On June 28, 2021, the White House Office of Science and Technology Policy issued a “Request for Information to Improve Federal Scientific Integrity Policies.” The Association of Research Libraries (ARL) is pleased to offer the following comments in response to this request.
Association of Research Libraries Comments on US Office of Science and Technology Policy Request
for Information to Improve Federal Scientific Integrity Policies
July 28, 2021
The Association of Research Libraries (ARL) thanks the US Office of Science and Technology Policy (OSTP) for the opportunity to submit comments on improving federal scientific integrity policies. ARL is a nonprofit membership organization of 125 research libraries in the United States and Canada whose mission is to advance research and learning through equitable, enduring, and barrier-free access to information.
Our member libraries, which include academic libraries along with federal and large public libraries, are key stakeholders and infrastructure partners in building a culture of evidence within the US scientific enterprise. With a long-term commitment to equity, data and information curation, discovery, and stewardship, research libraries promote standards and policies for persistence, provenance, and authority necessary to maintain trust in science. These comments mainly address specific data and information management practices that improve discovery, interoperability, and long-term access which contribute to trust in scientific research. They also align with Executive Order 13985 on “Advancing Racial Equity and Support for Underserved Communities through the Federal Government.”1
ARL represents its membership as stakeholders in engaging with US federal agencies as they develop policies and plans to improve scientific integrity. Our member libraries are often instrumental in engaging their local communities as institutional constituents and partners in research. And within their institutions, research libraries also teach and support practices to advance rigor and reproducibility in scientific research. Research libraries are key infrastructure partners in building a culture of evidence in US scientific research.
I. The effectiveness of Federal scientific integrity policies in promoting trust in Federal science
ARL applauds the work of OSTP and federal agencies in the development and implementation of policies to promote trust in federally funded science. OSTP has been instrumental in promoting policies and practices to advance scientific integrity, including the 2013 memo on “Expanding Public Access to the Results of Federally Funded Research”2 and the 2009 presidential memo on “Scientific Integrity.”3 These directives have strengthened federal funding policies, ultimately increasing the availability of open data, software, and code. Additionally, the work of OSTP on “Desirable Characteristics of Repositories for Managing and Sharing Data Resulting from Federally Funded Research”4 surfaced critical criteria for ensuring that locations where data is shared are sustainable and reputable.
II. Effective policies and practices Federal agencies could adopt to improve the communication of scientific and technological information
Scientific advancements come from research that is repeatedly tested and made available for further analysis. To accelerate this process, ARL further recommends that federal agencies consider the following practices to expand access, enhance scientific integrity, and increase trust in research. Where practicable, ARL recommends harmonization of policies across agencies to minimize compliance burdens on investigators and research institutions.
- Making research outputs publicly available as soon as possible: ARL is pleased to see the Biden-Harris Administration state its commitment5 to make the results of federally funded research available and useful for the public, industry, and the scientific community in a timely manner. To demonstrate the utility and necessity of the federal public access plans required by the 2013 OSTP memo, and the role of these plans in the scientific enterprise, OSTP may wish to collaborate with federal agencies to gather data on the budgetary impact of federal public access policies, and how these policies advance research on key challenges such as health, climate change, and social inequality. ARL has recently received funding from the National Science Foundation to work with a group of institutions and disciplines on functional cost models for making research data publicly accessible.
- Address racial inequity and disparity in science communication: Work with publishers, scholarly societies, and others pledging to combat racism in science, building on the recognition by OSTP6 and the National Academies of Sciences, Engineering, and Medicine7 that pervasive sexual harassment poses a threat to scientific integrity.
- Stakeholder engagement: Stakeholders in developing data access and sharing arrangements should include individuals or groups whose data is being collected.
Invest in machine-actionable data management plans (maDMPs) and the broad adoption of persistent identifiers (PIDs). A recent ARL report on Implementing Effective Data Practices8 articulated the following considerations for funding agencies:
- Develop systems to generate automatic updates to a DMP using the PID knowledge graph.
- Provide model maDMPs for researchers that incorporate PID infrastructure as a means of demonstrating the new connections made possible with the addition of identifiers.
