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Ensuring Scientific Integrity at the National Aeronautics and Space Administration

August 5, 2011

On May 5, 2011, Dr. John P. Holdren, Director of the Office of Science and Technology Policy 

(OSTP) and Assistant to the President for Science and Technology, requested that heads of 

executive departments and agencies provide draft scientific integrity policies to OSTP within 90 

days. This request followed a December 17, 2010, request by Dr. Holdren for departments and 

agencies to report the actions they have taken to develop and implement the Administration’s 

policies on scientific integrity detailed in President Obama’s memorandum of March 9, 2009, 

which articulated six principles central to the preservation and promotion of scientific integrity. 

The National Aeronautics and Space Administration (NASA) transmitted a response to the 

December 17, 2010, request in April 2011.

The present document responds to the May 5, 2011, request. As NASA demonstrated in its April 

2011 report to OSTP, NASA already has a variety of policies in place to ensure scientific and 

engineering integrity. The intent of the present document is thus to highlight how NASA’s 

existing policies support scientific and engineering integrity as well as to note the actions NASA 

plans to take to strengthen its policies in this area. References and website links to existing 

policy documents are furnished where applicable; NASA directs the reader to these references 

for a full description of the Agency’s commitment to scientific and engineering integrity. The 

present document is organized to respond to the four major areas and 17 sub-areas addressing 

scientific and engineering integrity that are explicitly addressed in Dr. Holdren’s December 17, 

2010, memorandum.

I. Foundations of Scientific Integrity in Government. 

1. Ensure a culture of scientific integrity.

NASA is committed to sustaining an environment of scientific integrity, honest investigation, 

and freedom from political interference:

NASA Policy Directive (NPD) 1000.0A, NASA Governance and Strategic Management 

Handbook, stipulates that integrity is a NASA core value and that the Agency “is 

committed to maintaining an environment of trust, build upon honesty, ethical behavior, 

respect, and candor.”

NPD 1080.1, Policy for the Conduct of NASA Research and Technology, stipulates that 

the Agency will achieve excellence by selecting the best research and technology project 

ideas to be carried out by the most capable people, thereby providing the American 

public the greatest return on its investment in NASA research and technology programs.

NASA Procedural Requirements (NPR) 1080.1, Requirements for the Conduct of NASA 

Research and Technology, creates and sustains a culture of scientific integrity by 

establishing NASA requirements for research and technology planning, solicitation 

selection of proposals, peer review, quality assessment and performance metrics, data 

protection, and dealing with misconduct.
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14 CFR 1275, Research Misconduct, stipulates the procedures NASA will use to handle 

allegations that a person or institution has engaged in fabrication, falsification, or 

plagiarism in proposing, performing, or reviewing research, or in reporting research 

results, funded or supported by NASA.

2. Strengthen the actual and perceived credibility of Government research.

NASA is committed to strengthening the actual and perceived credibility of its research. 

(a) Ensuring that the selection of candidates for scientific positions is based primarily on their 

scientific and technological knowledge, credentials, experience, and integrity. 

NASA is committed to ensuring that its workforce is qualified to carry out the Nation’s civil 

space program:

NPR 3335.1, Internal Placement of NASA Employees, stipulates that NASA will fill 

positions available only to internal candidates through competition and on the basis of 

merit.

5 CFR 300.102, Employment Practices, stipulates that NASA will use competitive 

practices for external hiring that fairly test the relative capacity and fitness of candidates 

for the jobs to be filled and to support selection from among the best qualified candidates.

(b) Ensuring that data and research used to support policy decisions undergo independent peer 

review by qualified experts. 

NASA is committed to ensuring that data and research that are used to support policy decisions 

undergo independent peer review by qualified experts:

NPD 1000.0A, NASA Governance and Strategic Management Handbook, stipulates 

NASA’s commitment to employing process-related checks and balances including peer 

review to ensure the integrity of its programs.

NPR 1080.1, Requirements for the Conduct of NASA Research and Technology, and NPR 

7120.8, NASA Research and Technology Program and Project Management 

Requirements, stipulate that NASA will rely on peer review panels of competent and nonconflicted research and technology experts from both internal and external to NASA to 

conduct quality and performance assessments.

