A Framework for Federal Scientific Integrity Policy and Practice

A Framework for Federal Scientific Integrity

Policy and Practice

Guidance by the

SCIENTIFIC INTEGRITY FRAMEWORK INTERAGENCY WORKING GROUP

of the

NATIONAL SCIENCE AND TECHNOLOGY COUNCIL

January 2023

A FRAMEWORK FOR FEDERAL SCIENTIFIC INTEGRITY POLICY AND PRACTICE

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About the Office of Science and Technology Policy

The Office of Science and Technology Policy (OSTP) was established by the National Science and

Technology Policy, Organization, and Priorities Act of 1976 to provide the President and others within the

Executive Office of the President with advice on the scientific, engineering, and technological aspects of

the economy, national security, homeland security, health, foreign relations, and the environment, among

other topics. OSTP leads interagency science and technology policy coordination efforts, assists the Office

of Management and Budget with an annual review and analysis of Federal research and development in

budgets, and serves as a source of scientific and technological analysis and judgment for the President with

respect to major policies, plans, and programs of the Federal Government. More information is available at

https://www.whitehouse.gov/ostp.

About the National Science and Technology Council

The National Science and Technology Council (NSTC) is the principal means by which the Executive

Branch coordinates science and technology policy across the diverse entities that make up the Federal

research and development enterprise. A primary objective of the NSTC is to ensure science and technology

policy decisions and programs are consistent with the President's stated goals. The NSTC prepares research

and development strategies that are coordinated across Federal agencies aimed at accomplishing multiple

national goals. The work of the NSTC is organized under committees that oversee subcommittees and

working groups focused on different aspects of science and technology. More information is available at

https://www.whitehouse.gov/ostp/nstc.

About the NSTC Scientific Integrity Framework Interagency Working Group

The Scientific Integrity Framework Interagency Working Group (SIF-IWG) was created in response to the

charge of the January 27, 2021 Presidential Memorandum on Restoring Trust in Government Through

Scientific Integrity and Evidence-Based Policymaking to create a Scientific Integrity Task Force. Carrying

the duties of 2022 Task Force, SIF-IWG developed a framework for regular assessment and iterative

improvement of agency scientific integrity policies, following publication of the January 11, 2022 Scientific

Integrity Fast-Track Action Committee’s (SI-FTAC) report entitled Protecting the Integrity of Government

Science. The SIF-IWG provided executive departments and agencies a forum for discussing scientific

integrity and the improvement of scientific integrity policies to promote Federal scientifically informed and

evidence-based decision making. More information on the work of the SIF-IWG and the SI-FTAC is

available at https://www.whitehouse.gov/ostp/nstc/scientific-integrity-task-force/.

About this Document

This document delivers A Framework for Scientific Integrity Policy and Practice (the Framework). This is

the culmination of the work conducted by the SI-FTAC (2021 Task Force) and the SIF-IWG (2022 Task

Force) and builds on the January 2022 SI-FTAC report, Protecting the Integrity of Government Science.

Both that report and the Framework are in response to the 2021 Presidential Memorandum on Restoring

Trust in Government Through Scientific Integrity and Evidence-Based Policymaking, which directed OSTP

to review scientific integrity policies and practices and to establish a framework for regular assessment and

iterative improvement of scientific integrity in U.S. Federal agencies. To develop the Framework, the SIF-

IWG relied upon evidence gathered from engagement with multiple Federal scientific integrity officials

and other relevant agency staff, and through engagement with the public. This guidance document includes

the Federal definition of scientific integrity, a model scientific integrity policy for Federal agencies, and a

roadmap for assessment and iterative improvement of agency scientific integrity policies and practices.

A FRAMEWORK FOR FEDERAL SCIENTIFIC INTEGRITY POLICY AND PRACTICE

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This document is a work of the United States Government and is in the public domain (see 17 U.S.C. §105).

Subject to the stipulations below, it may be distributed and copied with acknowledgment to OSTP.

Copyrights to graphics included in this document are reserved by the original copyright holders or their

assignees and are used here under the Government’s license and by permission. Requests to use any images

must be made to the provider identified in the image credits or to OSTP if no provider is identified.

Published in the United States of America, 2022.

A FRAMEWORK FOR FEDERAL SCIENTIFIC INTEGRITY POLICY AND PRACTICE

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NATIONAL SCIENCE AND TECHNOLOGY COUNCIL

Chair

Arati Prabhakar, Director, Office of Science

and Technology Policy

Executive Director

Kei Koizumi, Acting Executive Director,

National Science and Technology Council

Committee on Science

Co-Chairs

Alondra Nelson, Office of Science and Technology Policy

Larry Tabak, National Institutes of Health

Sethuraman Panchanathan, National Science Foundation

Scientific Integrity Framework Interagency Working Group

Co-Chairs

Ryan Donohue, Office of Science and

Technology Policy (through August, 2022)

Gretchen T. Goldman, Office of Science and

Technology Policy

Francesca Grifo, Environmental Protection

Agency

Christopher Marcum, Office of Science and

Technology Policy

Anne Ricciuti, Department of Education

Craig Robinson, United States Geological

Survey

Executive Secretaries

Kashyap Patel, United States Fish and Wildlife

Service

Linda Pimentel, Centers for Disease Control

and Prevention

Principal Members

Ad Hoc Subgroup Members

Sarah Burgess-Herbert, United States Agency

for International Development*

Firas Ibrahim, Department of Transportation

Daniel Kidder, Centers for Disease Control and

Prevention

Carmine Leggett, Office of Management and

Budget

Bindu Nair, Department of Defense

*Also designed graphics.

Doug Bannerman, Department of Veterans

Affairs

Cynthia Decker, National Oceanic and

Atmospheric Administration

Michael Hodgson, Occupational Safety and

Health Administration

Byron Shumate, United States Geological

Survey

William Trenkle, United States Department of

Agriculture

A FRAMEWORK FOR FEDERAL SCIENTIFIC INTEGRITY POLICY AND PRACTICE

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TABLE OF CONTENTS

ABOUT THE NATIONAL SCIENCE AND TECHNOLOGY COUNCIL ................................................................................ I

ABBREVIATIONS AND ACRONYMS ......................................................................................................................... 2

EXECUTIVE SUMMARY ........................................................................................................................................... 3

INTRODUCTION ..................................................................................................................................................... 4

1. THE FEDERAL DEFINITION OF SCIENTIFIC INTEGRITY .......................................................................................... 8

2. A ROADMAP OF ACTIVITIES AND EXPECTED OUTCOMES AND MEASURING PROGRESS TOWARD A CULTURE OF

SCIENTIFIC INTEGRITY AT FEDERAL AGENCIES ........................................................................................................ 9

TABLE 1. FEDERAL SCIENTIFIC INTEGRITY: A ROADMAP OF ACTIVITIES AND OUTCOMES ............................................................. 10

METRICS AND MEASUREMENT METHODS FOR SCIENTIFIC INTEGRITY ACTIVITIES AND OUTCOMES ................................................ 12

Table 2. Activities: Metrics and Measurement Methods .................................................................................... 12

Table 3. Short-Term Outcomes: Metrics and Measurement Methods ................................................................ 18

Table 4. Intermediate Outcomes: Metrics and Measurement Methods ............................................................. 21

3. CRITICAL METRICS FOR REGULAR ASSESSMENT AND ITERATIVE IMPROVEMENT OF AGENCY SCIENTIFIC

INTEGRITY POLICY IMPLEMENTATION ................................................................................................................. 23

TABLE 5. CRITICAL METRICS FOR ASSESSMENT OF AGENCY ACTIVITIES .................................................................................... 23

TABLE 6. CRITICAL METRICS FOR ASSESSMENT OF AGENCY SHORT-TERM AND INTERMEDIATE OUTCOMES .................................... 24

4. MODEL SCIENTIFIC INTEGRITY POLICY FOR UNITED STATES FEDERAL AGENCIES .............................................. 26

5. CRITICAL POLICY FEATURES FOR ASSESSMENT OF SCIENTIFIC INTEGRITY POLICIES .......................................... 43

TABLE 7. CRITICAL POLICY FEATURES FOR ASSESSMENT OF SCIENTIFIC INTEGRITY POLICY WITH MODEL SCIENTIFIC POLICY

COMPONENTS ............................................................................................................................................................. 44

6. APPENDICES ..................................................................................................................................................... 47

APPENDIX A: DEFINITIONS FOR POSSIBLE INCLUSION IN AGENCY SCIENTIFIC INTEGRITY POLICIES ................................................. 47

APPENDIX B: EXAMPLES OF AGENCY SCIENTIFIC INTEGRITY POLICIES, PROCEDURES, AND RELATED MATERIALS .............................. 50

Agency Policies .................................................................................................................................................... 50

Agency Procedures .............................................................................................................................................. 51

Codes of Conduct ................................................................................................................................................ 51

Extramural Grant, Award, and Contract Language ............................................................................................ 52

Guidance on Designation of Authorship Guidelines ............................................................................................ 52

Guidance on Addressing Differences in Scientific Opinion .................................................................................. 53

APPENDIX C: SUMMARY OF WHITE HOUSE SCIENTIFIC INTEGRITY MEMORANDUMS .................................................................. 54

Presidential Memorandum on Scientific Integrity for The Heads Of Executive Departments And Agencies from

President Barak Obama, March 2009 ................................................................................................................. 54

OSTP Memorandum on Scientific Integrity for the Heads of Executive Departments and Agencies from John P.

Holdren, December 2010 .................................................................................................................................... 54

Presidential Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based

Policymaking from President Joseph R. Biden, January, 2021 ............................................................................ 56

APPENDIX D: TEXT OF THE CHARTER OF THE NSTC SUBCOMMITTEE ON SCIENTIFIC INTEGRITY .................................................... 59

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Abbreviations and Acronyms

CFR Code of Federal Regulations

EOP Executive Office of the President

FAC Federal Advisory Committee

FTE Full Time Equivalent

NSTC National Science and Technology Council

OGC Office of the General Counsel

OIG Office of the Inspector General

OMB Office of Management and Budget

OSTP Office of Science and Technology Policy

PM Presidential Memorandum

SI Scientific Integrity

SIF-IWG Scientific Integrity Framework Interagency Working Group (Task Force, Jan 2022 – Jul 2022)

SI-FTAC Scientific Integrity Fast-Track Action Committee (Task Force, May 2021 – Dec 2021)

SIO Scientific Integrity Official

SIP Scientific Integrity Policy

SOSI Subcommittee on Scientific Integrity

USC United States Code

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Executive Summary

The 2021 Presidential Memorandum on Restoring Trust in Government Through Scientific Integrity and

Evidence-Based Policymaking charges OSTP to (1) review agency scientific integrity policy effectiveness

and (2) to develop a framework for regular assessment and iterative improvement of agency scientific

integrity policies and practices (Framework). This document builds on the review published in January

2022 by the National Science and Technology Council (NSTC) entitled Protecting the Integrity of

Government Science, which identified good agency practices on scientific integrity and areas in need of

consistency across agencies. This Framework includes key resources for agencies as they work to develop

and improve scientific integrity policies, practices, and culture. The Framework reflects input from the

interagency Scientific Integrity Task Force and other key Federal officials, and includes considerations

from public input.

To foster regular assessment and iterative improvement at Federal agencies, the Framework includes

several components, including a first-ever Government-wide definition of scientific integrity, a roadmap of

activities and outcomes to achieve an ideal state of scientific integrity, a Model Scientific Integrity Policy,

as well as critical policy features and metrics that OSTP will use to iteratively assess agency progress. The

Framework also includes a charter for the newly established NSTC Subcommittee on Scientific Integrity.

This subcommittee has been chartered by the NSTC Committee on Science to assist OSTP in assessment

and iterative improvement of agency and EOP component scientific integrity policies, practices, and

culture; provide advisory responses to agency requests for another agency to review their internal scientific

integrity policies and processes, such as inquiries related to senior-level officials, political appointees, or

scientific integrity officials; and serve as a community of practice for Federal agency scientific integrity

officials and staff.

The goal of this Framework is to assist agencies across the Federal Government as they take next steps

together to strengthen, implement, and institutionalize scientific integrity policy, practice, and culture.

Figure 1 illustrates the process by which agencies can take to use the components of this Framework with

the goal of making iterative improvements over time.

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Figure 1. Process for Improving Federal Scientific Integrity Policy and Practice

Presidential Memorandum for the Heads of Executive Departments and Agencies on Scientific Integrity. March 9, 2009. The

White House.

Memorandum for the Heads of Executive Departments and Agencies on Scientific Integrity. December 17, 2010. Office of

Science and Technology Policy

Presidential Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policy

Making. January 27, 2021. The White House

Protecting the Integrity of Government Science, A report by the Scientific Integrity Fast-Track Action Committee of the

National Science and Technology Council, January 2022

A Framework for Federal Scientific Integrity Policy and Practice, Guidance by the Scientific Integrity Framework

Interagency Working Group of the National Science and Technology Council, August 2022

Memorandum for the Heads of Executive Departments and Agencies on Scientific Integrity. August, 2022. Office of Science

and Technology Policy

Introduction

Scientific and technological information is essential for the development of evidence-based policies and

the equitable delivery of government programs intended to improve the environment and the health,

security, safety, and well-being of all people. In turn, government science and scientific activities must be

held to the highest standards of scientific integrity, free from inappropriate influence at all stages from

development to dissemination. A strong culture of scientific integrity allows science and scientists at

Federal agencies to thrive and supports agencies’ abilities to meet their missions. Most pressingly, measures

to prevent and address political interference in the conduct, management, communication, or use of science

should be at the forefront of agency practices to bolster high standards of scientific integrity. Indeed, over

the last decade and a half, Federal departments, agencies, administrations, and commissions (referred to

collectively as “agencies”) have taken steps to strengthen scientific integrity with good practices. These

good practices were outlined in the 2022 National Science and Technology Council (NSTC) Report titled:

Protecting the Integrity of Government Science (Report).

The Report identified considerable variability

A report by the Scientific Integrity Fast-Track Action Committee of the National Science and Technology Council.

“Protecting the Integrity of Government Science.” January 11, 2022.

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across agencies in policies and practices around scientific integrity. While agency scientific integrity

policies and practices may vary with agency-specific missions, statutes, and regulations, the Report noted

several areas where consistency across the Federal government would further strengthen scientific integrity

and protect government science. Specifically, the Report identifies approaches to bolster the ability of

Federal agencies to protect government science focusing on the following categories: strengthening

scientific integrity policies, making scientific integrity everyone’s responsibility, implementing good

practices, addressing emerging themes, institutionalizing scientific integrity, and identifying next steps for

enhancing scientific integrity. The NSTC presents this agency guidance, translating these good practices

and areas in need of improvement identified by the report into a framework. This framework will support

the continuation of the improvement of scientific integrity policies and practices across the Federal

government.

The 2021 Presidential Memorandum on Restoring Trust in Government Through Scientific Integrity and

Evidence-Based Policymaking

(PM 2021) charges OSTP and NSTC to (1) review agency scientific

integrity policies and consider whether they prevent political interference in the conduct, management,

communication, and use of science, and identify effective practices for improving their implementation

(resulting in the Report) and (2) to develop a framework for regular assessment and iterative improvement

of agency scientific integrity policies and practices. This Framework includes key resources for agencies to

use as they develop or update their scientific integrity policies, monitor and measure agency

implementation, and work to improve their policies, practices, and culture. The Framework reflects input

from the Scientific Integrity Task Force (presently per the publication of this document, the NSTC

Scientific Integrity Framework Interagency Working Group, or SIF-IWG; and formerly the NSTC

Scientific Integrity Fast-Track Action Committee, or SI-FTAC), other key Federal officials, and the public.

To facilitate regular assessment, iterative improvement, and a scientific integrity community of practice for

Federal agencies, the NSTC has established the Subcommittee on Scientific Integrity (the Subcommittee).

The Subcommittee is comprised of Federal agency Scientific Integrity Officers (SIOs) and is charged with

carrying out interagency functions related to scientific integrity, including recognition of agency progress

on fostering a vibrant culture of scientific integrity; assessment of agency scientific integrity policies and

practices; coordination and shared learning across SIOs; coordination with other relevant Councils such as

the Evaluation Officer Council, Chief Data Officer Council, and Interagency Council on Statistical Policy;

and, when appropriate, sharing of analysis or commentary on public allegations of scientific integrity

violations that cannot be suitably handled at an individual agency-, department-, or Executive Office of the

President component-level, such as allegations involving senior-level officials, political appointees, or SIOs

or allegations involving multiple agencies. The text of the Subcommittee Charter is provided in Appendix

To assess agency scientific integrity policies and practices, as directed in the Presidential Memorandum,

OSTP will be guided by the roadmap of activities and outcomes to achieve an ideal state of scientific

integrity (Chapter 2) and the Model Scientific Integrity Policy (Chapter 4). Specifically, OSTP, working

through the Subcommittee, will use the following to assess agency scientific integrity policies and practices,

while allowing appropriate agency flexibility in policy provisions, metrics, and activities:

1. Critical Metrics for Assessment of:

a. Agency Activities (Chapter 3, Table 5) and

b. Short-Term and Intermediate Outcomes (Chapter 3, Table 6)

2. Critical Scientific Integrity Policy Features (Chapter 5, Table 7)

The goal of this Framework is to assist agencies across the entire Federal government as they take next

steps together to strengthen and institutionalize scientific integrity policy, practice, and culture and to fill

gaps in consistency across government as identified in the Report. The balance of this section describes the

Presidential Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based

Policy Making, January 27, 2021.