- Require researchers and/or research offices to enable appropriate sharing of the content of DMPs. While consideration for sensitive information and/or intellectual property would need to be established, this transparency facilitates compliance and adherence with best practices and could be based on adoption of the Research Data Alliance Recommendations for FAIR DMPs.9
- Require publishers that receive funding and/or article processing charges to declare the funder ID and/or grant ID for the funding organization in all published articles. This connection will ensure that the results from the funding are publicly available.
- Require and facilitate the use of ORCID iDs, ROR IDs, grant IDs, DOIs, and funder IDs in all grant applications and reporting, as appropriate and to the extent possible.
- Implement pilot projects within the funding organization that use the connections made in maDMPs and PIDs. Through these exploratory projects all funders can learn how to build custom implementations and the community can further develop use cases.
- Invest in continuing support, including through partnerships with institutions and scientific societies, for open PID and DMP infrastructure for sustainability purposes.
- Join membership-supported organizations providing infrastructure, tools, and services essential to research activity, research data, and researchers themselves. Examples include Crossref, DataCite and ORCID.
- Promote the creation and adoption of common data elements. The National Library of Medicine and community organizations have developed or begun developing common data elements to describe and make data variables interoperable.
- Support the curation of research outputs. While the sharing of research outputs is a good first step to ensure research integrity, making research output Findable, Accessible, Interoperable, and Reusable (FAIR) is the next step to improve the integrity of research across the board. ARL recommends that OSTP direct federal funding agencies to create new policies and practices to make funded research outputs FAIR.
- Clearly delineate peer review status in object metadata. This applies to articles, data, software, and code.
- Clarify copyright status. To reduce uncertainty about how US federal government information may be used, label works that are not eligible for copyright protection and are therefore in the public domain according to Section105(a) of the US Copyright Act with statements on the rights of the authors and the users of these works. Consider the new copyright rights statement by the US Government Publishing Office (GPO) that will be added to the metadata for new and existing content.10
Rigor and Reproducibility
- Create more specific funding calls for meta-research, systematic reviews, and/or replication studies. Health science librarians and library staff often collaborate with faculty to identify relevant citations and studies for inclusion in these types of research.
- Require registered reports to improve research quality. Registered reports review the research approach as well as complete a peer review of the research prior to the research outcomes being completed.11 Research has shown the use of registered reports reduces bias and selective reporting in manuscripts.
- Normalize the creation and sharing of research protocols. Platforms such as Protocols.io allow the discovery, reuse, and annotation of research methods and workflows. Library staff often provide training and best practices on the use of research tools such as this.
Sustainability and capacity-building
- Align policies, practices, and funding. ARL recommends that federal agencies strongly align research integrity policies and practices with sustainable and capacity-building funding mechanisms. Libraries and institutions have invested a significant amount of resources in infrastructure and services to support faculty on academic campuses and in national laboratories to meet existing policies and practices, but any additional federal requirements from federal agencies should include financial support.
- Consider equity among institutions in all new policies and practices. Any new policies and practices put in place by federal agencies should consider downstream effects on institutions, especially where the requirements may place additional financial or infrastructure burdens. While some institutions may more easily support these new requirements and build infrastructure, for others it will be a considerable burden that will create additional inequities in the scientific enterprise. Policies should include mechanisms for inter-institutional partnerships or networks to build capacity, building consensus around best practices for requirements.
III. Effective policies and practices Federal agencies could adopt to address scientific issues and the scientific workforce
- Engage universities and the research community around security concerns. Basic, fundamental research, including emerging technologies such as artificial intelligence, is the engine of scientific innovation, and international collaboration is essential to meet global challenges. OSTP and federal agencies should work with university research officers, IT, and libraries to strengthen existing security practices while promoting expansive and timely access to fundamental research.
Further promote the use of ethical research sharing. Just because data or information can legally be shared, doesn’t mean it should be. Libraries and library staff are key partners with research offices and sponsored projects to convey policies and instruct on research practices. ARL recommends that:
- The “CARE Principles for Indigenous Data Governance”12 and other similar protocols for ethical partnerships with study groups should be more broadly adopted across federal agencies.