NPR 1080.1, Requirements for the Conduct of NASA Research and Technology, and NPR 

2200.2, Requirements for Documentation, Approval, and Dissemination of NASA 

Scientific and Technical Information, stipulate that NASA expects all scientific research 

by NASA investigators and NASA-sponsored investigators to be peer-reviewed before 

publication, whether the results are published by NASA or submitted to a scientific 

journal for publication.

The 2010 Science Plan for NASA’s Science Mission Directorate stipulates that 

investment choices for Earth and space science programs will be based on scientific merit 

via peer review and open competition.

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The Science Mission Directorate is responsible for conducting robotic space missions and supporting research and 

technology development in the areas of Earth science, planetary science, astrophysics, and heliophysics.
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Human Research Program (HRP)-47053, Science Management Plan, stipulates that 

projects managed by the Human Research Program will be selected on the basis of peer 

review of competing proposals.

(c) Setting clear standards regarding conflicts of interest. 

NASA is committed to setting and enforcing clear standards regarding conflicts of interest: 

NASA civil servants are bound by federal restrictions against financial conflicts of 

interest. As with federal civil servants generally, NASA scientists in covered positions 

file financial disclosure reports annually and are provided annual training on conflict of 

interest rules and other federal ethics requirements.

Scientists participating in NASA peer reviews and NASA research, whether NASA civil 

servants or members of the external scientific community, must follow documented 

standards for conflicts of interest:

o The Guidebook for Proposers Responding to a NASA Research Announcement or 

Cooperative Agreement Notice stipulates that all peer reviewers of NASA 

proposals made under a NASA Research Announcement must avoid not only 

actual but also any apparent conflicts of interest and must maintain confidentiality 

about all activities involved in the peer review process.

o Science Mission Directorate Policy Document (SPD)-01, Handling Conflicts-ofInterest for Peer Reviews, stipulates clear conflicts-of-interest policies for peer 

reviewers in all peer reviews managed by NASA’s Science Mission Directorate.

o SPD-05, Preventing Financial Conflicts for IPA Employees, stipulates the 

measures that may be utilized by an Intergovernmental Personnel Act (IPA) 

detailee to the NASA Science Mission Directorate to mitigate potential conflicts

of interest between his or her home institution and the Science Mission 

Directorate. The IPA permits assignments to and from universities. IPA detailees 

serve within the Science Mission Directorate in all capacities that civil servant 

scientists do.

o In 2008, the Office of Government Ethics approved the “NASA Conflicts of 

Interest and Confidentiality Self Certification for NASA Peer Reviewers who are 

Federal Government Employees Form.” This form is incorporated into the online 

NASA Solicitation and Proposal Integrated Review and Evaluation System, and 

all NASA civil servants must complete it to certify the absence of financial 

conflicts of interest before participating in peer reviews of projects proposed for 

Agency support.

o Human Research Program (HRP)-47053, Science Management Plan, stipulates 

clear conflicts-of-interest policies for peer reviewers and civil servants involved in 

proposal selections for projects managed by the Human Research Program.

(d) Adopting appropriate whistleblower protections. 

NASA is fully committed to the Whistleblower Protection Act of 1989, Public Law (P.L.) 101-

12, and its expanded protections enacted by P.L. 103-424: 

NASA’s Whistleblower Protection Plan dated March 2007 stipulates that the Agency will 

provide confidentiality, a single point of contact to make complaints, tracking of the 
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complaint for the whistleblower, education of employees about their rights and 

protections, education of employees about their obligation to report their concerns, and 

education to human resources professionals and NASA managers and supervisors 

regarding personnel laws, rules, and regulations. The plan was developed in response to 

Section 110 of the NASA Authorization Act of 2005 (P.L. 109-155), which required the 

NASA Administrator to transmit to Congress “... a plan describing steps to be taken by 

NASA to protect from retaliation NASA employees who raise concerns about substantial 

and specific dangers to public health and safety or about substantial and specific factors 

that could threaten the success of a mission.”

NASA conducts annual training regarding the No FEAR Act (P.L. 107-174) that informs 

employees of the rights and protections available under the Whistleblower Protection Act 

and anti-discrimination laws. In addition, the annual notice and training encourages 

employees to raise violations of the Whistleblower Protection Act to the NASA Office of 

Inspector General located at each NASA Center, or Office of Special Counsel.

