Restoring Gold Standard Science

5/23/2025

Action Summary

  • Purpose and Rationale:
    • Restore public trust in science by addressing a perceived reproducibility crisis and past misuse/misrepresentation of scientific evidence in federal policy.
    • Citing high-profile cases (e.g., COVID-19 reopening guidelines, North Atlantic right whale projections, and misuse of RCP 8.5 in climate assessments) to argue for science reform.
  • Restoring Gold Standard Science:
    • Define a “Gold Standard” for federally funded research: reproducible, transparent, communicative of uncertainties, collaborative, and subject to unbiased peer review.
    • Mandate the OSTP Director to issue guidance within 30 days, with agencies updating their scientific integrity policies accordingly.
    • Agencies must integrate this guidance into their decision-making and report implementation progress within 60 days.
  • Improving Use and Communication of Scientific Data:
    • Directs timely public disclosure of influential scientific data, models, and analyses, except where legally restricted.
    • Requires transparent communication of uncertainties and assumptions in agency analyses.
    • Stipulates that a “weight of scientific evidence” approach be applied in evaluations.
  • Interim Scientific Integrity Policies:
    • Requires agencies to revert to pre-January 2021 scientific integrity standards until updated policies are established.
    • Mandates the revocation of changes made between January 20, 2021, and January 20, 2025 that conflict with this order.
    • Encourages open exchange of ideas and protection of dissenting scientific views.
  • Scope and Applicability:
    • Applies to all federal employees engaged in generating, using, interpreting, or communicating scientific information.
    • Obligates agency contractors to adhere to these standards where practicable.
  • Enforcement and Oversight:
    • Each agency head must establish internal processes, led by a senior appointee, for evaluating and addressing violations.
    • These processes serve as the sole mechanism for oversight regarding scientific data management practices.
  • Waivers and General Provisions:
    • Agency heads may request waivers for good cause in consultation with the OMB and OSTP Directors.
    • Clarifies that the order does not impair the statutory authority of agencies or create enforceable rights against the government.
    • Implementation is subject to applicable law and funding availability.

Risks & Considerations

  • The Executive Order emphasizes restoring scientific integrity and transparency, which could lead to increased scrutiny of federally funded research. This may require Vanderbilt University to ensure that its research practices align with the new standards of reproducibility, transparency, and unbiased peer review.
  • There is a risk that the focus on “Gold Standard Science” could lead to increased administrative burdens for researchers, as they may need to provide more detailed documentation and transparency in their methodologies and data.
  • The order’s emphasis on avoiding scientific misconduct and ensuring data transparency may necessitate additional training and resources for Vanderbilt’s research community to comply with these new requirements.
  • Vanderbilt University may need to reassess its partnerships and collaborations with federal agencies to ensure alignment with the new scientific integrity policies, potentially affecting ongoing and future research projects.

Impacted Programs

  • Vanderbilt’s Research Administration will need to review and potentially update its policies and procedures to ensure compliance with the new federal guidelines on scientific integrity and transparency.
  • STEM Departments at Vanderbilt may experience increased demand for training and support in implementing the new standards of reproducibility and transparency in their research practices.
  • The Office of Sponsored Programs might need to adjust its grant application processes to align with the new requirements for data transparency and scientific integrity.
  • Vanderbilt’s Ethics and Compliance Office could play a crucial role in ensuring that researchers adhere to the new standards and avoid scientific misconduct.

Financial Impact

  • The increased emphasis on scientific integrity and transparency may lead to additional costs for Vanderbilt University in terms of training, compliance, and administrative support.
  • Vanderbilt might experience changes in its funding opportunities, particularly if federal grants prioritize projects that demonstrate adherence to the new “Gold Standard Science” criteria.
  • There may be opportunities for Vanderbilt to secure funding for research initiatives that align with the new federal priorities on scientific integrity and transparency.
  • The university may need to invest in new technologies or systems to support data transparency and reproducibility in research, potentially impacting its budget and resource allocation.

Relevance Score: 4 (The order presents a need for potential major changes or transformations of research practices and compliance requirements.)