- OSTP develops policies for federal agencies and funding recipients to engage stakeholders in developing data access and sharing arrangements that also include individuals or groups whose data is being collected.
- Stakeholders also be included in developing data governance plans and discussions of which data sets to publish.
IV. Effective practices Federal agencies could adopt to improve training of scientific staff about scientific integrity and the transparency into their scientific integrity practices
- ARL suggests that OSTP prioritize the upskilling of early career researchers, graduate students, and undergraduates in these areas, with a particular focus on historically underrepresented populations.
Thank you for your consideration of these comments.
Mary Lee Kennedy
Association of Research Libraries
2 “Expanding Public Access to the Results of Federally Funded Research,” the website of the White House, President Barack Obama (archived), February 22, 2013, https://obamawhitehouse.archives.gov/blog/2013/02/22/expanding-public-access-results-federally-funded-research.
3 “Memorandum for the Heads of Executive Departments and Agencies 3-9-09,” the website of the White House, President Barack Obama (archived), March 9, 2009, https://obamawhitehouse.archives.gov/the-press-office/memorandum-heads-executive-departments-and-agencies-3-9-09.
4 “Request for Public Comment on Draft Desirable Characteristics of Repositories for Managing and Sharing Data Resulting from Federally Funded Research,” 85 FR 3085 (Jan. 17, 2020), https://www.federalregister.gov/documents/2020/01/17/2020-00689/request-for-public-comment-on-draft-desirable-characteristics-of-repositories-for-managing-and.
5 “Memorandum on Restoring Trust in Government through Scientific Integrity and Evidence-Based Policymaking,” the website of the White House, January 27, 2021, https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/27/memorandum-on-restoring-trust-in-government-through-scientific-integrity-and-evidence-based-policymaking/.
6 Testimony on the President’s FY 2021 Budget Request for Research & Development, Before the Committee on Science, Space, and Technology, 116th Cong. (February 27, 2020) (statement of Dr. Kelvin Droegemeier, director of the Office of Science and Technology Policy, Executive Office of the President of the United States), https://science.house.gov/imo/media/doc/Droegemeier%20Testimony1.pdf.
7, “Sexual Harassment in Academic Science, Engineering, and Medicine,” National Academies of Sciences, Engineering, and Medicine, accessed July 28, 2021, https://www.nationalacademies.org/our-work/sexual-harassment-in-academia.
8 John Chodacki et al., Implementing Effective Data Practices: Stakeholder Recommendations for Collaborative Research Support (Washington, DC: Association of Research Libraries, September 2020), https://doi.org/10.29242/report.effectivedatapractices2020.
9 “Draft Recommendations,” Research Data Alliance Exposing Data Management Plans Working Group, accessed July 27, 2021, https://docs.google.com/forms/d/e/1FAIpQLSd-FKrKmXP1XZw4SI_kEbVlr2TiXQvKAYnEZTyXC-Csd18q8A/viewform.
10 “Release Notes: Congressional Serial Set Development, Bibliographic Citation Generator, API USCOURTS Parameter Enhancements, Additional Citation Search Patterns for Congressional Reports,” govinfo, July 13, 2021, https://www.govinfo.gov/features/june-2021-release-notes.
11 Courtney K. Soderberg et al., “Initial Evidence of Research Quality of Registered Reports Compared with the Standard Publishing Model,” Nature Human Behavior (2021), https://doi.org/10.1038/s41562-021-01142-4.
12 Research Data Alliance International Indigenous Data Sovereignty Interest Group, “CARE Principles for Indigenous Data Governance,” Global Indigenous Data Alliance, September 2019, https://www.gida-global.org/care.
About the Association of Research Libraries
The Association of Research Libraries (ARL) is a nonprofit organization of 125 research libraries in Canada and the US whose mission is to advance research, learning, and scholarly communication. The Association fosters the open exchange of ideas and expertise; advances diversity, equity, and inclusion; and pursues advocacy and public policy efforts that reflect the values of the library, scholarly, and higher education communities. ARL forges partnerships and catalyzes the collective efforts of research libraries to enable knowledge creation and to achieve enduring and barrier-free access to information. ARL is on the web at ARL.org.