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

and classification standards.

NASA is committed to facilitating open communication among scientists and engineers, between 

NASA staff and the technical community, and between NASA employees and the public. NASA 

requires the results of NASA-funded research, both internal and external, to be made available to 

the scientific community and to the public at no cost to them:

The National Aeronautics and Space Act of 1958, as amended, stipulates that NASA 

shall “provide for the widest practicable and appropriate dissemination of information 

concerning its activities and the results thereof.” Unless a determination is made that 

public dissemination of information must be prohibited or restricted, NASA information 

is made available to the public.2

NPD 2200.1, Management of NASA Scientific and Technical Information, stipulates that 

NASA shall provide for the "widest practicable and appropriate dissemination" of 

scientific and technical information resulting from NASA's research effort, while 

precluding the inappropriate dissemination of NASA's restricted and sensitive 

information, in keeping with the National Aeronautics and Space Act of 1958, as 

amended.

NPR 2200.2, Requirements for Documentation, Approval, and Dissemination of NASA 

Scientific and Technical Information, stipulates that NASA scientific and technical 

information must be made available to the public either through publication in the open 

literature or through NASA’s Scientific and Technical Information homepage, 

http://www.sti.nasa.gov/STI-public-homepage.html.

NPD 1001.0, NASA Strategic Plan, and the 2010 Science Plan for NASA’s Science 

Mission Directorate stipulate that the results of NASA research and development must be 

made available for the benefit of the Government, the advancement of research, and the 

increase in the public’s knowledge.

 

2 NASA scientific and technical information can be restricted if it includes national- security-classified information, 

export-controlled information, proprietary information, or discloses an invention (NPR 2200.2, Section 4.5.1).
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4. Establish principles for conveying scientific and technological information to the public.

NASA is committed to conveying to the public scientific and technological information that 

derives from its research and development activities:

The National Aeronautics and Space Act of 1958, as amended, stipulates that NASA 

shall “provide for the widest practicable and appropriate dissemination of information 

concerning its activities and the results thereof.” Unless a determination is made that 

public dissemination of information must be prohibited or restricted, NASA information 

is made available to the public.3

NPD 2200.1, Management of NASA Scientific and Technical Information, stipulates that 

NASA will collect, manage, disseminate, safeguard, and archive its scientific and 

technical information for use by NASA and NASA contractors and grantees, and unless 

restricted, the public in order to advance NASA’s goals in science, exploration, and 

aeronautics; to strengthen the effectiveness and improve the productivity and cost 

effectiveness of the NASA research effort; to reduce unnecessary duplication; and to 

improve U.S. competitiveness in science and technology. 

NPR 2200.2, Requirements for Documentation, Approval, and Dissemination of NASA 

Scientific and Technical Information, establishes NASA requirements for approving and

publishing NASA scientific and technical information and disseminating it to the NASA 

technical community and the public consistent with the stipulations contained in NPD 

2200.1.

NASA practice is to place all scientific data from robotic space missions into publicly 

accessible data archives for use by the scientific community and the public at no cost to 

them. These practices are governed by requirements that are generally included in all 

solicitations for space missions and investigations. See, for example, 

http://science.nasa.gov/earth-science/earth-science-data/data-information-policy/ and 

http://science.nasa.gov/heliophysics/heliophysics-data-centers/.

II. Public Communications.

NASA is committed to promoting and maximizing openness with the media and the American 

people:

The National Aeronautics and Space Act of 1958, as amended, stipulates that NASA 

shall “provide for the widest practicable and appropriate dissemination of information 

concerning its activities and the results thereof.” Unless a determination is made that 

public dissemination of information must be prohibited or restricted, NASA information 

is made available to the public.4

14 CFR 1213, Release of Information to News and Information Media, includes 

provisions that:

o NASA will offer articulate and knowledgeable spokespersons who can best serve 

the needs of the media and the American public (14 CFR 1213.105(b)).

 

3

Ibid.