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organization of the Framework, which provides agencies with the tools necessary to strengthen scientific

integrity policies and practices. Figure 2 provides a schematic summary of the chapters of the Framework.

Figure 2. Schematic of the Framework for Regular Assessment and Iterative Improvement of Federal

Scientific Integrity

Chapter 1 presents a government-wide definition of scientific integrity. With a common understanding of

the values that scientific integrity upholds, agencies can move forward together, united and dedicated to

protect them. Given the extensive interagency deliberation and broad support of this definition all agencies

should adopt it; however, it is intentionally broad to accommodate agency mission diversity.

Chapter 2 provides a roadmap to achieve a culture of scientific integrity that is institutionalized in

agencies, in which the accuracy and objectivity of science is preserved, and public trust in agency science

is improved. The roadmap depicts the relationship between key agency scientific integrity activities and the

desired short- and intermediate-term desired outcomes, that then lead to the ideal or aspirational state.

Measuring implementation progress toward achieving outcomes are critical for understanding how agencies

are progressing and how they can improve scientific integrity policies and practices. This chapter also

provides metrics and measurement methods that agencies can use to evaluate their scientific integrity

activities and short- and intermediate-term outcomes. A subset of these metrics is considered critical metrics

for assessment by OSTP and are denoted with italicization in Table 2 (Chapter 2) and compiled in Chapter

3, Tables 5-6.

Chapter 3 highlights the critical metrics that will be used by OSTP and the Subcommittee in their biennial

assessment of agency implementation and improvement of scientific integrity policies and practices,

drawing directly from the roadmap presented in Chapter 2. Agencies should regularly collect and provide

these critical metrics to OSTP. Though only the listed metrics in this chapter will be used for OSTP’s

agency assessment, it is strongly encouraged that agencies collect additional metrics listed in Chapter 2.

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Chapter 4 presents a model scientific integrity policy to assist agencies as they develop and update their

policies. The model policy contains suggested sections and text for agency use. Agencies may adopt or

adapt the model scientific integrity policy language and organization to fit their needs.

Chapter 5 lists critical scientific integrity policy features that will be assessed by OSTP. These critical

policy features are demonstrated in the model scientific integrity policy in Chapter 4. Agencies should

ensure their policies encompass the intent of the critical policy features, which may or may not include

verbatim Model Policy language. By referring to the Model Scientific Integrity Policy, the critical policy

features presented in this chapter provide contextual examples that agencies can use to ensure their policies

meet the expectations in the 2021 Presidential Memorandum.

Collectively, these five chapters provide resources to strengthen scientific integrity across the Federal

government by laying out expectations for improving agency policies and practices. Agencies can continue

to refer to this Framework to adapt, refine, and implement scientific integrity policies toward restoring trust

in Federal science and ensuring unencumbered science informs decision-making across the Federal

Government.

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1. The Federal Definition of Scientific Integrity

A substantial gap identified in the Report was that the US Federal Government lacked a consistent definition

of scientific integrity. A definition was developed and agreed upon by the National Science and Technology

Council 2022 Scientific Integrity Framework Interagency Working Group and the 2021 Scientific Integrity

Fast Track Action Committee. Federal agencies should adopt this definition, incorporate it into their

scientific integrity policy, and communicate it to their workforce.

Scientific integrity is the adherence to professional practices, ethical behavior, and the

principles of honesty and objectivity when conducting, managing, using the results of, and

communicating about science and scientific activities. Inclusivity, transparency, and

protection from inappropriate influence are hallmarks of scientific integrity.

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2. A Roadmap of Activities and Expected Outcomes and Measuring Progress Toward a

Culture of Scientific Integrity at Federal Agencies

Monitoring and evaluating the implementation and outcomes of scientific integrity policies and practices is

critical for understanding agency progress and for continuously improving scientific integrity activities.

Ongoing performance measurement and monitoring are used to understand program accomplishments and

progress, particularly progress towards achieving desired outcomes. Program evaluation is a critical agency

function that uses systematic data collection and analysis to assess the effectiveness and efficiency of

programs and practices (consistent with the Foundations for Evidence-Based Policymaking Act of 2018

[Evidence Act]). Evaluation can help us understand what we are doing well or poorly and determine what

can be changed to improve programs, practices, and processes. In the context of scientific integrity,

performance measurement, monitoring, and program evaluation provide key evidence for understanding

how agencies are doing and how they can improve scientific integrity policies and practices.

A program roadmap or logic model is a graphic depiction of the relationship between a program’s activities

and its intended effects or outcomes. It concisely shows the relationship between planned work and intended

results and helps ensure clarity and consensus about the main strategies/activities and intended program

outcomes through the long-term outcomes/aspirations. A roadmap also serves as a foundation for

identifying what and how we measure, monitor, and evaluate to show progress toward implementing

activities and achieving intended outcomes.

The sections below provide a Roadmap of Activities and Outcomes for Federal Scientific Integrity policy

and practice implementation, as well as metrics and measurement methods for the activities, short-term

outcomes, and intermediate outcomes identified in the roadmap. The activities and outcomes tables also

include (in italicization) the critical metrics for agencies to collect and report. These critical metrics are also

compiled in Chapter 3, Tables 5-6. Agencies should use the information in Chapter 2 to develop and

implement an evaluation plan to regularly measure, monitor, evaluate, and learn from ongoing scientific

integrity activities and outcomes.

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Table 1. Federal Scientific Integrity: A Roadmap of Activities and Outcomes

ACTIVITIES

When we (Federal

agencies) do this…

SHORT-TERM

OUTCOMES

…then we expect these

changes to occur…

INTERMEDIATE

OUTCOMES

…which will lead to…

ASPIRATIONS

…our ultimate goals.

Establish and Implement Scientific Integrity (SI) Policies and Practices

• Develop/update and

implement SI

policies and

procedures

• Educate workforce

and maintain

visibility of SI

policies, practices,

and culture

• Conduct robust

evaluation to

improve policies and

practices

• SI policies are widely

known within Federal

agencies

• Improved agency

scientific processes and

science-informed

decision-making

• Improved management

and oversight of science

with integrity

• Federal employees and

other covered entities

demonstrate high levels

of principled behavior

• Strong organizational SI

culture in Federal

agencies

• Federal science

proposed, conducted,

reviewed, and used with

high levels of integrity

• Scientific work is trusted

and valued by agency

leadership

Federal agencies have

institutionalized a culture of

scientific integrity that

adheres to professional

practices, ethical behavior,

and the principles of

honesty, transparency, and

objectivity.

↓

Accuracy and objectivity of

science is preserved

↓

Improved public trust in

Federal agency science

↓

The United States is looked

to as a model of scientific

integrity

Demonstrate Engaged and Supportive Leadership

• Model, support, and

lead SI policy

implementation

• Set clear SI

expectations

• Ensure SI resources

& infrastructure to

support SI policies,

practices, and

evaluation

• Use credible and

objective scientific

information to inform

decisions

• Increased

demonstrations of SI

importance to agency

mission

• Improved management

of scientific activities

including leadership

recognition of

inappropriate influences

and preventive actions

• SI better integrated into

related agency policies

• SI activities and

evaluations are

adequately resourced

• Decision-makers

proactively seek out

relevant, credible, and

objective science to

guide Federal agency

decision-making

• Scientific integrity

policies consistently and

fully implemented across

agencies

Promote Transparent and Free Flow of Scientific Information

• Ensure timely, free

flow of scientific

information within

and outside of

agencies

• Ensure clearance

procedures do not

interfere with

transparency and

timeliness of

information

• Ensure scientific

accuracy of agency

communications

• Scientists are able to

communicate their

scientific activities and

appropriately share their

work with the public in

a timely manner

• Ability to have open

discussion and

legitimate scientific

discourse

• Communications

accurately convey

scientific content

• Openness and

transparency with media

by Federal scientists

• Scientific findings are

communicated with

quality, accuracy, clarity,

consistency, objectivity,

and transparency

• Public is able to access

and use Federal science

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ACTIVITIES

When we (Federal

agencies) do this…

SHORT-TERM

OUTCOMES

…then we expect these

changes to occur…

INTERMEDIATE

OUTCOMES

…which will lead to…

ASPIRATIONS

…our ultimate goals.

Ensure Accountability

• Encourage early and

confidential reporting

and protect those

who report

• Effectively address

and transparently

report on SI

violations and

concerns, and their

outcomes

• Consequences and

remedies for

scientific integrity

policy violations are

clearly articulated

• Enforcement

responsibilities and

processes are

documented

• Established and

publicized channels for

early consultations

• Improved procedures

for screening,

investigating,

documenting, and

communicating

outcomes

• Reporters of concerns

empowered and assured

• Increased early SI

consultations

• Improved safeguarding

of submitters who report

potential violations

• Improved agency

community trust and use

of scientific integrity

system

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Metrics and Measurement Methods for Scientific Integrity Activities and

Outcomes

The tables below provide metrics and example measurement methods for the activities (Table 2),

short-term outcomes (Table 3), and intermediate outcomes (Table 4) identified in the Federal

Scientific Integrity Roadmap above (Table 1). Key points related to these three tables are as

follows:

• Most of the metrics in the tables are examples of how agencies can monitor and evaluate

how they are doing and how they can improve scientific integrity policies and practices.

• There are some critical metrics needed for OSTP to assess scientific integrity progress.

These are noted within Tables 2-4 as follows:

o The italicized items in Tables 2 and 3 are critical metrics agencies should collect

and report to OSTP. Agencies can determine the most appropriate methods for

collecting these metrics and may consult with the Subcommittee as needed.

o The items marked with a “#” footnote are critical metrics that will be developed

and collected by OSTP and the Subcommittee.

• The critical metrics from Tables 2-4 (italicized items and “#” footnote) are summarized in

Chapter 3.

• These metrics may be updated over time as agency scientific integrity policies and practices

evolve.

• In cases where there are multiple example metrics and methods for an activity or outcome,

the numbers in the Metrics column align with the numbers in the Example Measurement

Methods column (i.e., showing possible ways to measure the corresponding metric).

• These are not exhaustive or required metrics or methods, and agencies are encouraged to

measure and evaluate in ways that are appropriate for their agency.

Table 2. Activities: Metrics and Measurement Methods

Activities Metrics Example Measurement

Methods

Establish and Implement Scientific Integrity Policies and Practices

Develop/update and

implement scientific

integrity policies and

procedures

1. Policy in place that meets OSTP

critical Scientific Integrity

Policy features.

1. a. Assessment of policy content

for alignment with OSTP critical

policy features.

b. Policy has completed review

and clearance.

c. Policy has been publicly

published.

2. Clearly specified frequency of

reviewing and, as needed,

updating policies.

2. Scientific integrity policy

specifies frequency for periodic

review and update, and reviews

conducted accordingly.

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Activities Metrics Example Measurement

Methods

3. Clear documentation of

procedures for implementing

SIP.

3. Analysis of document(s)

describing procedures to ensure

completeness in detailing

scientific integrity policy

4. Evidence that key scientific

integrity policy requirements

are being implemented with

fidelity.

4. Process evaluation of policy

implementation

5. Agency scientific integrity

committee charter with

membership criteria, authority, and

meeting frequency (for agencies

that designate other scientific

integrity points of contact).

5. Assessment of agency scientific

integrity committee

implementation: Analysis of

charter, meeting frequency, and

notes

6. Assessment of agency scientific

integrity committee effectiveness

at implementing and promoting

scientific integrity policies.

6. Survey of agency scientific

integrity committee members:

Leadership support of initiatives,

effectiveness and usefulness of

agency scientific integrity

committee

Educate workforce

and maintain

visibility of scientific

integrity policies,

practices, and culture

1. Agency scientific integrity

policy training is accessible

and it is clear who is required

to complete the training.

1. Web metrics: Number of hits to

scientific integrity policy and

practice documents (internal and

external)

2. Percentage of workforce trained

to specific knowledge level.

2. a. Percentage of workforce [or

staff required to take] trained at

onboarding and ongoing basis.

b. Percentage of those who took

the training meeting minimum

score and/or knowledge test

score

3. Number and type of guidelines,

tools, and trainings available.

3. Analysis of the number of

guidelines, tools, and trainings

available.

4. Training for supervisors and

leaders is provided.

4. a. Percentage of supervisors or

leaders trained at onboarding or

when become supervisors, and on

ongoing basis.

b. Percentage meeting minimum

score and/or knowledge test

score

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Activities Metrics Example Measurement

Methods

Conduct robust

evaluation to improve

policies and practices

1. Scientific integrity evaluation

plan developed that includes

clear articulation of expected

activity and outcome measures

being collected and how they

will be used for improvement.

1. Completed and approved

evaluation plan that describes

measures to be collected, how

they will be collected and by

whom, frequency of collection

and analysis, and how data will

be used for policy and practice

improvement.

2. Evaluation plan implemented.

2a. Evaluation plan implemented.

Data collected are analyzed and

used on ongoing/continuous basis

to improve scientific integrity

processes and practices.

2b. Evaluation appropriately

resourced to implement and

complete.

Demonstrate Engaged and Supportive Leadership

Model, support, and

lead scientific

integrity policy

implementation

Set clear scientific

integrity expectations

1. Information and document(s)

describing leadership

responsibilities and

expectations.

1. Analysis of document describing

responsibilities and expectations

for completeness and clarity of

descriptions of leadership

responsibilities

2. Evidence of communications

about scientific integrity and

expectations.

2. Review of agency-wide

communications (e.g., leadership

emails to all staff, newsletters,

intranet) about leadership support

for scientific integrity and

expectations around SI

3. Evidence of engagement on

scientific integrity (e.g., meeting

and consulting their SIO).

3a. Frequency of briefings, meetings,

and consulting engagements with

the SIO.

3b. SIO survey reports of being

engaged in meaningful

discussions with leaders

– 15 –

Activities Metrics Example Measurement

Methods

Ensure scientific

integrity resources &

infrastructure to

support scientific

integrity policies,

practices, and

evaluation

1. Assessment of estimated

monetary and other resources

allocated to scientific integrity.

1a. Analysis of resources (e.g.,

dedicated FTEs, funding)

1b. SIO fed-wide survey: Accounting

of resources including staff and

other support.

Use relevant science

to inform decisions

1. Perceptions by staff of

whether/how leadership is using

science to inform decisions.

1. Staff survey & SIO fed-wide

survey: Perceptions of leadership

use of science in decision making

2. Processes in place to govern the

use of science to inform

decisions.

2. Review and assessment of

agency processes for use of

science to inform decisions.

Promote transparent and free flow of scientific information

Ensure timely, free

flow of scientific

information within

and outside of

agencies

1. Scientists’ perceptions of

timeliness and free flow of

information.

1. Survey of scientists on regular

basis over time to track trends:

Perceptions of timeliness of

information sharing, perceptions

of restrictions/free flow of

information.

2. Reports of allegations or

expressions of concern regarding,

or determinations of, suppression

and delay.

2. Analysis of systems for reporting

allegations/concerns: # reports,

types, trends over time.

Ensure clearance

procedures do not

interfere with

transparency and

timeliness of

information

1. Tracking clearance of scientific

products to detect problem areas.

1. Analysis of clearance systems:

timeliness of clearance, review of

types of comments.

– 16 –

Activities Metrics Example Measurement

Methods

Ensure scientific

accuracy of agency

communications

1. Agency communications policy

is consistent with the Model

SIP and includes how and

when scientists provide input

on communications.

1a. Assessment of agency

communications policy.

1b. Survey of scientists whether they

were consulted and agreed with

agency communications about

their products

Ensure Accountability

Encourage early and

confidential reporting

and protect those who

report

1. Scientific integrity policy or

procedures or both describe

protections and a confidential

reporting process and are

published on a publicly facing

website

1. Assessment of policy and

procedures for clarity,

confidentiality, and ease of

reporting

2. Reporting system and methods

are easy for scientists to find

on web, and easy to use

2a. Assessment of reporting system

for clarity, confidentiality, and

ease of reporting

2b. Analysis of reports submitted:

how early in process did

reporting occur, completeness of

data

3. Confidentiality limits and

whistleblower protections are

communicated, and reporting

of retaliation is encouraged

3. Survey of employees and other

covered entities as appropriate:

Knowledge of how to report.

Knowledge of confidentiality

limits and whistleblower

protections. Ease of reporting and

protecting confidentiality of

submitters (actual process for

those who have submitted,

perceptions for those who

haven’t submitted).

For those who reported: Whether

they felt protected and

experienced any retaliation.

– 17 –

Activities Metrics Example Measurement

Methods

Effectively address

and transparently

report on scientific

integrity violations

and concerns, and

their outcomes

1. Publishing annually the

number and outcome of

administrative investigations

and appeals involving alleged

deviations from the agency’s

scientific integrity policies on a

publicly facing website, while

protecting confidentiality of

individuals involved.

1a. Review SIO anonymized

documentation reported

violations and resolution.

1b. Survey of those who reported

violations or concerns assessing

their satisfaction with the

timeliness outcome of the

response

Consequences and

remedies for scientific

integrity policy

violations are clearly

articulated

Enforcement

responsibilities and

procedures are

documented

1. Scientific integrity policy or

procedures or both describe

consequences and enforcement

responsibilities, or reference

other agency policies that

address consequences and

enforcement responsibilities

1. Analysis of scientific integrity

policy and procedures for

consequences and enforcement

responsibilities

– 18 –

Table 3. Short-Term Outcomes: Metrics and Measurement Methods

Short-Term

Outcomes

Metrics Example Measurement

Methods

Establish and Implement Scientific Integrity Policies and Practices

Scientific integrity

policies are widely

known within federal

agencies

1. Percentage of employees and other

covered entities as appropriate, within

agencies who are aware of policies,

procedures, and practices

1. Survey of employees

and other covered

entities as appropriate,

within agencies:

Awareness of policies,

procedures, and

practices

Improved agency

scientific processes and

science-informed

decision-making

1. Whether there are processes in place that

can detect when there is a potential loss

of scientific integrity

1. Analysis of scientific

processes to determine

if issues were identified

and resolved

2. Staff perceptions of whether decision

making is being informed by science

(within their unit and agency-level)

2. Survey of employees

and other covered

entities as appropriate,

within agencies

Improved management

and oversight of science

with integrity

1. Perceptions among agency employees and

other covered entities as appropriate, of

scientific integrity in management and

oversight of scientific activities (within

their unit and agency-level)

1. Survey of employees

and other covered

entities as appropriate,

within agencies and

SIO input/survey

Federal employees and

other covered entities

demonstrate high levels

of principled behavior

1. Perceptions among agency employees and

other covered entities as appropriate, of

whether others are operating with

principled behavior within their unit and

agency-level

1. Survey of employees

and other covered

entities as appropriate,

within agencies

Demonstrate Engaged and Supportive Leadership

Increased

demonstrations of

scientific integrity

importance to agency

mission

1. Frequency of leadership communication

regarding importance of scientific

integrity (incorporating scientific integrity

in public engagement/interviews, internal

communications, etc).

1. Review of leadership

communications

2. Increased engagement between leadership

and SIO.

2. SIO survey

3. Perceptions of leadership commitment to

scientific integrity

3. Survey of employees

and other covered

entities as appropriate,

within agencies

Improved management

of scientific activities

1. Percentage of employees and other

covered entities as appropriate, within

agencies who agree: scientific activities

1. Survey of employees

and other covered

– 19 –

Short-Term

Outcomes

Metrics Example Measurement

Methods

including leadership

recognition of

inappropriate influences

and preventive actions

are managed according to scientific

integrity policy, leadership implements

preventive actions, leadership avoids

inappropriate influences, basis for

leadership decisions is transparent.

entities as appropriate,

within agencies

Scientific integrity

better integrated into

related agency policies

1. Percentage of identified policies where

scientific integrity has been integrated

(denominator: number of policies where

should be integrated).

1. Review of relevant

policies for integration.

Completed checklist for

scientific integrity

factors to be integrated

into agency policies.

Scientific integrity

activities and

evaluations are

adequately resourced

1. Tracking of resources devoted to

scientific integrity activities and

evaluations.

1. Database of resources

for scientific integrity,

such as staffing,

funding for evaluations,

policy implementation.

2. Tracking of full-time equivalents

(FTEs) dedicated to scientific integrity

activities.

2. SIO survey

3. Perceptions among employees and other

covered entities as appropriate, within

agencies and SIOs of resources devoted

to scientific integrity: e.g., whether have

sufficient staff to address scientific

integrity issues and concerns, requests for

support are thoroughly considered.

3. Survey of employees

and other covered

entities as appropriate,

within agencies; SIO

survey

Promote transparent and free flow of scientific information

Scientists are able to

communicate their

scientific activities and

appropriately share their

work with the public in

a timely manner

1. Percentage of employees and other

covered entities as appropriate, within

agencies who agree: they are able to

communicate their scientific activities

without interference, ability to speak

about their work is not inappropriately

impeded (e.g., presentations, publications,

interviews).

1. Survey of employees

and other covered

entities as appropriate,

within agencies

Ability to have open

discussion and

legitimate scientific

discourse

1. Percentage of employees and other

covered entities as appropriate, within

agencies who agree they are able to have

open discourse without fear of

repercussions.

1. Survey of employees

and other covered

entities as appropriate,

within agencies

Critical metrics whose development and administration will be overseen by OSTP and the Subcommittee

– 20 –

Short-Term

Outcomes

Metrics Example Measurement

Methods

Communications

accurately convey

scientific content

1. Percentage of employees and other

covered entities as appropriate, within

agencies who agree agency

communications accurately convey

scientific content.

1. Survey of employees

and other covered

entities as appropriate,

within agencies

Ensure Accountability

Established and

publicized channels for

early consultations

1. Ease of finding information on

consultations

1. Assessment of sources

where information is

publicized (e.g., web

sites)

2. Easily available and confidential

consultations

2. Assessment of sources

where information is

publicized (e.g., web

sites)

3. Percentage of scientific integrity training

materials that include information on early

consultations (why needed early, how to

report, how review process occurs)

3. Assessment of training

materials

Improved procedures

for screening,

investigating,

documenting, and

communicating

outcomes

1. Review of the procedures available and

updated as needed to continuously

improve their effectiveness.

1. SIO assessment and

report on frequency and

content of procedures

updates

2. Length of time taken from reporting

through communication of outcomes.

2. SIO tracking and

disposition data

Reporters of concerns

are empowered and

assured

1. Percentage of employees and other

covered entities as appropriate, within

agencies who are comfortable with

reporting a concern without repercussions

if it occurred.

1. Survey of employees

and other covered

entities as appropriate,

within agencies

2. Among staff who reported concern: %

who agreed they were comfortable

reporting concern, were assured there

would not be repercussions.

2. Survey or other follow

up method with people

who reported concerns

Critical metrics whose development and administration will be overseen by OSTP and the Subcommittee.

– 21 –

Table 4. Intermediate Outcomes: Metrics and Measurement Methods

Intermediate

Outcomes

Metrics

Example Measurement

Methods

Establish and Implement Scientific Integrity Policies and Practices

Strong organizational

scientific integrity

culture in Federal

agencies

1. Percentage of employees and other

covered entities as appropriate,

within agencies who agree their

agency has a strong scientific

integrity culture.

1. Survey of employees and

other covered entities as

appropriate, within

agencies

Federal science

proposed, conducted,

reviewed, and used with

high levels of integrity

1. Percentage of employees and other

covered entities as appropriate,

within agencies who agree their

agency science is (a) proposed, (b)

conducted, (c) reviewed, and (d) used

with high levels of integrity

1. Survey of employees and

other covered entities as

appropriate, within

agencies

Scientific work is

trusted and valued by

agency leadership

1. Percentage of employees and other

covered entities as appropriate,

within agencies who agree their

agency scientific work is trusted and

valued by their agency leadership.

1. Survey of employees and

other covered entities as

appropriate, within

agencies

Demonstrate Engaged and Supportive Leadership

Decision-makers

proactively seek out

relevant, credible, and

objective science to

guide Federal agency

decision-making

1. Percentage of employees and other

covered entities as appropriate,

within agencies who agree their

leadership proactively seeks out

relevant, credible, and objective

science to guide decision-making.

1. Survey of employees and

other covered entities as

appropriate, within

agencies and SIO survey

Scientific integrity

policies consistently and

fully implemented

across agencies

1. Review and assessment of

implementation across agencies.

1. Agency process evaluation

of policy and practice

implementation

2. Independent review and

SIO survey

Promote Transparent and Free Flow of Scientific Information

Openness and

transparency with media

by Federal scientists

1. Percentage of employees and other

covered entities as appropriate,

within agencies who report they a)

are able to communicate with media,

b) have permission to, and c) offered

the opportunity (if applicable)

1. Survey of employees and

other covered entities as

appropriate, within

agencies

1. Percentage of employees and other

covered entities as appropriate,

1. Survey of employees and

other covered entities as

Critical metrics whose development and administration will be overseen by OSTP and the Subcommittee.

– 22 –

Intermediate

Outcomes

Metrics

Example Measurement

Methods

Scientific findings are

communicated with

quality, accuracy,

clarity, consistency,

objectivity, and

transparency

within agencies who agree agency

findings are communicated with these

attributes

appropriate, within

agencies

2. Percentage of communications

products reviewed that meet specified

review criteria for quality, accuracy,

clarity, consistency, objectivity, and

transparency

2. Review of communications

products based on a rubric

addressing quality,

accuracy, clarity,

consistency, objectivity,

and transparency

Public is able to access

and use Federal science

1. Frequency of access and downloads

of documents

1. Web analytics for website

hits and download of

products

Ensure Accountability

Increased early scientific

integrity consultations

1. Percentage of concerns reported early

1. SIO data on reported

concerns (consultations)

2. Use of differing scientific opinion

(DSO) processes

2. Survey of employees and

other covered entities as

appropriate, within

agencies on use of DSO

Improved safeguarding

of submitters who report

potential violations

1. Percentage of covered entity

reporters who experienced negative

consequences

1. Survey of employees and

other covered entities as

appropriate, who reported

concerns

Improved agency

community trust and use

of scientific integrity

system

1. Percentage of employees and other

covered entities as appropriate,

within agencies who agree a)

reported concerns will be addressed,

b) validated concerns will have

consequences, and c) violators of

scientific integrity will be held

accountable

1. Survey of employees and

other covered entities as

appropriate, within

agencies

Aligned with the Foundations for Evidence-Based Policymaking Act of 2018 requirements for open data and

confidential information protection.

Critical metrics whose development and administration will be overseen by OSTP and the Subcommittee.

– 23 –

3. Critical Metrics for Regular Assessment and Iterative Improvement of Agency Scientific

Integrity Policy Implementation

The tables below show the critical metrics that OSTP and the Subcommittee will use in their

biennial assessment of agency implementation and improvement of scientific integrity policies

and practices, including assessment of agency scientific integrity activities (Tables 5) and short-

term and intermediate outcomes (Table 6), as submitted by agencies.

Tables 5-6 are the compilation of the critical metrics that agencies should collect (i.e. items

italicized in Tables 2-3) and critical metrics that OSTP will develop and implement (i.e. items

with the # footnote in Tables 3-4). Refer to Tables 2-4 for additional details on metrics and

example measurement methods for the activities, short-term outcomes, and intermediate

outcomes.

Table 5. Critical Metrics for Assessment of Agency Activities

ACTIVITIES

Establish and Implement Scientific Integrity Policies and Practices

Develop/update and implement agency scientific integrity policies and procedures

1. Policy in place that meets OSTP critical Scientific Integrity Policy features (see Chapter 5:

Critical Policy Features for Assessment of Scientific Integrity Policies)

2. Clearly specified frequency of reviewing and, as needed, updating policies. (see Chapter 5:

Critical Policy Features for Assessment of Scientific Integrity Policies)

3. Clear documentation of procedures for implementing scientific integrity policies (see Chapter 4:

Model Scientific Integrity Policy for United States Federal Agencies and Appendix B: Examples

of Agency Scientific Integrity Policies, Procedures, and Related Materials).

4. Evidence that key scientific integrity policy requirements are being implemented with fidelity.

Educate workforce and maintain visibility of scientific integrity policies, practices, and culture

1. Agency scientific integrity policy training is accessible and it is clear who is required to

complete the training.

2. Training for supervisors and leaders is provided.

Conduct robust evaluation to improve policies and practices

1. Scientific integrity evaluation plan developed that includes clear articulation of activity and

outcome measures being collected and how they will be used for improvement.

2. Evaluation plan implemented.

Demonstrate Engaged and Supportive Leadership

Model, support, and lead scientific integrity policy implementation. Set clear scientific integrity

expectations.

1. Information and document(s) describing leadership responsibilities and expectations

2. Evidence of communications about scientific integrity and expectations

Ensure scientific integrity resources & infrastructure

1. Assessment of monetary and other resources allocated to scientific integrity

Promote transparent and free flow of scientific information

– 24 –

Ensure scientific accuracy of agency communications

1. Agency communications policy is consistent with the Model SIP and includes how and when

scientists provide input on communications.

Ensure Accountability

Encourage early and confidential reporting and protect those who report

1. Scientific integrity policy or procedures or both describe protections and a confidential

reporting process and are published on a publicly facing website.

2. Reporting system and methods are easy for scientists to find on web, and easy to use

3. Confidentiality limits and whistleblower protections are communicated, and reporting of

retaliation is encouraged

Effectively address and transparently report on scientific integrity violations and concerns and

their outcomes

1. Publishing annually the number and outcome of administrative investigations and appeals

involving alleged deviations from the agency’s scientific integrity policies on a publicly facing

website, while protecting confidentiality of individuals involved.

Consequences and remedies for violations of the scientific integrity policy are clearly articulated.

Enforcement responsibilities and procedures are documented

1. Scientific integrity policy and/or procedures or both describe consequences and enforcement

responsibilities, or reference other agency policies that address consequences and enforcement

responsibilities

Table 6. Critical Metrics for Assessment of Agency Short-Term and

Intermediate Outcomes

SHORT-TERM OUTCOMES

Demonstrate Engaged and Supportive Leadership

Improved management of scientific activities, including leadership recognition of inappropriate

influences and preventive actions

• Percentage of employees and other covered entities as appropriate, within agencies who agree:

scientific activities are managed according to scientific integrity policy, leadership implements

preventive actions, leadership avoids inappropriate influences, basis for leadership decisions is

transparent

Scientific integrity activities and evaluations are adequately resourced

• Tracking of full-time equivalents (FTEs) devoted to scientific integrity activities

Promote Transparent and Free Flow of Scientific Information

For more information, see Tables 3 and 4. Metrics for the outcomes will be developed and administered by NSTC

Subcommittee on Scientific Integrity.

Unlike other criteria listed in this table, development of the metric for this outcome is complete.

– 25 –

Scientists are able to communicate their scientific activities and appropriately share their work

with the public in a timely manner

• Percentage of employees and other covered entities as appropriate, within agencies who agree:

they are able to communicate their scientific activities without interference, ability to speak

about their work is not inappropriately impeded (e.g., presentations, publications, interviews).

Ability to have open discussion and legitimate scientific discourse

• Percentage of covered entities within agencies who agree they are able to have open discourse

without fear of repercussions

Communications accurately convey scientific content

• Percentage of covered entities within agencies who agree agency communications accurately

convey scientific content

INTERMEDIATE OUTCOMES

Establish and Implement Scientific Integrity Policies and Practices

Strong organizational scientific integrity culture in Federal agencies

• Percentage of covered entities (as defined in agency Scientific Integrity Policy) within agencies

who agree their agency has a strong scientific integrity culture

Scientific work is trusted and valued by agency leadership

• Percentage of covered entities within agencies who agree their agency scientific work is trusted

and valued by their agency leadership

Demonstrate Engaged and Supportive Leadership

Decision-makers proactively seek out relevant, credible, and objective science to guide Federal

agency decision-making

• Percentage of covered entities within agencies who agree their leadership proactively seeks out

relevant, credible, and objective science to guide decision-making

Ensure Accountability

Improved agency community trust and use of scientific integrity system

• Percentage of covered entities within agencies who agree a) reported concerns will be

addressed, b) validated concerns will have consequences, and c) violators of scientific integrity

will be held accountable

MODEL SCIENTIFIC INTEGRITY POLICY FOR UNITED STATES FEDERAL AGENCIES

– 26 –

4. Model Scientific Integrity Policy for United States Federal Agencies

This model policy has been created as a resource for Federal agencies writing and updating their scientific

integrity policies. It is an example of what an ideal policy would look like. It contains suggested sections

and text for agencies to consider for incorporation, as applicable, into their scientific integrity policies.

