NHMRC request email]>
Subject: FOI Request 2025/26-005 - Conflicts of Interest Disclosure(s)
related to Australian Evidence-Based Clinical Practice Guideline for
Attention Deficit Hyperactivity Disorder [SEC=OFFICIAL]

 

OFFICIAL

 

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005

 

I refer to your request to the National Health and Medical Research
Council (NHMRC) under the [11]Freedom of Information Act 1982 (Cth) (FOI
Act) seeking:

 

…the Conflicts of Interest Disclosure(s) received by NHMRC in relation to

 

Australian Evidence-Based Clinical Practice Guideline for Attention
Deficit Hyperactivity Disorder

Developer: Australasian ADHD Professionals Association Date of Approval:
29/7/2022

 

as listed on
[12]https://aus01.safelinks.protection.outlo....

 

Time frame: 01/01/2018 to 30/7/2022

 

Below is some information about the processing of your request.

 

Timeframe for receiving your decision

The statutory timeframe for processing a request is 30 days, starting from
the day after the day on which your application was received. Therefore,
the due date for a decision on your request is 25 November 2025.

 

This timeframe may be extended where: 

·         charges are levied as prescribed by the [13]Freedom of
Information (Charges) Regulations 2019 (FOI Regulations) (see charges
below)

• consultation with third parties is necessary (see consultation with
third parties below). 

 

Charges

Agencies may decide that an applicant is liable to pay a charge in respect
of a request for access to documents. These charges are set by the
[14]FOI Regulations and are for search and retrieval of documents,
decision making and provision of access (for example, copying and
postage). 

 

If NHMRC decides to charge you in respect of this FOI request, we will
send you a preliminary assessment of the charges as soon as possible
following retrieval of any documents that may be relevant to your
request.  

 

Consultation with third parties

NHMRC may be required under the FOI Act to consult other parties (third
parties) where information relating to third parties arises in documents
sought by your request. The FOI Act prescribes a further 30 days
processing time for NHMRC to undertake this consultation. You will be
advised as soon as possible of any requirement to consult with a third
party.

 

Disclosure log

Please note that section 11C of the FOI Act requires agencies to disclose
documents released under the FOI Act in a disclosure log, which is made
publicly available. There are exceptions to this requirement, such as
where release of the documents or parts of them would involve the
unreasonable disclosure of your or another person’s personal or business
information. You may choose to express a view on this issue and to
identify personal or business information that in your view would be
unreasonable to publish. However, you should be aware that section 11C of
the FOI Act embodies a pro-disclosure policy which agencies are required
to follow, subject to any exceptions provided for under the FOI Act.

 

If you have any queries throughout the process, please contact the FOI
Unit at: [15][NHMRC request email]

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information
National Health & Medical Research Council
[16][NHMRC request email]

+61 (0) 2 6217 9000

[17]nhmrc.gov.au

 

                                             

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

 

OFFICIAL

show quoted sections

NHMRC FOI, National Health and Medical Research Council

1 Attachment

OFFICIAL

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005 – Extension request

 

This email is just a reminder that NHMRC is seeking your agreement to
extend the processing period of your FOI request by a further 30 days
(until 27 January 2026).

 

Please see my email below of 25 November 2025 for further information.

 

Grateful if you could please email [1][NHMRC request email] by close of
business today, 28 November 2025 to advise whether you agree to the
additional 30-day extension.

 

If you have any queries or would like to discuss, please contact the FOI
Unit by email at [2][NHMRC request email], or by phone at (02) 6217 9000.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[3][NHMRC request email]

+61 (0) 2 6217 9000

[4]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

OFFICIAL

From: NHMRC FOI <[NHMRC request email]>
Sent: Tuesday, 25 November 2025 4:13 PM
To: [FOI #13932 email]
Cc: NHMRC FOI <[NHMRC request email]>
Subject: FOI Request 2025/26-005 – Third party consultation and extension
request [SEC=OFFICIAL]

 

OFFICIAL

 

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005

 

I refer to your request to the National Health and Medical Research
Council (NHMRC) under the [5]Freedom of Information Act 1982 (Cth) (FOI
Act) seeking:

 

…the Conflicts of Interest Disclosure(s) received by NHMRC in relation to

 

Australian Evidence-Based Clinical Practice Guideline for Attention
Deficit Hyperactivity Disorder

Developer: Australasian ADHD Professionals Association Date of Approval:
29/7/2022

 

as listed on
[6]https://aus01.safelinks.protection.outlo....

 

Time frame: 01/01/2018 to 30/7/2022

 

Please see the below information about conducting third party consultation
for your FOI request. We are also seeking your agreement to extend the FOI
processing period.

 

Third party consultation

Through the processing of your request, NHMRC has identified a document
where the consultation provisions of the FOI Act (sections 27 and 27A)
apply – that is, where the document contains information concerning the
business, commercial or financial affairs of an organisation, or a
person’s business or professional affairs or personal information. NHMRC
is required to consult with the person or organisation concerned before
deciding on the release of the document.

 

Sections 27 and 27A of the FOI Act apply when it appears to the decision
maker, that the person or organisation concerned might wish to contend
that the document is exempt because its release would, or could reasonably
be expected to, unreasonably adversely affect their business or financial
affairs (section 27), or their personal privacy (section 27A).

 

More information about exemptions under the FOI Act is available on the
OAIC’s website: [7]www.oaic.gov.au/freedom-of-information

 

While any comments received from an individual or organisation that is
consulted will be taken into account, the final decision about whether to
grant you access to the documents you have requested rests with the
decision maker authorised under subsection 23(1) of the FOI Act.

 

In accordance with subsection 15(6) of the FOI Act, the period for
processing your request has been extended by an extra 30 days to allow
NHMRC time to conduct third party consultation. This places the due date
at 29 December 2025.

 

 

Extension request

In addition, NHMRC is seeking your agreement to extend the processing
period of your FOI request by a further 30 days (under section 15AA of the
FOI Act).

 

Please note that although the NHMRC office will be closed from 25 December
2025–1 January 2026 (inclusive), this time is still included in the FOI
processing period. A further extension of 30 days would allow NHMRC more
time to conduct third party consultation and process your request during
the December/January period.

 

If you agree to the additional extension, the due date for your request
would be 27 January 2026 (as the first business day following the
additional 30-day period).

 

Grateful if you could please email [8][NHMRC request email] by close of
business Friday 28 November 2025 to advise whether you agree to the
additional 30-day extension.

 

 

If you have any queries or would like to discuss, please contact the FOI
Unit by email at [9][NHMRC request email], or by phone at (02) 6217 9000.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[10][NHMRC request email]

+61 (0) 2 6217 9000

[11]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

OFFICIAL

From: NHMRC FOI <[12][NHMRC request email]>
Sent: Wednesday, 29 October 2025 3:15 PM
To: [13][FOI #13932 email]
Cc: NHMRC FOI <[14][NHMRC request email]>
Subject: FOI Request 2025/26-005 - Conflicts of Interest Disclosure(s)
related to Australian Evidence-Based Clinical Practice Guideline for
Attention Deficit Hyperactivity Disorder [SEC=OFFICIAL]

 

OFFICIAL

 

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005

 

I refer to your request to the National Health and Medical Research
Council (NHMRC) under the [15]Freedom of Information Act 1982 (Cth) (FOI
Act) seeking:

 

…the Conflicts of Interest Disclosure(s) received by NHMRC in relation to

 

Australian Evidence-Based Clinical Practice Guideline for Attention
Deficit Hyperactivity Disorder

Developer: Australasian ADHD Professionals Association Date of Approval:
29/7/2022

 

as listed on
[16]https://aus01.safelinks.protection.outlo....

 

Time frame: 01/01/2018 to 30/7/2022

 

Below is some information about the processing of your request.

 

Timeframe for receiving your decision

The statutory timeframe for processing a request is 30 days, starting from
the day after the day on which your application was received. Therefore,
the due date for a decision on your request is 25 November 2025.

 

This timeframe may be extended where: 

·       charges are levied as prescribed by the [17]Freedom of Information
(Charges) Regulations 2019 (FOI Regulations) (see charges below)

• consultation with third parties is necessary (see consultation with
third parties below). 

 

Charges

Agencies may decide that an applicant is liable to pay a charge in respect
of a request for access to documents. These charges are set by the
[18]FOI Regulations and are for search and retrieval of documents,
decision making and provision of access (for example, copying and
postage). 

 

If NHMRC decides to charge you in respect of this FOI request, we will
send you a preliminary assessment of the charges as soon as possible
following retrieval of any documents that may be relevant to your
request.  

 

Consultation with third parties

NHMRC may be required under the FOI Act to consult other parties (third
parties) where information relating to third parties arises in documents
sought by your request. The FOI Act prescribes a further 30 days
processing time for NHMRC to undertake this consultation. You will be
advised as soon as possible of any requirement to consult with a third
party.

 

Disclosure log

Please note that section 11C of the FOI Act requires agencies to disclose
documents released under the FOI Act in a disclosure log, which is made
publicly available. There are exceptions to this requirement, such as
where release of the documents or parts of them would involve the
unreasonable disclosure of your or another person’s personal or business
information. You may choose to express a view on this issue and to
identify personal or business information that in your view would be
unreasonable to publish. However, you should be aware that section 11C of
the FOI Act embodies a pro-disclosure policy which agencies are required
to follow, subject to any exceptions provided for under the FOI Act.

 

If you have any queries throughout the process, please contact the FOI
Unit at: [19][NHMRC request email]

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information
National Health & Medical Research Council
[20][NHMRC request email]

+61 (0) 2 6217 9000

[21]nhmrc.gov.au

 

                                             

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

 

OFFICIAL

show quoted sections

Dear NHMRC FOI,

The FOI Act provides an additional 30 processing days to undertake third party consultation. Are you requesting 30 days on top of this, for a total of 90 days?

Yours sincerely,

Zack

NHMRC FOI, National Health and Medical Research Council

1 Attachment

OFFICIAL

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005 – Extension request

 

Thank you for your email.

 

That is correct – NHMRC is seeking your agreement for an additional
30-days (under section 15AA of the FOI Act), to allow more time to conduct
third party consultation and process your request during the
December/January period.

 

If you agree to the additional 30 days, the due date for your request
would be 27 January 2026 (as the first business day following the extra
30-day period). If you do not agree, the due date would remain as 29
December 2025.

 

If you have any queries or would like to discuss, please contact the FOI
Unit by email at [1][NHMRC request email], or by phone at (02) 6217 9000.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[2][NHMRC request email]

+61 (0) 2 6217 9000

[3]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

OFFICIAL

show quoted sections

Dear NHMRC FOI,

I do not agree.

Yours sincerely,

Zack

NHMRC FOI, National Health and Medical Research Council

1 Attachment

OFFICIAL

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005

 

Thank you for your email.

 

We note that you do not agree to the extension and that the due date will
remain as 29 December 2025.

 

If you have any queries or would like to discuss, please contact the FOI
Unit by email at [1][NHMRC request email], or by phone at (02) 6217 9000.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[2][NHMRC request email]

+61 (0) 2 6217 9000

[3]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

OFFICIAL

show quoted sections

NHMRC FOI, National Health and Medical Research Council

2 Attachments

OFFICIAL

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005 – Access decision

 

Please see the attached correspondence in relation to your request.

 

If you have any queries or would like to discuss, please contact the FOI
Unit at: [1][NHMRC request email] or on (02) 6217 9000.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[2][NHMRC request email]

+61 (0) 2 6217 9000

[3]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

OFFICIAL

From: NHMRC FOI <[NHMRC request email]>
Sent: Friday, 5 December 2025 7:22 PM
To: [FOI #13932 email]
Cc: NHMRC FOI <[NHMRC request email]>
Subject: RE: Reminder: FOI Request 2025/26-005 – Third party consultation
and extension request [SEC=OFFICIAL]

 

OFFICIAL

 

Dear Zack

 

Re - Freedom of Information Request: No. 2025/26-005

 

Thank you for your email.

 

We note that you do not agree to the extension and that the due date will
remain as 29 December 2025.

 

If you have any queries or would like to discuss, please contact the FOI
Unit by email at [4][NHMRC request email], or by phone at (02) 6217 9000.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[5][NHMRC request email]

+61 (0) 2 6217 9000

[6]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

 

OFFICIAL

show quoted sections

Dear National Health and Medical Research Council,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of National Health and Medical Research Council's handling of my FOI request 'Conflicts of Interest Disclosure(s) related to Australian Evidence-Based Clinical Practice Guideline for Attention Deficit Hyperactivity Disorder'.

I contend this application of s 47E(d) and s 47F are deeply flawed.

The NHMRC Standards themselves (specifically Standard 2.3) require that guidelines "make publicly available the declarations of interest." Therefore, guideline developers are already on notice that their conflicts are a matter of public record, not private confidences.

The "proper and efficient conduct" of the NHMRC depends on public trust that the guidelines it approves are free from undisclosed bias. Keeping these disclosures secret does more to damage the credibility of the approval program than transparency ever could.

Information regarding a developer's financial ties to pharmaceutical companies or professional bodies is business information relevant to their suitability to draft national health guidelines. It is not "personal affairs" in the sense of one's private life; it is professional data central to the discharge of their public duties.

It is not "unreasonable" to disclose professional conflicts of those setting national health standards. These individuals hold positions of influence, and the public has a right to know if financial or professional interests may have influenced the ADHD Clinical Practice Guideline.

The original request seeks the disclosures received by NHMRC. Even if a redacted document confirms only the names of declarants and their specific commercial/research ties (while redacting phone numbers/family info), this is of immense value. It allows the public to verify if the disclosures made to the NHMRC match what the developer (AADPA) has publicly stated or released upon request.

It is highly likely that "Financial Disclosures" or "Commercial Relationships" are listed in columns or sections separate from "Home Address" or "Family Health." It is reasonably practicable to redact the truly private data while releasing the professional conflict data.

The public interest in ensuring that this guideline was developed without undue influence or unmanaged conflicts vastly outweighs the minimal privacy interest regarding the professional commercial ties of the guideline developers.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.righttoknow.org.au/request/c...

Yours faithfully,

Zack

NHMRC FOI, National Health and Medical Research Council

1 Attachment

OFFICIAL

Dear Zack

 

Thank you for your email.

 

I am writing to acknowledge receipt of your internal review application
for FOI request 2025/26-005.

 

Please note that under section 54C of the [1]Freedom of Information Act
1982 (Cth), the relevant timeframe for an internal review decision is
within 30 calendar days of receiving the internal review application.
Accordingly, the due date for a decision is 19 January 2026 (as the first
business day following the 30-day period).

 

If you have any queries, please contact the FOI Unit at:
[2][NHMRC request email]. Please note that the NHMRC office will be closed from
25 December 2025 to 2 January 2026.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[3][NHMRC request email]

+61 (0) 2 6217 9000

[4]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

OFFICIAL

show quoted sections

NHMRC FOI, National Health and Medical Research Council

2 Attachments

OFFICIAL

Dear Zack

 

Re – Internal Review Decision: Freedom of Information Request No.
2025/26-005

 

Please see the attached correspondence in relation to your internal review
request.

 

If you have any queries, please contact the FOI Unit at:
[1][NHMRC request email].

