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As the Biden administration draws to a close, the White House Office of Science and Technology Policy (OSTP) has issued a new report recapping progress on scientific integrity and highlighting areas where more work is needed. The many government employees who have been working for the past four years to create a strong infrastructure of scientific integrity in the executive branch deserve credit for all they’ve accomplished. As the report makes clear, though, agencies still have work to do to make sure that scientists at agencies can do their job free from political interference.
Scientists at federal agencies must be able to collect, analyze, and report on data without being told to falsify records, being ordered re-do analyses to achieve a desired result, or seeing their work suppressed—all problems we’ve seen in recent years. If the public is going to heed government advice on topics from pandemic precautions to hurricane evacuations, we must be able to trust that scientific findings haven’t been warped to support a political appointee’s policy preferences.
Recognizing the need to strengthen public trust in government science, President Biden signed a January 2021 memorandum instructing agencies to either revise their existing scientific integrity policies or create new ones. The memo directed an interagency task force to review the effectiveness of existing scientific integrity policies, collect public input, and identify effective practices. After the task force issued its report, the Scientific Integrity Framework Interagency Working Group created a framework for policies that includes a definition of scientific integrity; features all policies should contain; metrics for regular assessment and iterative improvement; and a model scientific integrity policy.
Policies, officials, procedures, and evaluations
The new OSTP report provides a snapshot of progress by 28 agencies (or, technically, “departments, independent agencies, distinct agencies within departments, or offices”). Nineteen of the 28 have finalized or updated their scientific integrity policies as required by the 2021 presidential memorandum; the remaining nine “are still undergoing review and approval within their agencies.” Twenty-five of the 28 have designated scientific integrity officials responsible for overseeing policy implementation.
One concern about many of the policies is that they don’t explain sufficiently how the agencies will handle allegations of policy violations. For policies to effectively safeguard scientific integrity, employees and the public must be able to trust that there’s an effective way to raise concerns about scientific integrity problems and get them resolved. Many scientific integrity policies don’t give specifics about policy enforcement, instead stating that procedures for addressing scientific integrity concerns are under development. According to the OSTP report, 15 agencies have finalized these procedures. Not all agencies are starting from scratch here; for instance, the scientific integrity policy of the National Oceanic and Atmospheric Administration policy references a Procedural Handbook that the agency first issued in 2011 and updated in 2021.
One positive aspect of the framework that OSTP and the inter-agency working group developed is an expectation for regular evaluations to inform periodic updates to scientific integrity policies and procedures. However, the report states that only one-third of agencies have evaluation plans “in some stage of development and deployment.” Strong evaluation procedures will be important for ensuring that policies and procedures can improve over time, so I hope we’ll see all agencies develop evaluation plans in the coming months.
The role of public input
Shortly before OSTP released this report, UCS’s Anita Desikan released the findings of her analysis of 38 agencies’ publicly available information about their scientific integrity policies, scientific integrity officials, and reporting of investigations into scientific integrity violations. She found that many agencies have been slow to provide this information, and she highlighted a particularly disappointing element of their processes: only five agencies published their draft policies and solicited public comment via a Federal Register notice. The Federal Register is where agencies publish information about their activities, and using it to call for public comment is the best way to ensure that all interested stakeholders know about the comment opportunity.
One of the agencies that solicited public comments in the Federal Register was the Environmental Protection Agency (EPA), and UCS was one of several organizations that provided recommendations in response. The fact that EPA has undertaken a more thorough process to incorporate stakeholder feedback than most other agencies might be a reason why it has not yet finalized its policy. I hope when agencies update their policies in the future, they’ll publish a Federal Register notice to request public comments and use the feedback to strengthen their policies.
The next administration
I hope we’ll see all agencies’ scientific integrity policies finalized before the end of the Biden administration in January, and I hope the next administration will build on the groundwork established over the last four years. Next steps should include reinforcing the importance of implementing policies effectively; conducting robust evaluations of scientific integrity policies and procedures; and strengthening policies based on experience and public input.
It’s also possible that the next administration will reverse President Biden’s memorandum and weaken or rescind the policies agencies have developed. To ensure that the executive branch keeps building on its scientific integrity progress rather than squandering it, we need Congress to put into law the requirement for agencies to adopt and enforce scientific integrity policies designed to prevent political interference with scientific work. The Scientific Integrity Act, reintroduced into the 118th Congress by Rep. Paul Tonko, would accomplish that. If it passes, it will help the public trust that federal agencies have access to strong science to guide their decisionmaking.