4

Ibid.
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o NASA employees may, but are not required to, speak to the media and the public 

about their work (14 CFR 1213.105(c) and (h)).

o Set forth an internal dispute resolution process for ensuring scientific and 

technical accuracy is not compromised (14 CFR 1213.104(e)).

o Scientific and technical information from or about Agency programs and projects 

will be accurate and unfiltered (14 CFR 1213.102(a)) and that editing by public 

affairs staff to ensure that public information products are well written and 

appropriate for the intended audience shall not change scientific or technical data 

or the meaning of programmatic content (14 CFR 1213.103(c)).

III. Use of Federal Advisory Committees. 

NASA is committed to the integrity of its use of Federal advisory committees (FAC) tasked with 

giving scientific advice:

NPD 1150.11, Federal Advisory Committee Act Committees, stipulates NASA policies 

for the management of its advisory committees subject to the Federal Advisory 

Committee Act (FACA) as well as committees which are not subject to FACA. This 

NPD was developed in compliance with the statutory provisions of the Federal Advisory 

Committee Act (5 U.S.C. App., as amended) and the General Services Administration 

(GSA) Final Rule on Federal Advisory Committee Management (41 CFR Parts 101-6 and 

102-3). NPD 1150.11 stipulates that “Subcommittees or task forces that... are not 

subject to FACA ... will operate under procedures that provide for public meetings and 

the maintenance of publicly available records.”

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

NASA is committed to making the recruitment process for new FAC members as transparent as 

possible:

NPD 1150.11 stipulates that NASA will rely on nominations from within the Agency 

followed by a thorough vetting of the nominee for expertise, experience, and conflicts of 

interest. The nomination process for members of one of NASA’s five FACs, the National 

Space-Based Positioning, Navigation, and Timing Advisory Board, is coordinated among 

the nine Federal stakeholder agencies. All members of NASA FACs are appointed by the 

NASA Administrator.

NASA anticipates revising NPD 1150.11 by October 31, 2011, to stipulate that the 

Agency will announce NASA FAC vacancies widely, including notice in the Federal 

Register with an invitation to the public to recommend individuals for consideration and 

also to submit self-nominations.
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2. Professional biographical information for appointed committee members should be made 

widely available to the public.

NASA is committed to making professional biographical information for appointed committee 

members widely available to the public:

NASA has posted professional biographical information to its websites for several of the 

NASA FACs.

NASA anticipates revising NPD 1150.11 by October 31, 2011, to stipulate that NASA 

will ensure that professional biographical information is available on its website for all of 

the members of its FACs.

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.

NASA is committed to ensuring that the Agency selects FAC members based on their expertise, 

knowledge, and contribution to the relevant subject area:

NASA practice is to select members of NASA FACs based on their expertise, 

knowledge, experience, and contribution to the relevant subject area. Additional factors 

considered include the availability of the member to serve, diversity among members of 

the committee, and the ability to work effectively on the committee. 

NASA is committed to having a fairly balanced membership with regard to points of 

view represented and functions to be performed by its FACs. To that end, beginning in 

2011, NASA submits a written Membership Balance Plan to the GSA for review of every 

new, renewed, or reestablished NASA FAC to ensure the balanced membership 

requirement is met.

NASA anticipates revising NPD 1150.11 by October 31, 2011, to stipulate the 

aforementioned selection practices as written policy as appropriate.

4. Agencies should make publicly available all Conflict of Interest waivers granted to 

committee members.

NASA is committed to making publicly available the names of all committee members receiving 

Conflict of Interest waivers:

NASA practice is to grant such waivers rarely.

NASA anticipates revising NPD 1150.11 by October 31, 2011, to stipulate that the 

Agency will make publicly available the names of all committee members receiving 

Conflict of Interest waivers.

5. All reports, recommendations, and products produced by FAC should be treated as the 

findings of such committees rather than the U.S. Government and are thus not subject to 

revision by NASA.

NASA is committed to treating all reports, recommendations, and products of FACs as the 

findings of such committees and, consequently, will refrain from revising them:

NPD 1150.11 stipulates that NASA FACs must make such reports, records, and other 

papers available to the public in accordance with all legal requirements.
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NASA practice is that all reports, recommendations, and products produced by NASA 

FACs are treated as the findings of such committees rather than the U.S. Government 

and are thus not subject to revision by NASA. 

