On January 12, 2023, the White House Office of Science and Technology Policy (OSTP) issued its long-awaited framework for scientific integrity protections within federal agencies. CSLDF submitted comments during the framework development process, as did many other organizations and individuals, and we are pleased to see a number of our recommendations in the new framework.
Scientific integrity protections are essential to preserving the independence of government science, and to ensuring that good science informs our public policies. The Biden administration’s new framework helps address some of the problems seen during previous administrations – such as government censorship and misinformation — and, hopefully, ushers in a new era for federal science.
Perhaps most importantly, we are excited to see the inclusion of a model scientific integrity policy for federal agencies; CSLDF has long been a proponent of the value of having a model scientific integrity policy, which helps ensure that all agencies address key issues consistently and appropriately. Of particular note, OSTP’s new model policy clearly prohibits political interference, which has been a severe shortcoming in the current generation of policies, especially during the Trump era. In addition, OSTP’s model policy clearly prohibits retaliation, which protects those trying to enforce scientific integrity and ultimately helps restore trust in the federal government.
Scientists are also given communication rights in OSTP’s framework, and there is an emphasis on allowing scientists to communicate their research to the public; muzzling scientists was also an issue in the previous administration. The framework’s inclusion of Diversity, Equity, Inclusion and Accessibility (DEIA) provisions is long overdue and also deserves credit. Its emphasis on whistleblower protections, including specific laws that an agency must comply with, is essential as well.
At the most basic level, the framework also offers clarity around definitions of terms like “scientific integrity” and “scientific integrity official” that, historically, have been muddied at times. To that end, the inclusion of a scientific integrity official is to be lauded, as are the regular surveys and reviews contained in the framework, which should do more to highlight future shortcomings. Finally, the framework includes annual reporting on the scientific integrity process, including anonymized scientific integrity complaints and their resolutions, which provides necessary transparency.
The educational component is important, too: notably, OSTP’s model policy states that, “All employees and other covered entities will receive scientific integrity information or training as new employees to make them aware of their responsibilities under this scientific integrity policy within 6 months of their date of hire.”
But more work needs to be done. For example, in addition to banning “successful” interference, attempted interference must also be outright prohibited (as CSLDF’s own model scientific integrity policy does). It should be made obvious that any attempts to interfere with a scientist’s work for political or other inappropriate purposes will be punished.
OSTP’s model policy also leaves out important implementation details. For example, the complaint process itself lacks guidance and contains only vague language. It is similarly unclear what sorts of disciplinary actions might be applied if a violation is found – an area where policies have previously struggled.
Overall, though, this framework is a significant step forward, albeit with shortcomings that can be addressed in future iterations of the framework.
Meanwhile, we have a while to go before we will see actual policies in place at federal agencies – nearly a year, if everything goes according to plan. (So far, unfortunately, OSTP has largely been behind schedule.) While the framework recognizes the importance of creating a strong culture of scientific integrity, even if there are no delays with OSTP’s timeline, is doubtful whether it will be long enough to infuse that culture into agencies prior to the next (potentially science-hostile) administration.
Finally, the biggest vulnerability in OSTP’s framework is the fact that it is yet to be codified into law. Thus, it is more vital than ever that Congress passes the Scientific Integrity Act (SIA); current policies could all easily be undone by a future administration. You can find more information about the importance of the SIA here.