Today, the White House released a landmark framework that strengthens scientific integrity by protecting science-based decisions from undue political interference. The new guidance reflects not only the hard work of the Office of Science and Technology Policy (OSTP), the Scientific Integrity Framework Interagency Working Group, and the National Science Technology Council (NSTC), but it also reflects the culmination of decades of research and advocacy by the Center for Science and Democracy (formerly known as the Scientific Integrity Program) at the Union of Concerned Scientists (UCS).
Back in February, 2004, UCS sent a statement to then-President George W. Bush signed by hundreds of the nation’s leading scientists that called on his administration to restore scientific integrity to federal policymaking. At that time, UCS’s use of “scientific integrity” as a policy term was new, but the problem was age old: scientists in the federal government and scientific advisors were reporting a sharp increase in the politicization of their work. Scientific findings were being suppressed and distorted to better align with political priorities; scientists were being prevented from speaking to the media; and scientific advisory committees were being stacked based on political considerations.
Not long after that, the UCS scientific integrity program began surveying federal scientists and collecting data to independently gauge the state of science in agencies–a survey that we continue to this day. We began making recommendations on strengthening scientific integrity during the Obama administration, and we strongly advocated for federal agencies to develop scientific integrity policies, which was the focus of a 2010 OSTP memo. Our program’s research and work prepared us to defend federal scientists and their work from an unprecedented number of scientific integrity violations in the Trump administration, during which we learned even more about how to strengthen scientific integrity.
Given that background, I am both excited and comforted to see that the Biden administration’s new scientific integrity framework aligns so closely with UCS’s work and recommendations. And I am hopeful that this framework will ensure that science always has a seat in our government’s decisionmaking processes. The framework will also help protect science-informed decisions from politicization, which should help increase the public’s trust in these decisions.
With this framework in place, everyone can breathe a little easier knowing independent science should be able to fully inform critical government decisions that protect public health and our environment.
What’s good? A lot!
There is a lot that is good in the framework–a full 68 pages of text–so I do encourage those who want the specifics to read the entire document. However, these are the details of the framework that I find particularly notable and exciting.
The framework charters a subcommittee on scientific integrity to be housed within the NSTC, a strong step in the right direction. Establishing this subcommittee under the NSTC–a cabinet-level council of advisors to the president on science and technology matters–also signals the importance of scientific integrity to the Biden administration. This subcommittee will be comprised of career scientific integrity officials from multiple federal agencies. It will serve as a coordinator for interagency scientific integrity matters, provide advice, and help assess updates or new development on agency scientific integrity policies. Most importantly, this subcommittee will be able to provide recommendations on scientific integrity violations where federal agencies may not have much power to do so (e.g., when a senior level political appointee is involved). During the Trump administration, senior-level political appointees were often the ones to violate agency scientific integrity policies. So, the independence of this subcommittee is a welcome development to help hold senior level decisionmakers accountable.
The framework also calls for scientific integrity policies to be reviewed, and updated as needed, every two years. Federal agencies will be required to collect information regarding several “critical” metrics outlined in the framework, such as measuring the percentage of agency leaders meeting the minimum score on their scientific integrity training. These metrics will help OSTP and the NSTC subcommittee on scientific integrity assess the effectiveness of an agency’s policy. Monitoring and evaluation of scientific integrity policies will help agencies better understand what is going well, and what is not, so that they can continue to improve and strengthen their program.
Additionally, these metrics, as well as the common definition of scientific integrity provided in the framework, will help establish some consistency across federal agency policies. Scientific integrity policies widely vary in the protections they afford to federal scientists and their work meaning a violation of a policy at one agency may not be a violation at another. More consistency across agency policies will alleviate confusion on whether a scientific integrity violation has occurred.
Where is more work needed?
While the framework is great on many scientific integrity issues, it is weak in detailing accountability and enforcement. The framework asks agencies to clearly articulate the “consequences and remedies for violations of the scientific integrity policy,” and an associated memorandum states that “violations of scientific integrity policies should be taken as seriously as violations of government ethics rules and must come with appropriate consequences,” but guidance stops there. This means that agencies are left to use their discretion when it comes to accountability, which did not work well under the prior administration. A lack of clarity on accountability and enforcement points out the need for Congress to act swiftly on codifying scientific integrity processes in legislation by passing the Scientific Integrity Act, to ensure that agencies have authority to act when integrity is lost.
We also are concerned about the framework’s lack of detail regarding the tie between scientific integrity and diversity, equity, inclusion, and accessibility (DEIA). Lapses of integrity in science-based decisions have the potential to harm many people in the United States, but the impacts often fall disproportionately on communities of color and low-income communities. A memorandum included with the release of the framework recognizes that “identity-based and other forms of harassment, discrimination and bias, unsafe work environments, and other issues related to improving diversity, equity, inclusion, and accessibility in Federal science intersect with issues of scientific integrity.” The framework’s model policy does provide text that agencies may include regarding the creation of a workplace that is “safe and equitable,” and regarding the use of different modes of science and knowledge-gathering systems. The framework also suggests agencies investigate disproportionate impacts of scientific integrity violations, but no details of how this will be done are provided, nor was DEIA included in the metrics used to assess the effectiveness of scientific integrity policies. The new NSTC subcommittee’s charter states that advice may be provided on emerging issues such as the intersection of scientific integrity and DEIA. We hope the administration will make this a priority.
The framework also could be strengthened by providing a definition of a federal “agency.” President Biden’s memorandum on strengthening scientific integrity was clear that all agencies, not just those that primarily conduct science, should strengthen their scientific integrity programs and processes, or develop scientific integrity policies if they currently do not exist. This means that departments and bureaus could find a loophole in complying with the president’s memorandum given that they are not technically defined as an “agency.” In other cases, some departments may defer to their parent agency’s policies, which has proven to make scientific integrity investigations confusing and complicated in the past.
A great step for science
Using the Biden administration’s charge to advance scientific integrity and the new framework to implement it, agencies must now get to work to ensure their policies adequately protect the independence of federal scientists and their work. The more work that’s done now to foster a culture of scientific integrity across the federal government the better we will be able to guard against future threats to science in decisionmaking.
I think this framework offers a great step forward and it is likely to remain in place for many years to come. I am especially thrilled to see that the federal government will now use systematic data collection and analysis will help improve scientific integrity on an ongoing basis. That is what we do in science: we ask questions, we collect data, we learn, we collect more data, and we continue to learn. Why should our scientific integrity policies be any different from the practices scientists rely on themselves?
Today is a great day for anyone who depends on our government to use unfettered science in its decisions to protect the public and our environment – and that’s pretty much all of us!