NASA anticipates revising NPD 1150.11 by October 31, 2011, to stipulate the 

aforementioned practices as written policy as appropriate.

IV. Professional Development of Government Scientists and Engineers.

1. Encourage publication of research findings in peer-reviewed, professional, or scholarly 

journals.

NASA is committed to encouraging Agency employees to publish NASA-sponsored research 

findings in peer-reviewed, professional, or scholarly journals:

NPR 1080.1, Requirements for the Conduct of NASA Research and Technology, 

stipulates that NASA researchers and project staff are required to publish the results of 

their research and development activities in peer-reviewed literature or publicly available 

NASA technical reports.

NPR 2200.2, Requirements for Documentation, Approval, and Dissemination of NASA 

Scientific and Technical Information, establishes NASA requirements for approving and

publishing NASA scientific and technical information and disseminating it to the NASA 

technical community and the public.

2. Encourage presentation of research findings at professional meetings.

NASA is committed to encouraging Agency employees to present research findings at 

professional meetings:

NPR 1080.1, Requirements for the Conduct of NASA Research and Technology,

stipulates that NASA researchers and project staff are expected to share their results with 

their peers and colleagues at professional meetings, science conferences, and other 

venues. NASA civil servants will do so to the extent permitted by available funding and 

law.5

3. Allow Government scientists and engineers to become editors or editorial board members of 

professional or scholarly journals.

NASA is committed to allowing NASA civil servant scientists and engineers to serve as editors 

or editorial board members of professional or scholarly journals: 

No policy precludes NASA civil servant scientists and engineers from accepting and 

performing such roles. This service is generally considered part of a NASA scientist’s or 

 

5

For example, the Consolidated Appropriations Act, 2010, P.L. 111-117, requires that NASA limit travel to any 

single conference outside of the United States (a “foreign conference”) to no more than 50 NASA employees. The 

NASA Authorization Act of 2008, P.L. 110-422, limited fiscal year 2009 funding for conferences to “not more than 

$5,000,000 for any expenses related to conferences, including conference programs, travel costs, and related 

expenses.”
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engineer’s official duties and, when approved by his or her supervisor, may be carried out 

as part of his or her job.

4. Allow full participation in professional societies including removing barriers for serving as 

officers or on governing boards of such societies.

NASA is committed to allowing its scientists, engineers, and all other NASA employees for 

whom such participation is an integral part of professional development to serve as officers in 

professional societies: 

There are no NASA-specific barriers to participation as officers or directors of 

professional societies. The Department of Justice Office of Legal Counsel has opined 

that with the exception of certain standard-setting organizations 18 U.S.C. § 208 prohibits 

outside board service in an official capacity. NASA ethics officials work with interested 

employees to ensure that outside activities are performed in compliance with all legal and 

ethics requirements.

NASA has issued an Agency-wide memorandum dated July 26, 2011, confirming the 

Agency’s support for NASA scientists, engineers, and all other NASA employees for 

whom such participation is an integral part of professional development to serve as 

society officers or board members, where appropriate, and summarizing the Agency’s 

processes for them to obtain approval for such service.

5. Allow Government scientists and engineers to receive honors and awards for their research 

and discoveries.

NASA is committed to allowing its scientists and engineers to receive honors and awards for 

their research and discoveries:

Consistent with 5 CFR 2635.204(d), NASA civil servant scientists and engineers may 

receive honors and awards from outside entities for their research and discoveries.

The Agency also makes full use of the Government Employees Incentive Awards Act, 5 

U.S.C. §§ 4501 et seq., to recognize superior accomplishments of its scientists and 

engineers.
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Appendix – List of Acronyms

CFR Code of Federal Regulations

FAC Federal Advisory Committee

FACA Federal Advisory Committee Act

GSA General Services Administration

HRP Human Research Program

IPA Intergovernmental Personnel Act

NASA National Aeronautics and Space Administration

NPD NASA Policy Directive 

NPR NASA Procedural Requirements

OSTP Office of Science and Technology Policy

P.L. Public Law

SPD Science Mission Directorate Policy Document

U.S.C. United States Code