Agencies may adopt it in whole or in part. The order of appearance of sections may be customized by

agencies. Text highlighted in gray contains guidance and suggestions. Agencies may customize to support

both scientific integrity and agency missions. OSTP developed critical Scientific Integrity Policy features

for assessing agency scientific integrity policies and the model demonstrates exemplary language for these

critical policy features. Additionally, there are examples that supplement this model policy in appendices

to A Framework for Federal Scientific Integrity Policy and Practice (Framework). When language is taken

from the foundational documents in Appendix C or the SI-FTAC Report, that reference is included in

parentheses at the end of the sentence. Agencies may wish to reference these documents.

Scientific Integrity Policy of [Agency]

PURPOSE ............................................................................................................................................................. 27

BACKGROUND ..................................................................................................................................................... 27

DEFINITION OF SCIENTIFIC INTEGRITY AND SCIENTIFIC INTEGRITY OFFICIAL ........................................................ 27

EFFECTIVE DATE AND POLICY AMENDMENTS ...................................................................................................... 28

APPLICABILITY & SCOPE ....................................................................................................................................... 28

AUTHORITIES ....................................................................................................................................................... 28

EXCEPTIONS ......................................................................................................................................................... 29

DEFINITIONS ........................................................................................................................................................ 29

PRINCIPLES/CORE VALUES ................................................................................................................................... 29

CODE OF SCIENTIFIC CONDUCT OR CODE OF ETHICS FOR SCIENTISTS .................................................................. 29

POLICY REQUIREMENTS ....................................................................................................................................... 29

PROMOTING A CULTURE OF SCIENTIFIC INTEGRITY .............................................................................................................. 29

I. Protecting Scientific Processes ......................................................................................................................... 30

II. Ensuring the Free Flow of Scientific Information ............................................................................................ 31

III. Supporting Decision Making Processes .......................................................................................................... 33

IV. Ensuring Accountability ................................................................................................................................. 34

V. Protections ...................................................................................................................................................... 34

VI. Professional Development for Government Scientists ................................................................................... 35

VII. Federal Advisory Committees (FACs) ............................................................................................................ 36

SCIENTIFIC INTEGRITY COMMITTEE/OTHER SCIENTIFIC INTEGRITY OFFICIALS ..................................................... 36

PROCEDURES ....................................................................................................................................................... 37

ROLES AND RESPONSIBILITIES.............................................................................................................................. 37

MONITORING AND EVALUATING SCIENTIFIC INTEGRITY ACTIVITIES AND OUTCOMES ......................................... 40

REPORTING ................................................................................................................................................................. 40

SCIENTIFIC INTEGRITY POLICY INTERSECTIONS WITH RELATED AND SUPPORTING POLICIES ................................ 41

RELATED POLICIES THAT CAN INTERSECT WITH SCIENTIFIC INTEGRITY ...................................................................................... 41

MODEL SCIENTIFIC INTEGRITY POLICY FOR UNITED STATES FEDERAL AGENCIES

– 27 –

Purpose

The purpose of this policy is to provide instruction to enhance and promote a continuing culture of scientific

integrity. This policy aims to ensure the integrity of all aspects of scientific activities including proposing,

conducting, reviewing, managing, communicating about science and scientific activities, and using the

results of science. This policy establishes the expectations and procedures required to maintain scientific

integrity at [AGENCY].

Background

Scientific and technological information, data, and evidence are central to the development and iterative

improvement of sound policies, and to the delivery of equitable services and programs, across every area

of the government. The 2022 NSTC Report of the SI-FTAC (2021 Task Force), Protecting the Integrity of

Government Science

, found that strong scientific integrity policies and practices bolster the ability of

Federal agencies to protect government science.

The Task Force Report summarizes recent foundational Executive branch actions on scientific integrity,

including the 2009 Presidential Memorandum

, the 2010 OSTP Memorandum

, and the 2021 Presidential

Memorandum

. The requirements of this policy are derived from these foundational actions, the collective

experience of Federal agencies, and the informed engagement of stakeholders both inside and outside of

government that were the basis of the 6

Definition of Scientific Integrity and Scientific Integrity Official

The [AGENCY] shall adopt the following Official Definition of Scientific Integrity:

Scientific integrity is the adherence to professional practices, ethical behavior, and the principles

of honesty and objectivity when conducting, managing, using the results of, and communicating

about science and scientific activities. Inclusivity, transparency, and protection from inappropriate

influence are hallmarks of scientific integrity.

While the responsibility for upholding scientific integrity lies with all of [AGENCY] and its contractors

and grantees, trainees, interns, and advisory committee members, the [AGENCY] has “designated a senior

career employee as the agency’s lead Scientific Integrity Official to oversee implementation and iterative

improvement of scientific integrity policies and processes.”

The Scientific Integrity Official shall be empowered with the independence necessary to gather and protect

information to support the review and assessment of scientific integrity concerns, as well as to ensure

implementation of corrective scientific actions and to coordinate with appropriate agency authorities to

enforce corrective and administrative actions as well as action to prevent scientific integrity concerns. The

Scientific Integrity Official, in conjunction with the Chief Science Officer, shall also advocate for

appropriate engagement of scientific leadership in decision-making.

A Report by the Scientific Integrity Fast-Track Action Committee of the National Science and Technology

Council. “Protecting the Integrity of Government Science.” January 11, 2022.

Presidential Memorandum for the Heads of Executive Departments and Agencies on Scientific Integrity. March 9,

2009. The White House.

Memorandum for the Heads of Executive Departments and Agencies on Scientific Integrity. December 17, 2010.

Office of Science and Technology Policy.

Presidential Memorandum on Restoring Trust in Government Through Scientific Integrity and Evidence-Based

Policy Making. January 27, 2021.

MODEL SCIENTIFIC INTEGRITY POLICY FOR UNITED STATES FEDERAL AGENCIES

– 28 –

Effective Date and Policy Amendments

This policy is effective when adopted. This policy shall be reviewed by [AGENCY] every 2 years.

Amendments to this policy shall be overseen by the Scientific Integrity Official and communicated to the

Director of the White House Office of Science and Technology Policy no later than 30 days after adoption.

Applicability & Scope

Scientific integrity is the responsibility of the entire [AGENCY] workforce. Covered entities who must

adhere to the requirements of this policy include all [AGENCY] employees, contractors, political

appointees, trainees, interns, and advisory committee members, when they propose, conduct, or review

science or communicate about science and scientific activities and to all levels of employees who manage

or supervise scientific activities and use scientific information in decision making.

All contractors, cooperators, partners, co-regulators, permittees, lessees, grantees, and volunteers, who

engage or assist in scientific activities are expected to uphold the principles of scientific integrity established

by this policy. Express requirements will be set forth in individual agreements, contracts, statements of

work, memoranda of understanding, etc., and/or established via issuance of a separate rule or other policy.

Authorities

Agencies may include fewer or additional authorities as needed or required by their General Counsel,

Solicitor, or other legal authority as appropriate.

Pursuant to the 2021 Presidential Memorandum on Restoring Trust in Government Through Scientific

Integrity and Evidence-Based Policymaking, and consistent with the 2009 Presidential Memorandum on

Scientific Integrity and the 2010 Memorandum from the White House Office of Science and Technology

Policy on Scientific Integrity, all Federal agencies must establish a scientific integrity policy. This policy

is established in accordance with:

1. The America COMPETES ACT, as amended

2. The Foundations for Evidenced-based Policymaking Act of 2018

3. Pub. L. No 106-554 ---The Information Quality Act of 2000

4. 67 FR 8451 --- OMB Guidelines for Ensuring and Maximizing the Quality, Objectivity,

Utility, and Integrity of Information Disseminated by Federal Agencies

5. 70 FR 2664 --- OMB Final Information Quality Bulletin for Peer Review

6. 65 FR 76260-76264 --- Federal Policy on Research Misconduct

7. Pub. L. 101-12 --- The Whistleblower Protection Act (WPA) of 1989, as amended

8. 41 USC § 4712 ---- The National Defense Authorization

9. 5 CFR § 2635 --- Standards of Ethical Conduct for Employees of the Executive Branch as

Amended

10. 5 USC Pub. L. 92–463, §1, Oct. 6, 1972, 86 Stat. 770 --- The Federal Advisory Committee

Act of 1972

11. 5 CFR 735, Employee Responsibilities and Conduct

12. 2017 Human Subjects Rule (Federal Register /Vol. 82, No. 12 /Thursday, January 19, 2017

/Rules and Regulations). Activities Deemed Not to Be Research: Public Health Surveillance

13. PPD 19 -- Protecting Whistleblowers with Access to Classified Information, 2012

14. M-20-12 --- OMB Phase 4 Implementation of the Foundations for Evidence-Based

Policymaking Act of 2018: Program Evaluation Standards and Practices

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Exceptions

Agencies should consult their General Counsel, Solicitor, or other legal authority as appropriate regarding

including specific content for this section.

This policy shall be implemented consistent with applicable law.

Definitions

Agencies should include the main SI definition below, and are encouraged to add a customized list of

additional definitions for inclusion in their policies as appropriate to their mission and scope. Agencies

should use previously published Federal definitions when available. A list of possible definitions to include

can be found in Appendix A of the Framework.

Scientific integrity is the adherence to professional practices, ethical behavior, and the principles

of honesty and objectivity when conducting, managing, using the results of, and communicating

about science and scientific activities. Inclusivity, transparency, and protection from inappropriate

influence are hallmarks of scientific integrity.

Principles/Core Values

Many agencies have found it beneficial to reaffirm their core scientific integrity values and principles in a

separate section of their policies.

Code of Scientific Conduct or Code of Ethics for Scientists

Agencies are encouraged to consider developing Codes of Scientific Conduct or Ethics within or alongside

their policies to establish clear expectations for behavior that is consistent with principles of scientific

integrity. A code bridges policy language with more relatable tasks and can reinforce a policy by defining

the accepted practices/standards of the relevant research or scientific community. Additionally, the

Standards of Ethical Conduct for Employees of the Executive Branch 5 CFR 2635 et seq (page 5) apply to

every Federal employee. Content from these standards as well as examples of existing codes are included

in Appendix B of the Framework.

Policy Requirements

Examples of agency scientific integrity policies and supporting policy requirements can be found in the

Framework Appendix B: Examples of Agency Scientific Integrity Policies, Procedures, and Related

Materials.

Promoting a Culture of Scientific Integrity

[AGENCY] leadership at all levels shall recognize, support, and promote this policy and its underlying

principles, as well as model behavior exemplary of a strong culture of scientific integrity.

[AGENCY] shall promote a culture of scientific integrity. This means both creating an empowering

environment that is conducive to innovation and progress and also protecting scientists and the process of

science. “Science, and public trust in science, thrives in an environment that shields scientific data and

analyses and their use in policymaking from political interference or inappropriate influence”.

Scientific

findings and products must not be suppressed, delayed, or altered for political purposes and must not be

subjected to inappropriate influence.

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A strong culture of scientific integrity begins with ensuring a professional environment that is safe,

equitable, and inclusive. Issues of diversity, equity, inclusion and accessibility are an integral component

of the entire scientific process and attention to these issues can improve the representativeness and eminence

of the scientific workforce, foster innovation in the conduct and use of science, and provide for more

equitable participation in science by diverse communities. The responsible and ethical conduct of research

and other scientific activities requires an environment that is equitable, inclusive, safe, and free from

harassment and discrimination.

To instill and enhance a culture of scientific integrity, [AGENCY] will post this policy prominently on its

website and take other measures such as agency townhalls, written and oral communications, as possible

and appropriate to keep scientific integrity visible at [AGENCY], educate all Agency employees and other

covered entities, as well as contractors who perform scientific activities for [AGENCY], on their rights and

responsibilities related to scientific integrity. 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. [AGENCY] will also provide training for

those who propose, review, conduct, manage, and use the results of and communicate about science and

scientific activities biannually. Training will be tracked to ensure covered entities have received appropriate

training.

[AGENCY] shall ensure that different modes of science, such as citizen science, community-engaged

research, participatory science, and crowdsourcing, have the recognition, support, and resources to meet

the same high standards of scientific integrity that traditional modes are expected to uphold. Further,

scientific integrity practices must be applied in ways that are inclusive of these modes of science. This may

require expanded scientific integrity practices and expectations, such as granting communities more

autonomy over research questions and research design, recognition of data and knowledge sovereignty, and

inclusion of multiple forms of evidence, such as Indigenous Knowledge.

To promote scientific integrity at [AGENCY], this policy outlines seven specific areas:

I. Protecting Scientific Processes

II. Ensuring the Free Flow of Scientific Information

III. Supporting Decision Making Processes

IV. Ensuring Accountability

V. Protecting Scientists

VI. Professional Development for Government Scientists, and

VII. Federal Advisory Committees

I. Protecting Scientific Processes

Scientific Integrity fosters “honest scientific investigation, open discussion, refined understanding, and a

firm commitment to evidence”.

It also enables consideration and documentation of differing scientific

opinions, and includes peer review. Science, and public trust in science, thrives in an environment that

shields scientific data and analyses and their use in policymaking from political interference or

inappropriate influence.

It is the policy of this agency to:

1. Prohibit 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.

2. Prohibit inappropriate restrictions on resources and capacity that limit and reduce the availability of

science and scientific products outside of normal budgetary or priority-setting processes or without

scientific justification.

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3. Require that leadership and management ensure that employees and other covered entities engaged

in scientific activities are able to conduct their work free from reprisal or concern for reprisal.

4. Require reasonable efforts by all employees and other covered entities to ensure the accuracy of the

scientific record and to correct identified inaccuracies that pertain to their contribution to any

scientific records.

5. Require that all employees and other covered entities represent their contributions to scientific work

fairly and accurately and neither accept nor assume unauthorized and/or unwarranted credit for

another's accomplishments. To be named as an author, contributors shall have made a substantial

intellectual contribution, written or provided editorial revisions that include critical intellectual

content, and approved the final version and agreed to be accountable for all aspects of the work.

6. Ensure independent review of scientific facilities, methodologies, and other scientific activities as

appropriate to ensure scientific integrity.

7. Require that employees and other covered entities comply with agency policies and procedures for

planning and conducting scientific activities and show appropriate diligence toward protecting and

conserving Federal research resources, such as equipment and other property, and records of data

and results that are entrusted to them.

8. Prohibit research misconduct and the use of improper methods or inappropriate methods or

processes in conducting research and lack of adherence to practices that ensure the quality of

research and other scientific activities such as quality assurance systems.

9. Require that all employees and other covered entities design, conduct, manage, evaluate, and report

scientific research and other scientific activities honestly and thoroughly, and disclose any conflicts

of interest to their supervisor or other appropriate agency official(s) for their determination as to

whether a recusal, disclaimer, or other appropriate notification would be appropriate.

10. Require that research involving the participation of human subjects and the use of non-human

animals is conducted in accordance with applicable, established laws, regulations and ethical

considerations.

11. Ensure recognition and prompt action to address and prevent scientific integrity policy violations

that have been shown to have a disproportional impact on underrepresented groups or weaken the

equitable delivery of Federal Government programs.

II. Ensuring the Free Flow of Scientific Information

For additional information see the Scientific Integrity Policy Intersections with Related and Supporting

Policies: Integrity in Public Science Communications.

Open and timely communication of [AGENCY] science plays a valuable role in building public trust and

understanding of [AGENCY] work. [AGENCY] shall facilitate the free flow of scientific and technological

information and support scientific integrity in the communication of scientific activities, findings and

products. Scientific and technological information will be disseminated to the extent allowed by and

consistent with privacy and classification standards and responsible communication of scientific

information. It is the policy of the [AGENCY] to:

1. Facilitate the free flow of scientific and technological information, consistent with privacy and

classification standards. Consistent with Open Government requirements, [AGENCY] shall expand

and promote access to scientific and technological information by making it available freely to the

public in an online digital format.

2. Ensure that scientific findings and products are not suppressed, delayed or altered for political

purposes and are not subjected to inappropriate influence.

3. Permit, and even encourage, agency scientists to participate in communications with the media

regarding their scientific activities and areas of scientific expertise. In communicating with the

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media, scientists are strongly encouraged to seek advice from [AGENCY] trained career

communications experts.

4. Provide scientific communication training and communications support to agency scientists to

enable their ability to clearly communicate their findings, both to policy makers within their

agencies and to the public and stakeholders more broadly.

5. Ensure that mechanisms are in place to resolve disputes that arise from decisions to proceed or not

to proceed with proposed interviews or other releases of public information or related activities.

6. Ensure that the work and conclusions of agency scientists and the work and conclusions of work

funded/supported by the federal government are accurately represented in agency communications.

If documents significantly rely on a scientist’s research, identify them as an author, or represent

their scientific opinion, the scientist(s) shall be given the option to review the scientific content of

proposed documents.