Key Actions

  • Vanderbilt’s Research Administration should ensure compliance with the new “Gold Standard Science” guidelines by reviewing and updating internal research policies to align with federal requirements for transparency, reproducibility, and unbiased peer review. This will help maintain the integrity and credibility of research conducted at the university.
  • The Office of Federal Relations should actively engage with federal agencies to understand the implications of the executive order on current and future research funding. By staying informed, Vanderbilt can better position itself to secure funding and influence policy decisions that affect its research initiatives.
  • Vanderbilt’s Science and Technology Departments should promote interdisciplinary collaboration and ensure that research methodologies are transparent and communicative of uncertainties. This will enhance the quality and impact of scientific findings and align with the executive order’s emphasis on rigorous and impactful research.
  • The Office of the Provost should establish a task force to evaluate the potential impacts of the executive order on academic programs and research activities. This proactive approach will help identify areas that require adjustments and ensure that the university remains compliant with federal guidelines.
  • Vanderbilt’s Legal and Compliance Office should review the university’s policies on scientific integrity and misconduct to ensure they are consistent with the new federal standards. This will help protect the university from potential legal and reputational risks associated with non-compliance.

Opportunities

  • The executive order presents an opportunity for Vanderbilt’s Research Centers to lead in developing best practices for scientific integrity and transparency. By setting high standards, Vanderbilt can enhance its reputation as a leader in ethical and impactful research.
  • Vanderbilt can capitalize on the emphasis on reproducibility and interdisciplinary collaboration by fostering partnerships with other institutions and industry leaders. This could lead to innovative research projects and increased funding opportunities.
  • The focus on transparent communication of scientific data offers an opportunity for Vanderbilt’s Communication and Public Relations Departments to develop strategies for effectively disseminating research findings to the public and policymakers, thereby enhancing the university’s influence and visibility.

Relevance Score: 4 (The order necessitates major process changes to ensure compliance with new federal research standards and to capitalize on opportunities for leadership in scientific integrity.)

Average Relevance Score: 4.2

Timeline for Implementation

  • Within 30 days from May 23, 2025: The OSTP Director, in consultation with agency heads, shall issue guidance for implementing Gold Standard Science, and agency heads and employees must adhere to the new rules for using, interpreting, and communicating scientific data.
  • Within 60 days of the publication of the OSTP Director’s guidance: Agency heads shall report to the OSTP Director on the actions taken to implement Gold Standard Science.

Relevance Score: 4

Impacted Government Organizations

  • Office of Science and Technology Policy (OSTP): The OSTP Director is mandated to issue guidance on implementing “Gold Standard Science” across federal agencies.
  • Office of Management and Budget (OMB): The OMB Director is involved in consulting on the guidance’s implementation and reviewing waiver requests.
  • Centers for Disease Control and Prevention (CDC): Cited as an example of an agency whose recent use and communication of scientific data affected public policy decisions during the COVID-19 pandemic.
  • National Marine Fisheries Service (NMFS): Referenced for its controversial application of worst-case scenario projections that impacted economic interests in the Maine lobster fishery.
  • All Federal Agencies Involved in Scientific Activities: This order applies broadly to every agency that generates, uses, or communicates scientific information, requiring adherence to enhanced scientific integrity policies.

Relevance Score: 5 (The directive applies across the entire government’s agencies involved in scientific activities.)

Responsible Officials

  • Director of the Office of Science and Technology Policy (OSTP Director) – Tasked with issuing guidance on “Gold Standard Science” and coordinating with agency heads.
  • Agency Heads – Responsible for updating agency policies, incorporating the OSTP guidance into their practices, reporting on implementation, and reverting prior changes inconsistent with this order.
  • Director of the Office of Management and Budget (OMB Director) – Involved in the consultation process for both updating agency policies and considering waiver requests.
  • Designated Senior Appointees – Appointed by agency heads to establish and oversee internal processes for investigating and addressing alleged violations of the order’s requirements.

Relevance Score: 4 (Directives significantly impact agency heads and senior appointees, who hold high-level decision-making authority within their respective agencies.)