Although the documents were highly suggestive (as was the lack of waivers for a number of individuals who probably should have gotten them) on their own, they did not constitute proof that NIH had been overlooking conflicts of interest.
The Office of Government Ethics is the agency in charge of setting the ethical standards of executive branch personnel. Every time an agency like NIH issues a 208(b)(3) waiver—except under "all but the most exigent circumstances"—it is required by federal regulations to consult with OGE about the waiver. I put in a FOIA request for records of any such consultations from NIH. Despite producing a number of consultation records, including one with NIH about a different kind of waiver, OGE was unable to substantiate a single instance between 2005 and late 2011 where NIH consulted with OGE regarding a 208(b)(3) waiver as required. When I asked NIH to provide evidence that it was consulting with OGE, NIH refused to do so.
Investigative journalists are familiar with all the techniques my class and I used to write this story. We figured out how to use existing data in new ways, as we did with the Dollars for Docs dataset, to generate leads for story ideas. Then, once we had those leads—the list of grantees and advisory committee members taking money from big pharma—we chased down documents that could help us figure out what was really going on. The answers we got were worth the effort.