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[2][NHMRC request email]

+61 (0) 2 6217 9000

[3]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

OFFICIAL

From: NHMRC FOI <[NHMRC request email]>
Sent: Friday, 19 December 2025 5:00 PM
To: [FOI #13932 email]
Cc: NHMRC FOI <[NHMRC request email]>
Subject: RE: Internal review of Freedom of Information request - Conflicts
of Interest Disclosure(s) related to Australian Evidence-Based Clinical
Practice Guideline for Attention Deficit Hyperactivity Disorder
[SEC=OFFICIAL]

 

OFFICIAL

 

Dear Zack

 

Thank you for your email.

 

I am writing to acknowledge receipt of your internal review application
for FOI request 2025/26-005.

 

Please note that under section 54C of the [4]Freedom of Information Act
1982 (Cth), the relevant timeframe for an internal review decision is
within 30 calendar days of receiving the internal review application.
Accordingly, the due date for a decision is 19 January 2026 (as the first
business day following the 30-day period).

 

If you have any queries, please contact the FOI Unit at:
[5][NHMRC request email]. Please note that the NHMRC office will be closed from
25 December 2025 to 2 January 2026.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[6][NHMRC request email]

+61 (0) 2 6217 9000

[7]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

 

OFFICIAL

show quoted sections

NHMRC FOI, National Health and Medical Research Council

1 Attachment

OFFICIAL

Dear Zack

 

Re – Internal Review Decision: Freedom of Information Request No.
2025/26-005 – Query about disclosing identity to third party

 

We are writing to ask whether you would consent to disclosing your
identity to the relevant third party for the Internal Review of your FOI
request.

 

As advised in NHMRC’s Internal Review Decision letter of 19 January 2026,
the original access refusal decision for your FOI request was changed to
granting partial access and the third party has review rights under the
Freedom of Information Act 1982.

 

Under paragraph [1]3.24 of the FOI Guidelines – Guidelines issued by the
Australian Information Commissioner under s 93A of the Freedom of
Information Act 1982:

 

An FOI applicant’s identity should not be provided to any third party
without prior consultation and agreement by the FOI applicant. This also
applies if there is a request consultation process under ss 26A, 27 or
27A, or if another agency is consulted. Nevertheless, knowing an FOI
applicant’s identity may help a third party decide more easily whether to
object to disclosure and to frame any specific objections, and this issue
can be raised in consultation with an FOI applicant.

 

Grateful if you could please email [2][NHMRC request email] by close of
business Wednesday 28 January 2026 to advise whether you agree to
disclosing your identity (e.g. full name) and/or providing a link to the
[3]webpage for your FOI request on the Right to Know website (where you
have lodged your FOI and internal review requests, and which includes
correspondence between you and NHMRC, as well as your first name) to the
relevant third party.

 

If you have any queries or would like to discuss, please contact the FOI
Unit by email at [4][NHMRC request email], or by phone on (02) 6217 9000.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[5][NHMRC request email]

+61 (0) 2 6217 9000

[6]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

OFFICIAL

From: NHMRC FOI <[NHMRC request email]>
Sent: Monday, 19 January 2026 6:22 PM
To: [FOI #13932 email]
Cc: NHMRC FOI <[NHMRC request email]>
Subject: Decision: Internal review of Freedom of Information request -
Conflicts of Interest Disclosure(s) related to Australian Evidence-Based
Clinical Practice Guideline for Attention Deficit Hyperactivity Disorder
[SEC=OFFICIAL]

 

OFFICIAL

 

Dear Zack

 

Re – Internal Review Decision: Freedom of Information Request No.
2025/26-005

 

Please see the attached correspondence in relation to your internal review
request.

 

If you have any queries, please contact the FOI Unit at:
[7][NHMRC request email].

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[8][NHMRC request email]

+61 (0) 2 6217 9000

[9]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

OFFICIAL

From: NHMRC FOI <[10][NHMRC request email]>
Sent: Friday, 19 December 2025 5:00 PM
To: [11][FOI #13932 email]
Cc: NHMRC FOI <[12][NHMRC request email]>
Subject: RE: Internal review of Freedom of Information request - Conflicts
of Interest Disclosure(s) related to Australian Evidence-Based Clinical
Practice Guideline for Attention Deficit Hyperactivity Disorder
[SEC=OFFICIAL]

 

OFFICIAL

 

Dear Zack

 

Thank you for your email.

 

I am writing to acknowledge receipt of your internal review application
for FOI request 2025/26-005.

 

Please note that under section 54C of the [13]Freedom of Information Act
1982 (Cth), the relevant timeframe for an internal review decision is
within 30 calendar days of receiving the internal review application.
Accordingly, the due date for a decision is 19 January 2026 (as the first
business day following the 30-day period).

 

If you have any queries, please contact the FOI Unit at:
[14][NHMRC request email]. Please note that the NHMRC office will be closed
from 25 December 2025 to 2 January 2026.

 

Kind regards

 

Kate

 

____________________________________________________

NHMRC Freedom of Information 
National Health & Medical Research Council 
[15][NHMRC request email]

+61 (0) 2 6217 9000

[16]nhmrc.gov.au

 

 

In the spirit of reconciliation, NHMRC acknowledges the Traditional
Custodians of country throughout Australia and their connections to land,
sea and community. We pay our respects to their Elders past and present
and extend that respect to all Aboriginal and Torres Strait Islander
people.

 

 

 

 

 

OFFICIAL

show quoted sections

Dear NHMRC FOI,

> We are writing to ask whether you would consent to disclosing your
identity to the relevant third party for the Internal Review of your FOI
request.

You may and you may also include the link to the right to know request: https://www.righttoknow.org.au/request/c...

I strongly contest your decision to uphold the refusal of access to the substantive Conflict of Interest disclosures under sections 47E and 47F of the FOI Act.

By doing so is undermining the public's faith in NHMRC ability to execute it's role faithfully and honestly.

You argue that releasing this information would harm the NHMRC’s guideline approval program because the information was provided "on the understanding of mutual confidentiality." You state that breaching this trust would dissuade future developers from providing detailed info.

However, in the very same decision, you cite the ADHD Guideline (Appendix 4) which states: "The Conflict-of-Interest declarations for the GDG is available via request: [email address]".

You cannot simultaneously argue that:
a) The information is confidential and its release would breach a "mutual understanding" of secrecy; and
b) The developer has publicly stated that the information is available to the public upon request.

If the developer has publicly advertised that these declarations are available on request, there can be no reasonable expectation of confidentiality regarding the content of those professional declarations. The NHMRC’s refusal to release them when the developer fails to do so facilitates a lack of transparency that contradicts NHMRC Standard 2.31.

I accept the redaction of purely private information such as home addresses, private email addresses, health information, or family details. However, financial and professional/business affairs related to the subject matter of the guideline (e.g., funding from pharmaceutical companies, research grants, or paid advisory roles) do not pass the "unreasonable to disclose" test in this context.

The individuals in question were members of a Guideline Development Group (GDG) responsible for shaping national clinical practice and public health policy.

When experts agree to author national guidelines, they enter the public sphere. Their professional conflicts of interest are not "private affairs"; they are essential qualifications (or disqualifications) for the role they hold.

There is a profound public interest in knowing if the authors of the ADHD Clinical Practice Guideline received funding from entities that stand to profit from the guideline's recommendations. This public interest outweighs the "stress" or "professional interests" of the individuals. If an individual feels "stress" regarding the disclosure of their industry funding, it suggests in my opinion a conflict that the public absolutely needs to know.

You argue that transparency will dissuade future participation (ie "chilling effect"). I refute this. The integrity of the NHMRC approval process relies on transparency. If an expert refuses to participate in guideline development because they do not wish their industry conflicts to be public, they should not be on the panel. Transparency acts as a necessary filter for integrity, not a hindrance to operations.

To ensure the ADHD Clinical Practice Guidelines were developed with integrity and that the public trust is not undermined a reasonable person would expect that the information surrounding the conflicts of interests that NHMRC holds would be released expediently and without hindrance.

Yours sincerely,

Zack