7. Ensure that agency scientists may communicate their scientific activities objectively without

political interference or inappropriate influence, while at the same time complying with agency

policies and procedures for planning and conducting scientific activities, reporting scientific

findings, and reviewing and releasing scientific products. Scientific products (e.g., manuscripts for

scientific journals, presentations for workshops, conferences, and symposia) shall adhere to agency

review procedures.

8. Allow [AGENCY] employees and other covered entities to report their scientific findings and

communicate with the media or the public in their official capacities at [AGENCY]. [AGENCY]

scientists shall refrain from making or publishing statements that could be construed as being

judgments of, or recommendations on, [AGENCY] or any other Federal Government policy, unless

they have secured appropriate prior approval to do so. Such communications shall remain within

the bounds of their scientific or technological findings, unless specifically otherwise authorized.

9. Allow scientists to communicate with the media or the public in their personal capacities subject to

limitations of government ethics rules. [AGENCY] scientists may express their personal views and

opinions; however, they should not claim to officially represent the agency or its policies or use the

agency or other U.S. Government seals or logos. Employees and other covered entities shall use

appropriate written or oral disclaimers for personal activities.

10. Require that agency officials, including public affairs officers, shall not alter, nor direct agency

scientists and technology experts to alter, scientific and technological research findings.

11. Require that agency officials, including public affairs officers, shall not direct an agency scientist or

technology expert to alter a presentation of their scientific findings in a manner that would

knowingly compromise the objectivity or accurate representation of those findings, nor affect a

change in presentation without concurrence of the principle agency scientist or technology expert.

12. In response to media requests about the scientific or technological aspects of their work, agencies

will offer knowledgeable spokespersons who can, in an objective and nonpartisan fashion, describe

these dimensions (OSTP 2010). This does not include describing the policy implications of their

work. That requires a separate permission.

13. Require that technical review and clearance processes include provisions for timely clearance and

expressly forbid censorship, unreasonable delay, and suppression of objective communication of

data and results without scientific justification.

14. Ensure that scientific information is accurately represented in responses to Congressional inquiries,

testimony, and other requests.

15. Accurately represent the work and conclusions of agency scientists in agency social media

communications and that agency scientists are appropriately guided on use of social media, which

includes but is not limited to blogs, social networks, forums, and micro blogs.

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a. When communicating on social media in their personal capacities, and subject to limitations of

government ethics rules, agency social media regulations, and obligation to protect nonpublic

information, [AGENCY] scientists may express their personal views and opinions and may

name their agency, in the context of biographical information, as long as it is clear in context

that they are not speaking on behalf of, or as a representative of, the agency.

b. If employees and other covered entities choose to disclose their [AGENCY] on their personal

social media, a disclaimer clarifying that the account or communication represents personal

views may be appropriate.

c. Agencies should examine their social media rules to ensure that they are not overly restrictive.

d. Social media managers are responsible for correction of any errors pointed out by scientists

whose work is represented in [AGENCY] social media.

III. Supporting Decision Making Processes

For additional information see Scientific Integrity Policy Intersections with Related and Supporting

Policies: Credibility of the Science to Support Policy Decisions.

It is the policy of the [AGENCY] to:

1. Ensure the quality, accuracy, and transparency of scientific information used to support policy and

decision making including:

a. Use scientific information that is subject to well-established scientific processes.

b. Ensure that scientific data and research used to support policy decisions undergo review by

qualified experts, where feasible and appropriate, and consistent with law.

c. Adhere to the Office of Management and Budget Final Information Quality Bulletin for Peer

Review [and relevant AGENCY peer-review guidelines]

When independent peer reviews of

scientific products are conducted by contractors, a conflict of interest review shall be

conducted for all reviewers.

d. Reflect scientific information appropriately and accurately and ensure that it is free of

misinformation; and make scientific findings or conclusions considered or relied on in policy

decisions publicly available online and in open formats, to the extent practicable.

2. Where legally permissible and appropriate, enable scientists to directly participate in policy and

management decisions for which they are the agency subject matter expert in order to ensure that

the science is accurately represented and interpreted.

3. Ensure the accuracy of communication of the science upon which a policy decision is based.

4. Ensure that the Scientific Integrity Official, with input from the other scientific officials, develop a

transparent mechanism for Agency employees and other covered entities to express differing

scientific opinions. When an agency employee, who is substantively engaged in the science

informing an agency policy decision, disagrees with the scientific data, interpretations or

conclusions that are to be relied upon for that decision, the employee is encouraged to express that

opinion complete with rationale and in writing. If differing scientific opinions are not resolved

during internal deliberations, they can be part of peer review charge questions with the results

publicly available. When there is no peer review, the differing opinion will be represented in the

agency deliberative documents for the decision maker’s consideration.

Office of Management and Budget. “Final Information Quality Bulletin for Peer Review.” Federal Register. Doc.

05-769, January 14

, 2005

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IV. Ensuring Accountability

Examples of agency procedures for addressing scientific integrity concerns are contained in the

Appendix B of the Framework.

In consultation with [AGENCY] Office of General Counsel, it is the policy of the [AGENCY] to:

1. Ensure correction of the scientific record, the implementation of recommendations to prevent such

allegations in the future and the enforcement of administrative actions when allegations of a loss of

scientific integrity are substantiated.

2. Encourage and facilitate early informal or formal consultation with scientific integrity officials to

seek advice on preventing a situation of concern, to determine if it is a potential violation of the

Scientific Integrity Policy, and to ascertain if it should be referred elsewhere in the agency for

resolution.

3. Provide clear guidance on how to formally and confidentially report concerns and allegations of

Scientific Integrity Policy violations. Those who report concerns and allegations need not be

directly involved or witness a violation.

4. Ensure that the Scientific Integrity Official, together with the other Agency scientific integrity

officials, as applicable, drafts procedures to respond to allegations of compromised scientific

integrity in a timely, objective, and thorough manner. These procedures shall include the following

steps: an initial assessment and review, a fact-finding process, an agency adjudication or

determination including description of remedies and preventative measures to safeguard the

science, an appeals process, follow-up to track implementation of remedies, and reporting.

5. Ensure that procedures document the necessary aspects for each step of the process including

burden of proof, any necessary determination of intentionality, and reporting as well as the roles of

the Scientific Integrity Official and Agency staff in the process.

6. Ensure that subordinate agencies have Scientific Integrity policies that are consistent and in

alignment with this policy. Subordinate agencies are free to enact stronger policies than their parent

department and departments shall not inappropriately influence agency Scientific Integrity matters.

V. Protections

For additional information see Scientific Integrity Policy Intersections with Related and Supporting

Policies: Diversity, Equity, Inclusion, and Accessibility and Whistleblower Protections.

To assure the protection of government scientists and as appropriate other covered entities from retribution,

retaliation or reprisal, and in consultation with [AGENCY] Office of General Counsel, it is the policy of

[AGENCY] to:

1. Select and retain candidates for scientific and technical positions based on the candidate's scientific

and technical knowledge, credentials, experience, and integrity, and hold them and their supervisors

to the highest standards of professional and scientific ethics [including those described in the Code

of Scientific Ethics/Conduct if one exists].

2. Promote diversity, equity, inclusion, and accessibility in the scientific workforce and to create safe

workspaces that are free from harassment and discrimination. Support scientists and researchers

including, but not limited to, Black, Latino, and Indigenous and Native American persons, Asian

Americans and Pacific Islanders and other persons of color; members of religious minorities;

lesbian, gay, bisexual, transgender, and queer (LGBTQI+) persons; persons with disabilities;

persons who live in rural areas; and persons otherwise adversely affected by persistent poverty or

inequality; and advance the equitable delivery of Federal programs.

3. Protect those individuals who report allegations of compromised scientific integrity in good faith,

as well as those agency employees and other covered entities alleged to have compromised

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scientific integrity in the absence of a finding that the individual compromised scientific integrity,

from prohibited personnel practices (as defined in 5 USC 2302(b)).

4. Prevent supervisors [and managers] or other agency leadership from intimidating or coercing

scientists to alter scientific data, findings, or professional opinions or inappropriately influencing

scientific advisory boards.

5. Comply with whistleblower protections, specifically:

a. By protecting employees from prohibited personnel practices (as defined in 5 U.S.C. 2302(b)),

especially those who uncover and report allegations of loss of scientific integrity in good faith,

as well as those [AGENCY] employees alleged to have compromised scientific integrity in the

absence of a finding that the individual compromised scientific integrity;

b. The requirements of the Whistleblower Protection Act of 1989, and its expanded protections

enacted by PL 103-424 and the Whistleblower Protection Enhancement Act of 2012;

c. The National Defense Authorization Act’s expansion of certain whistleblower protections to

employees of federal government contractors, subcontractors, and grant recipients. 41 USC

4712; and,

d. Presidential Policy Directive 19, which prohibits supervisors from taking, failing to take, or

threatening to take or fail to take any action affecting an employee’s eligibility for access to

classified information in reprisal for making a protected disclosure.

VI. Professional Development for Government Scientists

For additional information see Scientific Integrity Policy Intersections with Related and Supporting

Policies: Professional Development and Advancement of Scientists.

It is the policy of the agency to encourage agency scientists and other agency employees and covered

entities involved in agency scientific activities to interact with the broader scientific community, in a

manner that is consistent with Federal rules of ethics, job responsibilities, and to the extent that is practicable

given the availability of funding to support such interactions and any budgetary restraints. This includes:

1. Encouraging timely publication of research such as in peer-reviewed, professional, scholarly

journals, [AGENCY] technical reports and publications or other appropriate outlets;

2. Encouraging the sharing of scientific activities, findings, and materials through appropriate avenues

including on digital repositories;

3. Encouraging attendance and presentation of research at professional meetings including workshops,

conferences and symposia;

4. Permitting service on editorial boards, as peer reviewers, or as editors of professional or scholarly

journals;

5. Permitting participation in professional societies, committees, task forces, and other specialized

bodies of professional societies, including removing barriers to serving as officers or on governing

boards of such societies, to the extent allowed by law;

6. Permitting government scientists to receive honors and awards for contributions to scientific

activities and discoveries to the extent allowed by law, and to accrue the professional recognition of

such honors or awards; and

7. Permitting scientists to perform outreach and engagement activities, such as speaking to community

and student groups, as part of their official duties.

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VII. Federal Advisory Committees (FACs)

This section may not be applicable – not all agencies have FACs.

Federal Advisory Committees are an important tool within [AGENCY] for ensuring the credibility, quality,

and transparency of agency science. [AGENCY] shall adhere to the Federal Advisory Committee Act and

develop policies, in coordination with the General Services Administration and consistent with the guidance

on lobbyists serving on Federal advisory committees (FACs), for convening FACs tasked with giving

scientific advice, consistent with the following:

1. “The recruitment process for new FAC members should be as transparent as practicable.

[AGENCY] should, when practicable and appropriate, announce FAC member vacancies widely,

including notification in the Federal Register with an invitation for the public to recommend

individuals for consideration and for self-nominations to be submitted.”

2. “Professional biographical information (including current and past professional affiliations) for

appointed committee members should be made widely available to the public (e.g., via a website)

subject to Privacy Act and other statutory/regulatory considerations. Such information should

clearly illustrate the individuals' qualifications for serving on the committee.”

3. “The selection of members to serve on a scientific or technical FAC should be based on expertise,

knowledge, and contribution to the relevant subject area. Additional factors that may be considered

are availability of the member to serve, diversity among members of the FAC, and the ability to

work effectively on advisory committees. Committee membership should be fairly balanced in

terms of points of view represented with respect to the functions to be performed by the FAC.”

The

selection process should be overseen by career [AGENCY] officials.

4. Except when prohibited by law, [AGENCY] should make all COI waivers granted to committee

members publicly available.

5. Whenever possible, [AGENCY] should engage members of scientific and technical FACs as

Special Government Employees to further transparency goals.

6. Except when explicitly stated in a prior agreement between [AGENCY] and a FAC, all reports,

recommendations, and products produced by FACs should be treated as solely the findings of such

committees rather than of the U.S. Government, and thus are not subject to intra- or inter-agency

revision.

7. [AGENCY] must comply with current standards governing conflict of interest as defined in statutes

and implementing regulations.

Scientific Integrity Committee/Other Scientific Integrity Officials

[AGENCY] shall establish a Scientific Integrity Committee comprised of senior Agency career employees

and chaired by the Scientific Integrity Official to provide oversight for the implementation of the Scientific

Integrity Policy at [AGENCY], act as liaisons for their respective Agency units, assist with training and

policy assessment, updates and amendments, and to be available to address any questions or concerns

regarding this policy. The Scientific Integrity Official together with the Committee will draft a Scientific

Integrity Committee Charter outlining criteria for selection as a member, other duties of members, and the

frequency of meetings.

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Procedures

Agencies are encouraged to use this header to enumerate and briefly describe any agency policies

through which their Scientific Integrity Policy is implemented. These may include already extant policies

and ones to be written. For those to be written we suggest agencies lay out a time-line for their

completion as well as a summary of what they will contain. Alternatively, many agencies have scientific

integrity handbooks that include these important details for full implementation of their Policies.

Examples of agency procedures for addressing scientific integrity concerns are contained in the Appendix

B of the Framework.

The Scientific Integrity Official in conjunction with other [AGENCY] career officials shall expeditiously

draft and prominently post on [AGENCY’s] website the following procedures: addressing scientific

integrity concerns, handling differing scientific opinions, clearance of scientific products, scientific

communications, authorship and attribution and other topics as needed. These policies shall be completed

within one year of the release of this policy.

Roles and Responsibilities

Agencies may modify the position titles but should retain the positions as applicable and outline roles and

responsibilities with enough detail to provide clarity. It may be appropriate to include additional role

descriptions and/or modify text to align with individual agency structures and roles on scientific integrity.

Agencies may want to consider including a description of the circumstances under which the Scientific

Integrity Official and other scientific integrity points of contact may be removed from these roles.

Scientific Integrity is everyone’s responsibility and the following have specific scientific integrity roles and

responsibilities:

I. [Agency Head]

1. Provides leadership for the agency on scientific integrity such as leading through example,

upholding scientific integrity principles and regularly communicating the importance of scientific

integrity.

2. Ensures that all agency activities associated with scientific and technological processes are

conducted in accordance with the policy

3. Ensures all supervisors and managers comply with the scientific integrity policy and ensure

accountability for those who do not.

4. Violations of scientific integrity policies shall be taken as seriously as violations of government

ethics rules and must come with appropriate consequences.

5. [Designates a senior agency employee with agency-appropriate qualifications and scientific

credentials for the role of chief science officer, science advisor, or chief scientist (‘‘Chief Science

Officer’’) as applicable and support their role as advisor on scientific issues.]

6. Ensures that the scientific-integrity policy considers, supplements, and supports agency plans for

forming evidence-based policies, including the evidence-building plans required by 5 U.S.C. 312(a)

and the annual evaluation plans required by 5 U.S.C. 312(b).

7. Provides adequate resources and funding to implement this policy including staffing, monitoring,

evaluation, and reporting, and training.

8. Supports and respects the scientific integrity official’s independence, recommendations and

designation of and agency compliance with corrective scientific actions when violations of this

policy are substantiated.

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II. Chief Scientist/Chief Science Officer [Agency Head if the appointment of a chief scientist/chief

science officer is not required.]

1. Serves as the principal advisor to the head of the agency on scientific issues and ensures that the

agency’s research programs are scientifically and technologically well-founded and conducted with

integrity.

2. In cooperation with the Scientific Integrity Official, oversees the implementation and iterative

improvement of policies and processes affecting the integrity of research funded, conducted, or

overseen by the agency, as well as policies affecting the Federal and non-Federal scientists who

support the research activities of the agency, including scientific-integrity policies.

3. Supports the scientific integrity official’s designation of and agency compliance with corrective

scientific actions when violations of this policy are substantiated. Assistance may be sought from

the National Science and Technology Council Subcommittee on Scientific Integrity in cases of

disagreement.

4. Ensures agencies establish as necessary clear administrative actions for substantiated violations of

scientific integrity policies, designating responsibility for each aspect of accountability.

III. Scientific Integrity Official

1. Is a designated, full-time equivalent, career employee who has agency appropriate scientific

credentials and is appointed at a senior level, for example as an ST (scientific or professional),

Senior Leader (SL), or in the Senior Executive Service (SES).

2. Oversees implementation and iterative improvement of scientific-integrity policies and processes

providing leadership, acting to champion scientific integrity, and serving as the primary Agency-

level contact for questions regarding Scientific Integrity and ensuring scientific integrity activities

and outcomes are appropriately monitored and evaluated.

3. Leads training and outreach initiatives to facilitate employee awareness and understanding of this

policy.

4. Serves as a neutral point of contact for receiving scientific integrity questions and concerns and

allegations of compromised scientific integrity.

5. Conducts an initial assessment of allegations and submitted materials, following established

procedures, to determine whether the allegations pertain to compromised scientific integrity and the

appropriate handling of said allegations. Provides independent oversight of agency responses to

allegations of compromised scientific integrity referred for an inquiry or investigation, including:

a. Reviewing agency-submitted reports of allegations and their disposition; and

b. Maintaining a status report of responses to allegations as a means of monitoring the progress

toward resolution.

6. Leads efforts to update this policy and any accompanying guidance, as appropriate.

7. Reports to the [Chief Science Officer] or similarly placed individual with an appropriate

background] on matters involving scientific integrity.

8. Coordinates with the [Office of the General Counsel (OGC), Office of Inspector General (OIG), the

Office of Ethics, the Office of Human Resources Management, Office of Communications, the

Office of the Chief Information Officer], and other offices, as necessary.

9. Reports any potentially criminal behavior related to waste, fraud or abuse to OIG that is uncovered

during the course of responding to an allegation of compromised scientific integrity and coordinate

as appropriate related to the referral provided to OIG.

10. Keeps the [Chief Science Officer and] the Agency Head informed on the status of the

implementation of this policy and any compliance concerns, as warranted.

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11. Delegates responsibilities to other scientific integrity officials exercising a purview applicable to

organizational submits (e.g., offices, bureaus, directorates) of the agency, and chairs their regular

meetings.

12. Publishes an annual scientific integrity report as described below.

13. Leads efforts for the iterative improvement of this policy and scientific integrity initiatives overall

including development and implementation of an evaluation plan to regularly monitor and evaluate

ongoing scientific integrity activities and outcomes.

14. To the extent possible, be involved in high level discussions and strategic planning on the

recruitment, retention, development, and advancement of scientists—especially scientists from

underrepresented communities—to help ensure that scientific integrity is appropriately and

carefully considered.

IV. Scientific Integrity Committee

1. As delegated by the Scientific Integrity Official, oversee implementation and iterative improvement

of scientific integrity policies and processes.

2. Coordinate with the agency’s Scientific Integrity Official in implementing the agency’s scientific-

integrity policies and processes.

3. Provide oversight for the implementation of the Scientific Integrity Policy at [AGENCY].

4. Act as liaisons for their respective Agency units.

5. Assist with training and policy assessment, updates and amendments.

6. Be available to address any questions or concerns regarding this policy.

7. Other duties as delegated.

V. Managers and Supervisors

1. Comply with and ensure agency and employee compliance with the scientific integrity policy and

to listen, advise, and report allegations of compromised scientific integrity and take action as

appropriate.

2. Be aware of and uphold the principles contained in this policy [and the Scientific Code of Conduct].

Lead through example by upholding scientific integrity principles and communicating the

importance of doing so.

3. Report any knowledge of potential losses of scientific integrity to the Scientific Integrity Official or

other scientific integrity officials.

4. Refrain from committing prohibited personnel practices (as defined in 5 U.S.C. 2302(b)) against all

agency employees and other covered entities including those who uncover and report allegations of

compromised scientific integrity in good faith, as well as those agency employees alleged to have

compromised scientific integrity.

5. Consult, as appropriate depending upon the nature of the allegation, with the Scientific Integrity

Official, human resources officer, contracting and grant personnel, ethics officer, [OIG, OGC, and

the Office of Civil Rights].

VI. Employees and other covered entities

1. Should be aware of the principles contained in this policy [including the Code of Conduct] and how

the policy applies to their duties.

2. Comply with this policy.

3. [Abide by the Code of Conduct, and] adhere to accepted professional values and practices of the

relevant research/scientific communities so as to ensure scientific integrity;

4. Are encouraged to report to the Scientific Integrity Official or any Deputy Scientific Integrity

Official any knowledge of compromised scientific integrity

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Monitoring and Evaluating Scientific Integrity Activities and Outcomes

[AGENCY] will develop and implement an evaluation plan to regularly measure, monitor, and evaluate

ongoing scientific integrity activities and outcomes. The plan will include a roadmap of activities and

expected outcomes, the steps and methods needed to assess the processes and outcomes, the methods and

metrics used to evaluate the activities and outcomes, and how the data will be analyzed on a regular basis

and used for ongoing improvement of SI processes, procedures, and policies. The plan shall include, at a

minimum, the metrics for agencies to collect and report as identified in Chapter 2, subpart Metrics and

Measurement Methods for Scientific Integrity Activities and Outcomes and Chapter 3: Critical Metrics for

Regular Assessment and Iterative Improvement of Agency Scientific Integrity Policy Implementation.

The plan shall also include a timeline for implementation and frequency of data collection, analysis, review,

recommendations, and implementing recommendations. Monitoring and evaluation results,

recommendations, and policy/procedure changes based on results will be reported to agency leadership and

will be made available to agency staff and the public in a timely manner.

Reporting

This report is from the Scientific Integrity Official [and other scientific integrity points of contact] to

leadership and hence should not be edited by that leadership before release. Agencies are encouraged to

track informal queries and report summary statistics including date and topic.

Annual Reporting. The Scientific Integrity Official [with input from the Scientific Integrity Committee]

is responsible for generating and making prominently available on the agency’s public facing website an

annual report to the [AGENCY] leadership on the status of scientific integrity within [AGENCY], per the

January 27, 2021, Presidential Memorandum. The report shall highlight scientific integrity successes,

accomplishments, or progress across [AGENCY] such as any new scientific integrity hires, training,

enhancements to scientific integrity policies, etc.), identify areas for improvement and develop a plan for

addressing critical weaknesses, if any. It shall report on progress toward achieving the critical metrics

identified in Chapters 2 and 3, including comparisons to the same metrics from prior years to show trends

over time, whenever feasible. It will also include the number of formal administrative investigations,

informal requests for assistance, inquiries and appeals involving alleged or actual deviations from the

scientific integrity policy and the number of investigations and pending appeals. Annual Reporting will also

include anonymized individual closed scientific integrity case summaries. These summaries may be posted

in a timely manner after completion of inquiries and/or incorporated into the annual report. The identities

of complainants, respondents, witnesses and others involved in the investigations shall be protected.

The metrics may be collected every other year.

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Scientific Integrity Policy Intersections with Related and Supporting Policies

Involving Scientific Integrity Officials in the writing and updating of related policies can help provide

needed perspectives before such policies are issued and better ensure they support scientific integrity.

Officials should consider the scientific integrity-related components of other policies (e.g., professional

development of scientists, science-related communications, etc.) and determine where those other policies

should be referenced, or perhaps reinforced, within the agency scientific integrity policy to help ensure their

longevity. Violations of related and supporting policies may result in a loss of scientific integrity and it is

appropriate for scientific integrity officials to coordinate with their agency counterparts in these matters.

Scientific integrity officials should have an awareness of policies and programs that intersect with the

development of the culture of scientific integrity within the agency. Scientific Integrity officials, where

possible, shall be involved in the development or revision of the broader set of policies and practices that

affect the culture and applicability of scientific integrity within [Agency].

Related Policies that Can Intersect with Scientific Integrity

Diversity, Equity, Inclusion, and Accessibility (DEIA) in Addressing and Strengthening Scientific

Integrity and the Disproportional Impact of Scientific Integrity Policy Violations on

Underrepresented Groups. Policies, practices, and agency culture to promote diversity, equity, inclusion,

and accessibility in the scientific workforce and Federal workforce at large and to create safe workspaces

that are free from harassment and discrimination are foundational for achieving a culture of scientific

integrity. Because of existing power structures, racism, sexism, discrimination and other forms of bias in

the workplace, scientific integrity and DEIA policies may intersect in many places. Similarly, scientific

integrity entails greater transparency into research processes and policy-making outcomes. The agency will

review and address potential scientific integrity policy violations that have a disproportionate impact on

underrepresented groups or weaken the equitable delivery of agency programs.

Public Access. Policies and practices that help to ensure that publications, data, and other outputs of

government-funded research are equitably and publicly available to other researchers, innovators, students,

and the broader public, including underserved communities, consistent with the 2022 OSTP Memorandum

on Ensuring Free, Immediate, and Equitable Access to Federally Funded Research.

Human and Animal Subject Protections. For the protection of human subjects of research and clinical

investigations, requirements for Federal departments or agencies (conducting or supporting) as applicable,

are provided in the Federal Policy for Protection of Human Research Subjects (the Common Rule) outlined

in 45 C.F.R. §§ 46.101-46.124 and the FDA Policy for the Protection of Human Subjects outlined in 21

C.F.R. §§ 50, 56, 312 and 812.

To protect the welfare of animals used in research or other activities conducted or supported by federal

departments or agencies, compliance with the Federal regulations and policies governing animal care and

use is required, including regulated species under the United States Department of Agriculture Animal

Welfare Act (AWA) and regulations (AWAR), the Public Health Service Policy on Humane Care and Use

of Laboratory Animals (PHS Policy) administered by the National Institutes of Health, Office of Laboratory

Animal Welfare and the Guide for the Care and Use of Laboratory Animals.

Scientific Integrity with Research Security. Scientists are encouraged to interact with the broader

scientific community as well as to engage with collaborators with a commitment to a shared research

environment of openness, transparency, honesty, equity, fair competition, objectivity, and democratic

values. However, some foreign governments are working vigorously in contradiction with these values to

acquire, through both licit and illicit means, U.S. research and technology. Research security policies, such

as the National Security Presidential Memorandum 33 (NSPM-33) and subsequent Guidance for

Implementing NSPM-33, must harmonize with scientific integrity policies by both guarding against foreign

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abuses and protecting intellectual property rights, while ensuring the scientists maintain honesty,

objectivity, transparency, and professional and ethical behaviors.

Foundations for Evidence-Based Policymaking Act (“Evidence Act”). Scientific integrity is a

foundational component of Federal policies and data infrastructure investments supporting information

quality, access, protection, and evidence building and use. The Evidence Act, also anchored in scientific

integrity, called on agencies to strategically plan and organize evidence building, data management, and

data access functions to ensure an integrated and direct connection to data and evidence needs. Title II of

the Act – the OPEN Government Data Act - requires federal agencies to make public data assets available

online, using open standards, machine-readable, open formats, and without restrictions (other than

intellectual property rights) that would impede use. The metadata associated with open government data

assets is made available through the Federal Data Catalogue at data.gov. Title III – the Confidential

Information Protection and Statistical Efficiency Act (CIPSEA) of 2018 - requires agencies to enable

statistical agencies to uphold their fundamental responsibilities to provide timely, relevant, credible, and

objective data and statistics and to maintain public trust. Agencies should consult OMB’s implementing

guidance, (including OMB M-19-23, OMB M-20-12, and OMB M-21-27, and Statistical Policy Directive

1) to ensure that scientific integrity policies and procedures complement and reinforce related requirements

of the Evidence Act. Agency Learning Agendas and Annual Evaluation Plans, required by the Evidence

Act, are posted on agency websites and linked at Evaluation.gov.

Notification and Federal Employee Antidiscrimination and Retaliation Act (“No FEAR Act”). Federal

agencies are required to be held accountable for violations of antidiscrimination and whistleblower

protection laws. Under the No FEAR Act, agencies must pay for settlements, awards or judgments against

them in whistleblower and discrimination cases out of their own budgets.

Dual Use Research of Concern. The United States Policy for Oversight of Life Sciences Dual Use

Research of Concern stipulates that additional review is required for scientific research that could be

directly misapplied to pose a significant threat with broad potential consequences to public health and

safety, agricultural crops and other plants, animals, the environment, materiel, or national security.

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5. Critical Policy Features for Assessment of Scientific Integrity Policies

In accordance with the 2021 Presidential Memorandum, agency scientific integrity policies will be

periodically assessed by OSTP, through the NSTC Subcommittee on Scientific Integrity. The following

critical policy features were derived from the Model Scientific Integrity Policy (Chapter 4), which adheres

to the principles of the 2009 Presidential Memorandum, 2010 OSTP Memorandum, 2021 Presidential

Memorandum, and 2022 Task Force Report, and will form the basis of that assessment. All agencies’

Scientific Integrity Policies will be assessed by OSTP in 2022 and again on a rolling-basis as new agency

policies are developed and established agency policies are updated.

Table 7 provides critical policy features aligned to components of the Model Policy. The critical policy

features that agencies should include in their scientific integrity policies are listed in the first column, titled

“Critical Policy Features for Assessment.” The second column, titled “Model Policy Component”, lists the

corresponding sections within the Model Scientific Integrity Policy (Chapter 4) that agencies can reference

for exemplary language that would meet the corresponding criteria.

While OSTP does not necessarily expect agencies to use the exact text of the Model Scientific Integrity

Policy components in their own policies, agencies can look to the Model Policy language in the right column

of Table 7 for an example of the level of detail, scope, and outcomes that OSTP and the NSTC

Subcommittee on Scientific Integrity will be looking for in their assessment. Therefore, agencies are

encouraged to adapt their scientific integrity policies with the critical policy features in mind, using the

model policy as a guide. A potential use of Table 7 is as a tool for agencies to map the critical policy features

We suggest agencies might replace the Model Policy Component column with relevant text or explanation

from their policy. Specific feedback resulting from this assessment will be provide to agencies by OSTP

and the NSTC Subcommittee on Scientific Integrity.

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Table 7. Critical Policy Features for Assessment of Scientific Integrity Policy with

Model Scientific Policy Components

Critical Policy Features for Assessment

Model Policy Component

Policy includes sections and structure equivalent to the

Model Scientific Integrity Policy for United States

Federal Agencies, as appropriate for agency mission,

structure, and function.

Table of Contents

Agency policy includes the Federal Definition of

Scientific Integrity.

Definition of Scientific Integrity

Detailed list of categories of covered entities to include

all those who conduct, manage, design, evaluate,

communicate, or use science to support policy and

decision making.

Applicability & Scope

List of agency-specific and general authorities of the

policy is included.

Authorities

The policy addresses, as appropriate, the following

seven major areas or equivalent: Protecting Scientific

Processes, Ensuring the Free Flow of Scientific

Information, Supporting Decision Making Processes,

Ensuring Accountability, Protections, Professional

Development for Government Scientists, and Federal

Advisory Committees (FACs).

Policy Requirements

Policy is prominently and publicly available and

accessible on agency website.

Promoting a Culture of Scientific Integrity

Policy articulates scientific integrity training

requirements and cadence.

Promoting a Culture of Scientific Integrity

Policy prohibits political interference and inappropriate

influence with agency science and scientific activities.

Protecting Scientific Processes

Policy prohibits research misconduct.

Protecting Scientific Processes

Policy requires that those agencies who assign

authorship to agency scientific products require that

Protecting Scientific Processes

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scientists’ contributions are represented fairly and

accurately.

Policy ensures the free flow of scientific information

and activities, including ensuring that scientists’ work

and conclusions are accurately represented in agency

communications, including permitting scientists to

communicate scientific information on social media

platforms.

Ensuring the Free Flow of Scientific Information

Policy ensures that science is accurately represented in

agency communications. Scientists shall be given the

option to review the scientific content of proposed

agency communications that rely on their research,

identify them as an author, or represent their scientific

opinion.

Ensuring the Free Flow of Scientific Information

Policy prohibits the agency from inappropriately

influencing scientist communication with the media

and public, including by unreasonably delaying the

release of scientific information.

Ensuring the Free Flow of Scientific Information

Policy prohibits the suppression, delay or alteration of

scientific products and findings for political purposes

or due to inappropriate influence.

Ensuring the Free Flow of Scientific Information

Policy requires that scientific information is accurately

represented in Congressional inquiries, testimony, and

other requests.

Ensuring the Free Flow of Scientific Information

Policy ensures use of appropriate peer review.

Supporting Decision Making Processes

Policy ensures scientists may express differing

scientific opinions.

Supporting Decision Making Processes

Policy describes allegation reporting and adjudication

processes, including consultation with SIO.

Ensuring Accountability

Policy recognizes that diversity, equity, inclusion and

accessibility in the scientific workforce intersects with

scientific integrity.

Protections

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Policy ensures protections for whistleblowers and

individuals reporting allegations of losses of scientific

integrity including research misconduct.

Protections

Policy requires agencies select and retain candidates

for scientific and technical positions based on the

candidate’s scientific and technical knowledge,

credentials, experience, and integrity.

Protections

Policy encourages agency scientists and other covered

entities involved in agency scientific activities to

interact with the broader scientific community in a

manner that is consistent with Federal rules of ethics

and job responsibilities.

Professional Development for Government Scientists

Policy includes guidance for Federal science advisory

committees.

Federal Advisory Committees

The roles and responsibilities of the Scientific Integrity

Official and other agency scientific integrity staff are

clearly defined in the policy.

Roles and Responsibilities

Policy requires regular public reporting on agency

scientific integrity activities, to include the number of

investigations and appeals involving alleged deviations

from the SI policy.

Reporting

Policy describes intersections with other, related

agency policies and procedures.

