I wrote in February about the new Framework for Federal Scientific Integrity Policies and Practices released by the White House Office on Scientific and Technology Policy (OSTP), which represents an important step forward in the Biden-Harris administration’s efforts to strengthen scientific integrity across the executive branch. Now my organization, the Jacobs Institute of Women’s Health, is one of 13 groups — including environmental, public health, watchdog, reproductive health, and whistleblower groups — that have written to OSTP to thank the agency for issuing the framework and recommend some small but meaningful improvements. 

Guiding agencies’ scientific integrity policies

The framework is part of a process that President Biden laid out in a memorandum during his first week in office to ensure that all agencies develop and enact policies to protect science from inappropriate political interference. The framework provides guidance for agencies to use when either developing new scientific integrity policies or revising their existing policies. When the framework was released, OSTP Director Arati Prabhakar instructed agencies to submit their draft policies to OSTP and the Subcommittee on Scientific Integrity for review; based on OSTP feedback and public input, agencies should then revise their policies and adopt final versions.

A key component of the framework is a model policy that agencies can use as a starting point and tailor to suit their needs. In my previous post, I highlighted several of the important sections of the model policy, such as those prohibiting “political interference or inappropriate influence in the funding, design, proposal, conduct, review, management, evaluation, or reporting of scientific activities and the use of scientific information” and stating that it is the agency’s policy to “ensure that scientific findings and products are not suppressed, delayed or altered for political purposes and are not subjected to inappropriate influence.” 

One thing I noted that I wanted to see more of in the model policy, though, was specifics about enforcement. The framework does designate individuals to establish procedures for ensuring compliance and accountability; however, given how central these elements are to the success of the effort to protect scientific integrity, it would be helpful to have them written into the policies. Enforcement is one of the areas that the letter to OSTP addresses. 

Recommendations to OSTP

Through the model policy and the metrics it lays out for evaluating agencies’ scientific integrity policies, the framework recognizes the importance of agencies handling allegations of scientific integrity violations fairly, allowing scientists to communicate with reporters and the public, holding accountable those found to have violated scientific integrity policies, and protecting whistleblowers from reprisal (among many other elements). The 13 organizations recommend modifications in each of these four areas.

Investigating allegations: The framework recognizes the importance of agencies adopting thorough and objective procedures for investigating allegations, but it leaves the specifics up to individual agencies. The letter recommends that the policies themselves (as opposed to the procedures, which agencies are tasked with developing later in the process) include more specifics about independent appeal mechanisms, safeguards for investigators’ independence, and timeliness.

Communications: The framework takes the important step of encouraging scientists to communicate with the media. The letter recommends 1) clarifying some ambiguities regarding media communications and clearance of materials intended for publication and presentation, 2) reinforcing federal anti-gag rules, and 3) removing a provision that could make scientists apprehensive about speaking with the media.

Enforcement: The framework acknowledges the importance of agencies establishing consequences and enforcement mechanisms by making this one of the criteria against which agencies’ policies will be evaluated. The letter recommends that scientific integrity policies should specify penalties for those found to have compromised scientific integrity and that the penalties be sufficiently meaningful to discourage violations. For appointees, who are not subject to the same kinds of penalties that civil servants are, the letter recommends publicly identifying those found to have violated scientific integrity policies.

Protections for Activities not Meeting the Definition of Whistleblowing: The model policy requires compliance with whistleblower protections, and the letter urges that it add explicit protections for scientists whose activities might not meet the definition of whistleblowing but nonetheless merit protection — e.g., pursuing research on controversial topics or publishing research findings that could be interpreted as disagreement with agency policy. 

The organizations recommend these modifications to the model policy to enhance its effectiveness. If updates to the model policy are not feasible, they recommend that agencies be encouraged to incorporate into their scientific integrity policies the provisions described in the letter.

I’m impressed with the work OSTP and the Scientific Integrity Framework Interagency Working Group have done to produce the framework and lay a strong foundation for effective scientific integrity policies from individual agencies. I hope to see these recommendations reflected in the draft policies that agencies produce.