Federal Research: Agency Actions Could Strengthen Scientific Integrity Policies
Released: 2019-07-17T00:00:00

Letter

Selected Agencies Have Scientific Integrity Policies That Are Generally Consistent with Federal Guidance

In our April 2019 report, we found that all nine of the selected agencies have policies that are generally consistent with OSTP’s guidance for the principles of scientific integrity that we reviewed: foundations of scientific integrity in government and professional development of government scientists and engineers. OSTP’s guidance describes several components for each of these principles, which the selected agencies addressed either (1) through their scientific integrity policies, (2) in related policies, or (3) through related actions. For example, when addressing the components of foundations of scientific integrity in government, NOAA’s scientific integrity policy states that the agency will ensure the free flow of scientific information online and in other formats, consistent with privacy and classification standards, and in keeping with other Commerce and NOAA policies. In another example, NASA’s scientific integrity policy states that NASA facilitates the free flow of scientific and technological information among scientists and engineers, between NASA staff and the scientific and technical community, and between NASA employees and the public. The policy goes on to cite additional NASA policies on dissemination of information and public access to data.

Similarly, we found that all nine selected agencies addressed all of the components of the principle professional development of government scientists and engineers. For example, EPA’s policy states that the agency encourages publication and presentation of research findings in peer-reviewed, professional, or scholarly journals and at professional meetings. NIST’s scientific integrity policy states that the agency supports scientists’ full participation in professional or scholarly societies, committees, task forces, and other specialized bodies of professional societies, with proper legal review and approval. The policy goes on to cite separate NIST guidance for staff on how to seek approval for memberships and participation in professional organizations.

All of the Selected Agencies Took Some Action to Achieve Policy Objectives, but Opportunities Exist for Furthering Those Objectives

We found in our April 2019 report that the nine selected agencies have taken some actions to help achieve the objectives of their scientific integrity policies in the three areas we reviewed—communicating information to staff, providing oversight, and monitoring and evaluating performance.

First, according to our analysis, seven of the nine selected agencies have taken some actions to educate and communicate to staff about their scientific integrity policies, and two have not. Specifically, FE and NIST have not provided scientific integrity training for staff, according to officials, or taken other actions to promote their scientific integrity policies with staff. Under the 2007 America COMPETES Act, civilian agencies that conduct scientific research are, among other things, required to widely communicate and readily make accessible to all employees their scientific integrity policies and procedures. According to FE and NIST officials, the agencies made their policies available to staff on their websites and believed no additional actions were needed. By taking action to educate and communicate their scientific integrity policies to staff through, for example, regular training, these agencies would have better assurance that employees have the information, skills, and competencies they need to help achieve agency scientific integrity objectives. We recommended the Secretary of Energy and Director of NIST take action to educate and communicate the agencies’ polices to staff through, for example, regular training. In DOE’s written comments on a draft of our report, reproduced in our final report, the department explained that it will designate a scientific integrity official to be responsible for leading and coordinating with other offices across DOE to develop measures to educate and communicate to staff about scientific integrity policies. In Commerce’s written comments, reproduced in in our final report, NIST identified ways it plans to provide training to its staff.

Second, we found that eight of the nine selected agencies have designated scientific integrity officials, or the equivalent, who are responsible for overseeing the agencies’ implementation of their scientific integrity policies. FE, which follows DOE’s policy, does not have a scientific integrity official or the equivalent. DOE’s scientific integrity policy states that the Secretary of Energy will designate a scientific integrity official for the department. DOE officials explained that the scientific integrity official has not been designated because the scientific integrity policy was implemented in January 2017, as the administration was changing, and that the current Secretary has not yet designated a scientific integrity official. We recommended the Secretary of Energy should establish steps and a time frame for designating a scientific integrity official to oversee the department’s scientific integrity activities. In DOE’s written comments on a draft of our report, reproduced in our final report, the department concurred with our recommendation and estimated that it would address the recommendation by the end of 2019.