Related Policies that Can Intersect with Scientific

Integrity, Procedures

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6. Appendices

Appendix A: Definitions for Possible Inclusion in Agency Scientific Integrity

Policies

This list of definitions is meant to be illustrative, but not exhaustive, of terms that might appear in agency

scientific integrity policies and procedures. With the exception of the definitions of Research Misconduct

and Scientific Integrity, these definitions are examples and are pliable for agency specific use.

Allegation refers to a formal accusation of a suspected loss of scientific integrity.

Administrative Record refers to the set of non-deliberative documents that the decision-maker

considered, directly or indirectly, in making a final decision. The record should include all the factual,

technical, and scientific material or data considered in making the decision, whether or not those

materials or data support the decision.

Conduct of Science refers to the formulation of hypotheses, study design, testing, data collection,

systematic review, statistical analysis, interpretation, findings, conclusions, and peer review.

Covered entities refers to those persons who must adhere to the requirements of [AGENCY] policy

include all [AGENCY] employees, contractors, political appointees, trainees, interns, and advisory

committee members, when they propose, conduct, or review science or communicate about science and

scientific activities and to all levels of employees who manage or supervise scientific activities and use

scientific information in decision making.

Decision-making/policymaking refers to the (1) development of policies or making determinations

about policy or management; (2) making determinations about expenditures of Federal agency funds;

(3) implementing or managing activities that involve, or rely on, scientific activities.

Ethical behavior refers to activities that reflect norms for conduct that distinguish between acceptable

and unacceptable behavior, such as honesty, lawfulness, equity, and professionalism.

Federal agency refers to an Executive department, a Government corporation, and an independent

establishment.

Federal science refers to science conducted by Federal scientists.

Federal science agency refers to a Federal agency that conducts intramural research and/or funds

extramural research activities.

Federal scientist refers to a scientist who is a Federal employee or Federal contractor.

Inclusivity refers to the practice of intentionally ensuring full participation of all people and all groups,

including marginalized, underserved, and underrepresented contributors, without bias or prejudice. Full

participation is enabled through equitable access and fair treatment in the organization. Inclusivity also

means asking questions and conducting scientific activities that serve diverse constituencies and

This definition is consistent with that used in the Report “Protecting the Integrity of Government Science,” and

was adapted from the definition of “Decision-makers” in NOAA’s scientific integrity policy.

5 USC § 105

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contribute to the equitable delivery of Government services. For example, in the context of human

subjects research, full participation happens when researchers, oversight committees and human

subjects themselves have equal access and treatment in research studies, no matter what their role.

Inclusivity happens when the perspectives of those persons who are studied are taken into account.

Particularly in situations when human subjects may come from marginalized, underserved or

underrepresented populations, their voices should be heard to deflect any concerns about exploitation or

unfairness.

Inappropriate influence refers to the attempt to shape or interfere in scientific activities or the

communication about or use of scientific activities or findings against well-accepted scientific methods

and theories or without scientific justification.

14,15

Interference refers to inappropriate, scientifically unjustified intervention in the conduct, management,

communication, or use of science. It includes censorship, suppression, or distortion of scientific or

technological findings, data, information, or conclusions; inhibiting scientific independence during

clearance and review; scientifically unjustified intervention in research and data collection; and

inappropriate engagement or participation in peer review processes or on Federal advisory committees.

Loss of Scientific Integrity refers to the failure to comply with the Scientific Integrity Policy or to

adhere to the principles of honesty, objectivity, and transparency; professional practices; and ethical

behavior when conducting, managing, using the results of, and communicating about science and

scientific activities.

Misinformation refers to incorrect, misleading, or misattributed information.

Objectivity refers to the quality of being explicit, unbiased, honest, and impartial.

Policy refers to laws, regulations, procedures, administrative actions, incentives, or voluntary practices

of governments and other institutions.

Political interference refers to interference conducted by political officials and/or motivated by

political considerations.

Professional Practices refers to conducting oneself with the qualities that are characterized by skill,

competence, ethics, and courtesy.

Examples may include 1) suppressing a decisionmaker’s ability to offer the best judgment based on scientific

information; 2) preventing the use of best available science; 3) insisting on preclearance of a scientific product for

purposes other than providing advance notification or opportunity to review for technical merit; 4) suppressing,

altering or delaying the release of a scientific product for any reason other than technical merit or providing advance

notification; 5) removing or reassigning scientific personnel for the purposes of undermining the science; 6) using

scientific products that are not representative of the current state of scientific knowledge and research (for example

because of a lack of appropriate peer review, poor methodology, or flawed analyses) to inform decision making and

policy formulation; or 7) misrepresenting the underlying assumptions, uncertainties, or probabilities of scientific

products. This is not intended to be an exhaustive list.

Differences of scientific opinion are not necessarily inappropriate influence.

This definition is consistent with that used by the CDC. See

https://www.cdc.gov/policy/analysis/process/definition.html.

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Quality assurance refers to the systematic monitoring and evaluation of scientific activities to ensure

that standards of quality, information security and research integrity are being met.

Research misconduct refers to fabrication, falsification, or plagiarism in proposing, performing or

reviewing research, or in reporting research results or ordering, advising or suggesting that subordinates

engage in research misconduct. Research misconduct does not include honest error or differences of

opinion.

Research security refers to safeguarding the research enterprise against the misappropriation of

research and development to the detriment of national or economic security, related violations of

research integrity, and foreign government interference.

Retaliation refers to, per 5 U.S.C. § 2302(b)(8), taking or failing to take or threatening to take or failing

to take a personnel action with respect to any employee or applicant for employment because of any

disclosure of information that the employee or applicant reasonably believes evidences any violation of

any law, rule, or regulation or gross mismanagement, a gross waste of funds, an abuse of authority, or a

substantial and specific danger to public health or safety if such disclosure is not specifically prohibited

by law and if such information is not specifically required by Executive Order to be kept secret in the

interest of national defense or the conduct of foreign affairs. Per Pub. L. 112-199 § 110

Science refers to the full spectrum of scientific endeavors, including basic science, applied science,

evaluation, engineering, technology, economics, social sciences, and statistics, as well as the scientific

and technical information derived from these endeavors.

Scientific activities refer to activities that involve the application of well-accepted scientific methods

and theories in a systematic manner, and includes, but is not limited to, data collection, inventorying,

monitoring, statistical analysis, surveying, observations, experimentation, study, research, integration,

economic analysis, forecasting, predictive analytics, modeling, technology development, and scientific

assessment.

Scientific integrity is the adherence to professional practices, ethical behavior, and the principles of

honesty and objectivity when conducting, managing, using the results of, and communicating about

science and scientific activities. Inclusivity, transparency, and protection from inappropriate influence

are hallmarks of scientific integrity.

Scientific Integrity Official refers to a senior career employee designated as an agency’s lead to

oversee implementation and iterative improvement of scientific integrity policies and processes

consistent with the provisions of the 2021 Presidential Memorandum.

Scientist refers to an individual whose responsibilities include collection, generation, use, or evaluation

of scientific and technical data, analyses, or products. This includes, but is not limited to, Federal

scientists, contractors, and trainees. It does not refer to individuals with scientific and technical training

whose primary job functions are in non-scientific roles (e.g., policymakers, communicators).

This definition is consistent with that contained in OSTP, Federal Policy on Research Misconduct, Dec. 6, 2000.

This definition is consistent with that contained in a report by the Scientific Integrity Fast-Track Action

Committee of the National Science and Technology Council. “Protecting the Integrity of Government Science.”

January 11, 2022.

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Special Government Employee refers to an officer or employee who is retained, designated,

appointed, or employed by the Government to perform temporary duties, with or without compensation,

for not more than 130 days during any period of 365 consecutive days.

Transparency refers to ensuring all relevant data and information used to inform a decision made or

action taken is visible, accessible, and consumable by affected or interested parties, to the extent

allowable by law.

Appendix B: Examples of Agency Scientific Integrity Policies, Procedures, and

Related Materials

Provided in this appendix are links to examples of various scientific integrity policies, procedures, codes of

conduct, sample language for extramural grants and Federal contracts for agencies where these entities are

included, and guidance on authorship designation and addressing differences in scientific opinion. These

examples are provided as illustrative of a diverse range of well-established policies and practices from

different agencies. Scientific integrity policies and practices change over time, and these examples are

meant to be a contemporaneous resource that may evolve with changing practices.

Agency Policies

Pursuant to the 2021 Presidential Memorandum, agency policies should be prominently publicly available

and accessible on an agency website. These online examples of agency scientific integrity policies are

provided for reference.

Centers for Disease Control and Prevention

https://www.cdc.gov/scientific-integrity

Department of Energy

https://www.energy.gov/downloads/department-energy-scientific-integrity-policy

Department of the Interior

https://www.doi.gov/scientificintegrity

Environmental Protection Agency

https://www.epa.gov/scientific-integrity/epas-scientific-integrity-policy

National Oceanic and Atmospheric Administration

https://www.noaa.gov/organization/administration/nao-202-735d-2-scientific-integrity

United States Department of Agriculture

https://www.usda.gov/directives/dr-1074-001

United States Geological Survey

https://www.usgs.gov/survey-manual/50025-scientific-integrity

18 U.S.C. § 202

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Agency Procedures

These examples of agency procedures for protecting scientific integrity are provided for reference. Some

agencies prefer to include their procedures directly in their scientific integrity policies while others

establish stand-alone guidelines and handbooks to supplement the policy.

Department of the Interior

SCIENTIFIC INTEGRITY PROCEDURES HANDBOOK (305-DM-3)

https://www.doi.gov/sites/doi.gov/files/elips/documents/305 DM 3_ Handbook - Scientific Integrity

Procedures.pdf

National Oceanic and Atmospheric Administration

PROCEDURAL HANDBOOK FOR SCIENTIFIC INTEGRITY (NAO 202-735D-2)

https://www.noaa.gov/sites/default/files/2021-08/Scientific_Integrity_ProceduralHB_NAO_202-735D-

2.pdf

United States Department of Agriculture

PROCEDURES FOR RESPONDING TO ALLEGATIONS OF COMPROMISED SCIENTIFIC

INTEGRITY (DM 1074-001)

https://www.usda.gov/directives/dm-1074-001

Codes of Conduct

Several agencies have produced codes of conduct that intersect with scientific integrity in accordance

with their missions. Federal scientists and managers are also subject to the US Office of Government

Ethics Standards of Ethical Conduct for Employees of the Executive Branch.

Department of the Interior

DOI Code of Scientific and Scholarly Conduct

https://www.doi.gov/sites/doi.gov/files/migrated/scientificintegrity/upload/DOI-Code-of-Scientific-and-

Scholarly-Conduct-Poster-December-2014.pdf

National Oceanic and Atmospheric Administration

NAO 202-735D-2: Scientific Integrity Section 7: Code of Scientific Conduct

https://www.noaa.gov/organization/administration/nao-202-735d-2-scientific-integrity

United States Agency for International Development

USAID Employee Standards of Conduct

https://www.usaid.gov/sites/default/files/documents/1868/USAID_EmployeeStandardsOfConduct.pdf

United States Department of Agriculture

Appendix A USDA Code of Scientific Ethics of the Departmental Regulations on Scientific Integrity

DR 1074-001

https://www.usda.gov/directives/dr-1074-001

Department of Justice

Code of Professional Responsibility for the Practice of Forensic Science

https://www.justice.gov/sites/default/files/code_of_professional_responsibility_for-

the_practice_of_forensic_science_08242016.pdf

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Extramural Grant, Award, and Contract Language

Sample Language for Statements of Work from the Department of the Interior (page 27):

https://www.doi.gov/sites/doi.gov/files/elips/documents/305%20DM%203_%20Handbook%20-

%20Scientific%20Integrity%20Procedures.pdf

Solicitation Provisions and Contract Clauses from the Federal Register: Environmental

Protection Agency Acquisition Regulation (EPAAR); Scientific Integrity:

https://www.federalregister.gov/documents/2020/10/19/2020-20665/environmental-protection-agency-

acquisition-regulation-epaar-scientific-integrity

Scientific Integrity Language for Grants from the Environmental Protection Agency EPA

General Terms and Conditions Effective October 1, 2018: https://www.epa.gov/grants/epa-general-

terms-and-conditions-effective-october-1-2018

Proposal and Award Policies and Procedures Guide from the National Science Foundation

(2022): https://www.nsf.gov/publications/pub_summ.jsp?ods_key=pappg

Research Terms and Conditions from the National Science Foundation:

https://www.nsf.gov/bfa/dias/policy/fedrtc/agencyspecifics/nsf_1021.pdf

Contracts and Financial Assistance from the National Oceanic and Atmospheric Administration:

NOAA Procedural Handbook for NAO 202-735D.2: Scientific Integrity Section 5. Contracts and

Financial Assistance (2021): https://www.noaa.gov/sites/default/files/2021-

08/Scientific_Integrity_ProceduralHB_NAO_202-735D-2.pdf

Guidance on Designation of Authorship Guidelines

Centers for Disease Control and Prevention

Authorship Guidelines: https://www.cdc.gov/maso/policy/authorship.pdf

Environmental Protection Agency

Best Practices for Designating Authorship: https://www.epa.gov/sites/default/files/2016-

09/documents/best_practices_designating_authorship.pdf

National Institutes of Health

General Guidelines for Authorship Contributions:

https://oir.nih.gov/sites/default/files/uploads/sourcebook/documents/ethical_conduct/guidelines-

authorship_contributions.pdf

Processes for Authorship Dispute Resolution: https://oir.nih.gov/sourcebook/ethical-

conduct/responsible-conduct-research-training/processes-authorship-dispute-resolution

United States Geological Survey

Fundamental Science Practices: USGS Authorship of Scientific Information Products:

https://www.usgs.gov/survey-manual/50210-fundamental-science-practices-usgs-authorship-scientific-

information-products

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Guidance on Addressing Differences in Scientific Opinion

Environmental Protection Agency

Approaches for Expressing and Resolving Differing Scientific Opinions (EPA):

https://www.epa.gov/system/files/documents/2021-

09/epas_approaches_for_expressing_and_resolving_differing_scientific_opinions.pdf

Food and Drug Administration

FDA Staff Manual Guide (SMG 9010.1) – Scientific Dispute Resolution at FDA

https://www.fda.gov/media/79659/download

United States Nuclear Regulatory Commission

Management Directive 10.159, NRC Differing Professional Opinion Program:

https://www.nrc.gov/docs/ML1513/ML15132A664.pdf

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Appendix C: Summary of White House Scientific Integrity Memorandums

This appendix includes excerpts of the foundational elements contained in the March 2009 Presidential

Memorandum,

the December 2010 OSTP Memorandum,

and the January 2021 Presidential

Memorandum.

Presidential Memorandum on Scientific Integrity for The Heads Of Executive Departments And

Agencies from President Barak Obama, March 2009

Science and the scientific process must inform and guide decisions on a wide range of issues, including

improvement of public health, protection of the environment, increased efficiency in the use of energy and

other resources, mitigation of the threat of climate change, and protection of national security.

• Political officials should not suppress or alter scientific or technological findings and conclusions.

• If scientific and technological information is developed and used by the Federal Government, it

should ordinarily be made available to the public. To the extent permitted by law, there should be

transparency in the preparation, identification, and use of scientific and technological information

in policymaking.

• The selection of scientists and technology professionals for positions in the executive branch should

be based on their scientific and technological knowledge, credentials, experience, and integrity.

• The selection and retention of candidates for science and technology positions in the executive

branch should be based on the candidate's knowledge, credentials, experience, and integrity;

• Each agency should have appropriate rules and procedures to ensure the integrity of the scientific

process within the agency;

• When scientific or technological information is considered in policy decisions, the information

should be subject to well-established scientific processes, including peer review where appropriate,

and each agency should appropriately and accurately reflect that information in complying with

and applying relevant statutory standards;

• Except for information that is properly restricted from disclosure under procedures established in

accordance with statute, regulation, Executive Order, or Presidential Memorandum, each agency

should make available to the public the scientific or technological findings or conclusions

considered or relied on in policy decisions;

• Each agency should have in place procedures to identify and address instances in which the

scientific process or the integrity of scientific and technological information may be compromised;

and

• Each agency should adopt such additional procedures, including any appropriate whistleblower

protections, as are necessary to ensure the integrity of scientific and technological information and

processes on which the agency relies in its decision making or otherwise uses or prepares.

OSTP Memorandum on Scientific Integrity for the Heads of Executive Departments and

Agencies from John P. Holdren, December 2010

I. Foundations of Scientific Integrity in Government

Scientific and technological information is often a significant contributor to the development of sound

policies. Successful application of science in public policy depends on the integrity of the scientific process

both to ensure the validity of the information itself and to engender public trust in Government. For this

reason, agencies should develop policies that:

1. Ensure a culture of scientific integrity. Scientific progress depends upon honest investigation, open

discussion, refined understanding, and a firm commitment to evidence. Science, and public trust in

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science, thrives in an environment that shields scientific data and analyses from inappropriate political

influence; political officials should not suppress or alter scientific or technological findings.

2. Strengthen the actual and perceived credibility of Government research. Of particular importance are:

a. ensuring that selection of candidates for scientific positions in the executive branch is based

primarily on their scientific and technological knowledge, credentials, experience, and integrity;

b. ensuring that data and research used to support policy decisions undergo independent peer review

by qualified experts, where feasible and appropriate, and consistent with law;

c. setting clear standards governing conflicts of interest; and

d. adopting appropriate whistleblower protections.

3. Facilitate the free flow of scientific and technological information, consistent with privacy and

classification standards. Open communication among scientists and engineers, and between these

experts and the public, accelerates scientific and technological advancement, strengthens the economy,

educates the Nation, and enhances democracy. Consistent with the Administration's Open Government

Initiative, agencies should expand and promote access to scientific and technological information by

making it available online in open formats. Where appropriate, this should include data and models

underlying regulatory proposals and policy decisions.

4. Establish principles for conveying scientific and technological information to the public. The accurate

presentation of scientific and technological information is critical to informed decision making by the

public and policymakers. Agencies should communicate scientific and technological findings by

including a clear explication of underlying assumptions; accurate contextualization of uncertainties;

and a description of the probabilities associated with both optimistic and pessimistic projections,

including best-case and worst-case scenarios where appropriate.

II. Public Communications

Agencies should develop public communications policies that promote and maximize, to the extent

practicable, openness and transparency with the media and the American people while ensuring full

compliance with limits on disclosure of classified information. Such policies should ensure that:

1. In response to media interview requests about the scientific and technological dimensions of their

work, agencies will offer articulate and knowledgeable spokespersons. who can, in an objective and

nonpartisan fashion, describe and explain these dimensions to the media and the American people.

2. Federal scientists may speak to the media and the public about scientific and technological matters

based on their official work, with appropriate coordination with their immediate supervisor and their

public affairs office. In no circumstance may public affairs officers ask or direct Federal scientists

to alter scientific findings.

3. Mechanisms are in place to resolve disputes that arise from decisions to proceed or not to proceed

with proposed interviews or other public information-related activities.

III. Use of Federal Advisory Committees

Agencies should develop policies, in coordination with the General Services Administration and consistent

with the Administration's guidance on lobbyists serving on Federal advisory committees (FACs) for

convening FACs tasked with giving scientific advice, consistent with the following:

1. The recruitment process for new FAC members should be as transparent as practicable.

Departments and agencies should, when practicable and appropriate, announce FAC member

vacancies widely, including notification in the Federal Register with an invitation for the public to

recommend individuals for consideration and for self -nominations to be submitted;

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2. Professional biographical information (including current and past professional affiliations) for

appointed committee members should be made widely available to the public (e.g., via a website)

subject to Privacy Act and other statutory/regulatory considerations. Such information should

clearly illustrate the individuals' qualifications for serving on the committee;

3. The selection of members to serve on a scientific or technical FAC should be based on expertise,

knowledge, and contribution to the relevant subject area. Additional factors that may be considered

are availability of the member to serve, diversity among members of the FAC, and the ability to

work effectively on advisory committees. Committee membership should be fairly balanced in

terms of points of view represented with respect to the functions to be performed by the FAC;

4. Except when prohibited by law, agencies should make all Conflict of Interest waivers granted to

committee members publicly available; and

5. Except when explicitly stated in a prior agreement between an agency and a FAC, all reports,

recommendations, and products produced by FACs should be treated as solely the findings of such

committees rather than of the U.S. Government, and thus are not subject to intra- or inter-agency

revision.

IV. Professional Development of Government Scientists and Engineers

Agencies should establish policies that promote and facilitate, as permitted by law, the professional

development of Government scientists and engineers. Such policies should, consistent with Federal ethics

rules, job responsibilities, and existing agency policies regarding political appointees:

1. Encourage publication of research findings in peer-reviewed, professional, or scholarly journals;

2. Encourage presentation of research findings at professional meetings;

3. Allow Government scientists and engineers to become editors or editorial board members of

professional or scholarly journals;

4. Allow full participation in professional or scholarly societies, committees, task forces and other

specialized bodies of professional societies, including removing barriers for serving as officers or

on governing boards of such societies; and

5. Allow Government scientists and engineers to receive honors and awards for their research and

discoveries with the goal of minimizing, to the extent practicable, disparities in the potential for

private-sector and public-sector scientists and engineers to accrue the professional benefits of such

honors or awards.

Presidential Memorandum on Restoring Trust in Government Through Scientific Integrity and

Evidence-Based Policymaking from President Joseph R. Biden, January, 2021

• It is the policy of my Administration to make evidence-based decisions guided by the best available

science and data. Scientific and technological information, data, and evidence are central to the

development and iterative improvement of sound policies, and to the delivery of equitable

programs, across every area of government. Scientific findings should never be distorted or

influenced by political considerations. When scientific or technological information is considered

in policy decisions, it should be subjected to well-established scientific processes, including peer

review where feasible and appropriate, with appropriate protections for privacy. Improper political

interference in the work of Federal scientists or other scientists who support the work of the Federal

Government and in the communication of scientific facts undermines the welfare of the Nation,

contributes to systemic inequities and injustices, and violates the trust that the public places in

government to best serve its collective interests.

• This memorandum reaffirms and builds on the Presidential Memorandum of March 9, 2009

(Scientific Integrity), and the Director of the Office of Science and Technology Policy’s

Memorandum of December 17, 2010 (Scientific Integrity).

• Executive departments and agencies (agencies) shall establish and enforce scientific-integrity

policies that ban improper political interference in the conduct of scientific research and in the

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collection of scientific or technological data, and that prevent the suppression or distortion of

scientific or technological findings, data, information, conclusions, or technical results.

• Heads of agencies shall ensure that all agency activities associated with scientific and technological

processes are conducted in accordance with the 6 principles set forth in section 1 of the Presidential

Memorandum of March 9, 2009, and the 4 foundations of scientific integrity in government set

forth in part I of the Director’s Memorandum of December 17, 2010.

• Heads of agencies shall ensure that their agency scientific-integrity policies reflect the findings in

the Task Force report produced under section (2)(b)(v) of this memorandum and apply to all agency

employees, regardless of the nature of their appointment, as well as contractors who perform

scientific activities for agencies.

• The head of each agency with an existing scientific-integrity policy shall submit an updated policy

to the Director within 180 days of the publication of the Task Force’s report.

• The head of each agency without an existing scientific-integrity policy shall submit a draft agency

scientific-integrity policy to the Director within 180 days of the publication of the Task Force’s

report.

• Policies shall respond to the Task Force’s analysis, adhere to the policy directives in this

memorandum, and uphold the highest standards of scientific practice.

• Publish the agency’s scientific-integrity policy on the agency’s website, and disseminate

information about the policy through the agency’s social media channels;

• Develop and publish procedures, as appropriate and consistent with applicable law, for

implementing the agency’s scientific-integrity policy, including establishing and publishing an

administrative process for reporting, investigating, and appealing allegations of deviations from the

agency’s policy, and for resolving any disputes or disagreements about scientific methods and

conclusions;

• Educate agency employees, as well as contractors who perform scientific activities for the agency,

on their rights and responsibilities related to scientific integrity, including by conducting routine

training on the agency’s scientific-integrity policy for all employees, and by ensuring any new

employees are made aware of their responsibilities under the agency’s scientific-integrity policy

shortly after they are hired; and

• Publish, consistent with any requirements related to national security and privacy, as well as any

other applicable law, an annual report on the agency’s website that includes the number of

administrative investigations and appeals involving alleged deviations from the agency’s scientific-

integrity policies, as described in section (3)(c)(iii) of this memorandum, for the year covered by

the report, and the number of investigations and appeals pending from years prior to the year

covered by the report, if any.

• Agency Chief Science Officers and Scientific Integrity Officials. (a) Within 120 days of the date

of this memorandum, the heads of agencies that fund, conduct, or oversee scientific research shall,

to the extent consistent with applicable law, designate a senior agency employee for the role of

chief science officer, science advisor, or chief scientist (“Chief Science Officer”), who shall:

o Serve as the principal advisor to the head of the agency on scientific issues and ensure that

the agency’s research programs are scientifically and technologically well-founded and

conducted with integrity; and

o Oversee the implementation and iterative improvement of policies and processes affecting

the integrity of research funded, conducted, or overseen by the agency, as well as policies

affecting the Federal and non-Federal scientists who support the research activities of the

agency, including scientific-integrity policies consistent with the provisions of this

memorandum.

• Because science, facts, and evidence are vital to addressing policy and programmatic issues across

the Federal Government, the heads of all agencies (not only those that fund, conduct, or oversee

scientific research) shall designate expeditiously a senior career employee as the agency’s lead

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scientific-integrity official (“Scientific Integrity Official”) to oversee implementation and iterative

improvement of scientific-integrity policies and processes consistent with the provisions of this

memorandum, including implementation of the administrative and dispute resolution processes

described in section (3)(c)(iii) of this memorandum. For agencies with a Chief Science Officer, the

Scientific Integrity Official shall report to the Chief Science Officer on all matters involving

scientific-integrity policies.

• To the extent necessary to fully implement the provisions of this memorandum, heads of agencies

may designate additional scientific-integrity points of contact in different offices and components,

who shall coordinate with the agency’s Scientific Integrity Official in implementing the agency’s

scientific-integrity policies and processes.

• Heads of agencies should ensure those designated to serve in the roles described in this section,

along with their respective staffs, are selected based on their scientific and technological

knowledge, skills, experience, and integrity, including experience conducting and overseeing

scientific research and utilizing scientific and technological information and data in agency

decision-making, prioritizing experience with evidence-based, equitable, inclusive, and

participatory practices and structures for the conduct of scientific research and the communication

of scientific results.

• Ensure that members and future nominees of scientific advisory committees reflect the diversity of

America in terms of gender, race, ethnicity, geography, and other characteristics; represent a variety

of backgrounds, areas of expertise, and experiences; and are selected based on their scientific and

technological knowledge, skills, experience, and integrity, including prioritization of experience

with evidence-based, equitable, inclusive, and participatory practices and structures for the conduct

of scientific research and the communication of scientific results.

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Appendix D: Text of the Charter of the NSTC Subcommittee on Scientific

Integrity

CHARTER

of the

SUBCOMMITTEE ON SCIENTIFIC INTEGRITY

COMMITTEE ON SCIENCE

NATIONAL SCIENCE AND TECHNOLOGY COUNCIL

[AS ADOPTED JULY, 2022]

A. Official Designation

The Subcommittee on Scientific Integrity (SOSI) is hereby established by action of the Committee

on Science of the National Science and Technology Council (NSTC).

B. Purpose and Scope

The SOSI is established in response to the 2022 NSTC Scientific Integrity Fast-Track Action

Committee’s report entitled Protecting the Integrity of Government Science (2022 Report) which

found that an interagency deliberative body would be critical to building successful scientific

integrity programs across the whole of government. This body is essential to the long-term

protection of scientific integrity in the Executive Branch (agencies).

The scope of the SOSI is to assess and communicate on matters of Federal scientific integrity for

the purposes of (1) fostering and strengthening a culture and practice of scientific integrity

government-wide and (2) providing coordination, information-sharing, and support across

agencies and components of the Executive Office of the President (EOP). This scope enables SOSI

to be a primary vehicle for cross-agency coordination, assessment and improvement of agency

policies and practices, while maintaining a role as an independent voice on matters of Federal

scientific integrity.

The SOSI shall be comprised of career Scientific Integrity Officials (SIO) from Federal agencies

and staff members of EOP components.

C. Functions

The SOSI shall (no order of priority is implied):

• Promote a culture of scientific integrity across government by sharing and celebrating agency

achievements and milestones involving scientific integrity;

• Convene SIOs from Federal agencies for the purposes of interagency coordination on matters

related to scientific integrity;

• Share developments in, case studies about, advice, and resources for, scientific integrity

policies and practices;

• Review and provide guidance on newly established or amended agency scientific integrity

policies;

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• Assist the White House Office of Science and Technology Policy (OSTP) in assessing regular

performance and improvement of agency and EOP component scientific integrity policies,

practices, and culture;

• Assess, analyze, and offer recommendations to the extent allowed by law, applicable

regulations, and consistent with privacy obligations, regarding public allegations of scientific

integrity violations, such as allegations that involve senior-level officials, political appointees,

or scientific integrity officials;

• Provide advisory responses to agency inquiries about scientific integrity;

• At the discretion of SOSI, and only when the agency provides the level of access that SOSI

deems necessary to any internal information needed for a valid analysis, provide advisory

responses to agency requests for another agency to review their internal scientific integrity

policies and processes, such as inquiries related to senior-level officials, political appointees,

or SIOs; and,

• Coordinate, accelerate, and advise agencies and EOP components on important and emerging

issues with scientific integrity implications, including but not limited to those identified in the

2022 Report such as: diversity, equity, inclusion, and accessibility of science; scientific

engagement with underserved communities; advances in automated decision-making

technologies; new modes of science; and, coordination of related or adjacent policy domains

such as research security and open science.

In conducting its work, the SOSI may, as needed (no order of priority is implied):

• Liaise between the OSTP Director, heads of agencies, Chief Data Officer Council, Evaluation

Officer Council, OMB Director, Chief Scientific Officers, SIOs, and other Federal agency

stakeholders as appropriate to best optimize, streamline, and prevent duplicative work across

the Federal government;

• Confer with and gather input from stakeholders outside of government, using a variety of

methods including convening meetings, requesting data calls, and issuing requests for

information or comment;

• Convene meetings with and gather input from relevant agency and EOP component members;

• Consult and collaborate with other NSTC bodies;

• Create standing and term-limited subgroups;

• Share findings and recommendations with the Chair(s) of the Committee on Science on

allegations of scientific integrity violations brought before SOSI by agencies for review and to

other Federal agency stakeholders, as appropriate, to raise awareness, share best practices

between agencies, gather input, and recommend institutional improvements;

• Publish SOSI proceedings, final reports, guidance, and other materials, to the extent permitted

by law, regulations, and consistent with privacy obligations, on OSTP and/or agency websites;

and,

• Establish meeting cadence, parliamentary procedures, notetaking procedures, and other

requirements in the conduct of SOSI administration.

Membership

The Membership of the SOSI shall be constituted by the SIOs of Executive Branch departments

and agencies. Representative agencies include, but shall not be limited to:

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Department of Agriculture

Department of Commerce

Department of Defense

Department of Education

Department of Energy

Department of Health and Human Services

Department of Homeland Security

Department of Housing and Urban Development

Department of Justice

Department of Labor

Department of State

Department of the Interior

Department of Transportation

Department of Treasury

Department of Veterans Affairs

National Aeronautics and Space Administration

National Science Foundation

Smithsonian Institution

The Office of Personnel Management

United States Agency for International Development

United States Consumer Financial Protection Bureau

United States Consumer Product Safety Commission

United States Environmental Protection Agency

United States Nuclear Regulatory Commission

Federal Communications Commission

The following components in the Executive Office of the President are represented on the SOSI:

Office of Management and Budget; and

Office of Science and Technology Policy (permanent co-chair)

The following agencies members shall serve as co-chairs for a one-year term, effective from the

date of this charter:

Department of the Interior

United States Environmental Protection Agency

D.2. Member Roles, Responsibilities, and Procedures

OSTP and agency co-chairs shall act as an executive council on the SOSI, establishing SOSI

priorities, agendas, and acting as principal authors of SOSI communications. Election of agency

co-chairs shall be subject to SOSI parliamentary procedures as decided and led by the Executive

Secretaries. Elected agency co-chairs shall serve a term of two years and may be re-elected.

Agency members shall participate in SOSI meetings, serve on subgroups of the SOSI, provide

information to the SOSI, and perform duties on SOSI business as appropriate and as designated

by the SOSI co-chairs.

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All agency and EOP component members shall hold a single vote on proposed actions by the

SOSI.

E. Private-Sector and Inter-Governmental Agency Interface

The SOSI may work with the President’s Council of Advisors on Science and Technology

(PCAST) to secure appropriate private-sector advice, and will recommend to the Director of the

OSTP the nature of additional private-sector advice needed to accomplish its mission. The SOSI

may also interact with and receive ad hoc advice from various private-sector groups as consistent

with the Federal Advisory Committee Act.

The SOSI may seek input from communities affected by scientific integrity policies and

practices. Input from these communities may be acquired through interactions with national or

international state, local or Tribal governments, or with private and non-profit organizations, as

appropriate.

The SOSI may consult with agency inspectors general or other legal counsel and liaise with the

Council of the Inspectors General on Integrity and Efficiency on matters related to scientific

integrity.