Third, we found in our April 2019 report that four of the nine selected agencies—ARS, EPA, NASA, and NIH—monitor and evaluate the performance of their activities under their scientific integrity policies, or have plans to do so. The remaining five agencies—FAA, FE, NIST, NOAA, and USGS—have, for different reasons, not done so. Standards for Internal Control in the Federal Government states that management should design control activities to achieve objectives and respond to risks, which may include establishing activities to monitor performance measures and indicators. By establishing mechanisms to effectively monitor the implementation of their scientific integrity policies, agencies may be better positioned to evaluate and measure whether their scientific integrity policies are achieving their objectives and, where necessary, improve their implementation.

We recommended in our April 2019 report that the five agencies develop mechanisms to regularly monitor and evaluate implementation of their scientific integrity policies, including mechanisms to remediate identified deficiencies and make improvements where necessary. All five agencies agreed with our recommendation and responded as follows: In a May 2019 letter from DOT, the department identified several mechanisms it plans to implement by the end of March 2020.

In DOE’s written comments on a draft of our report, the department said that its scientific integrity official will have the responsibility to lead in developing procedures to monitor and evaluate implementation of DOE’s policy.

In Commerce’s written comments, NIST stated that, beginning in fiscal year 2019, the agency will review implementation of its policy at least annually and make recommendations to the Director of NIST as to whether any improvements are needed.

In Commerce’s written comments, NOAA stated that it will identify additional metrics for monitoring and evaluating its policy.

The Department of the Interior’s written comments stated that the department plans to implement a biennial scientific integrity survey of USGS employees, beginning in 2020, to gauge scientific integrity policy awareness and effectiveness at USGS, among other things.

Most of the Selected Agencies Have Procedures for Addressing Alleged Violations of Scientific Integrity Policies, but Two Do Not, Raising Questions about the Consistency of Their Investigations

Seven of the nine selected agencies—ARS, EPA, FAA, NIH, NIST, NOAA, and USGS—have specific, documented procedures for identifying and addressing alleged violations of their scientific integrity policies. Although the details of agencies’ procedures may vary, the procedures generally include five basic steps: (1) report allegation, (2) screen allegation, (3) investigate allegation, (4) respond to violation, and (5) appeal decision (see fig. 1).

In contrast, two of the nine selected agencies—FE and NASA—do not have specific, documented procedures for identifying and addressing alleged violations of their scientific integrity policies. In March 2009, the President issued a memorandum on scientific integrity that states that 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. FE, which follows DOE’s scientific integrity policy, does not have specific procedures because DOE has not established any. DOE and FE officials said staff can report allegations to a supervisor, the whistleblower ombudsperson, or the U.S. Office of Special Counsel (OSC). Similarly, NASA officials said employees can report allegations through their chain of command, such as to a supervisor, for investigation on a case-by-case basis. However, without documented procedures for identifying and addressing alleged violations of their scientific integrity policies, DOE and NASA do not have assurance that all staff have a clear understanding of how to report allegations and that investigations will be conducted consistently.

We recommended the Secretary of Energy and Administrator of NASA develop documented procedures for identifying and addressing alleged violations of their scientific integrity policies. In DOE’s written comments on a draft of our report, the department stated that it will be the responsibility of the scientific integrity official to lead, and coordinate with other elements of the department, in developing procedures for identifying and addressing alleged violations of its scientific integrity policy and estimated completing actions in June 2020. In written comments from NASA, the agency stated that it will develop documented procedures for identifying and addressing alleged violations of its policy and estimated completion by October 2020.

Chairwoman Stevens and Chairwoman Sherrill, Ranking Member Baird and Ranking Member Norman, and Members of the Subcommittees, this concludes my prepared statement. I would be pleased to respond to any questions that you may have at this time.

GAO Contact and Staff Acknowledgments

If you or your staff have any questions about this statement, please contact John Neumann, Managing Director, Science, Technology Assessment, and Analytics, at (202) 512-6888 or neumannj@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this statement. GAO staff who made key contributions to this testimony are Rob Marek (Assistant Director), Wyatt R. Hundrup (Analyst in Charge), Cheryl Harris, and Douglas G. Hunker. Also contributing to this testimony were Eric Charles and Ben Shouse. Additional staff who made contributions to our April 2019 report are identified in that report.

This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately.