Protecting Public Health Evidence in an Adversarial Environment

The ability of public health officials to share and act on evidence is a matter of life and death for the people they serve. Decisions made on credible evidence is critical to whether children are vaccinated, how schools and businesses react to a pandemic or other health emergency, or how people understand and make lifestyle choices. We can and should debate the implications of facts — but not the facts themselves. Especially during transitions.

Managing such political transitions at all levels of government is key to free-flowing science and information. I’ve participated in and witnessed many leadership transitions, at the federal agency level and across Presidential administrations, and each comes with its own challenges. This particular Presidential transition has caused more anxiety than any in my memory: a product of an election that brought cynicism about science and government to the fore, a 24-hour news cycle that provokes rather than clarifies, and a power vacuum with few key appointments made in science agencies.

Though Washington, DC is the main focus, we also have seven new governors and other key transitions at the local levels. In less than two years, 36 states will have gubernatorial elections. It’s important to realize that any scientific agency is only one change in leadership — to either party — away from having to revisit fundamental issues related to protecting science and evidence.

Challenges and Potential Red Flags

Every new Administration seeks to assert control of the communications channels from within an agency; no new official wants to be surprised, or contradicted, by communications from within their own agency. For this reason, and with few exceptions, press releases and public communications of agencies are reviewed and cleared by political appointees.

The real question isn’t whether an Administration has the right to review certain types of communications, but whether they will ultimately do the right thing and wield their authority in the public’s interest. There must be a bright line between 1) review of policy-related communications, and 2) interference with the underlying science and evidence generated by agencies. Put differently, the key question isn’t whether a scientific agency can independently tweet, but whether there is an effort to suppress or alter underlying scientific findings.

Many are on the lookout for signs that public health science (along with other data) is being subjected to unwarranted controls. Early warning signs to watch for include:

Funding cuts and restrictions. Budget reductions in the upcoming appropriations cycle, particularly if domestic spending cuts fall disproportionately on science, public health, or statistical activities, may be the first red flags. There’s no need to suppress or manipulate the release of information if research was never conducted and data never collected. Advocates for data resources available to the public are already sounding an alarm.

Federal agencies missing scheduled data releases. The CDC/NCHS has posted plans to release health insurance coverage estimates every quarter; similarly economic statistics are released on a predictable cycle.

Efforts to revise or suspend existing protections for release of statistical information. Take for example the Office of Management and Budget (OMB) Circulars. Protections were last published for comment in October 2016, but as Executive Branch guidance they could be further revised without action or input from Congress.

Key appointments that lack appreciation for the role of science and information. Two are particularly critical: the White House Science Advisor and the OMB’s Office of Information and Regulatory Affairs. The latter leads both statistical policy and regulatory policy across the federal government. These officials need to be strong advocates for open and transparent Federal science and data.

First Lines of Defense

Public health data isn’t without safeguards, though only few are built into law (and therefore subject to change by executive action). Among the most important protections:

The scientists themselves. The first line of defense against manipulation of evidence is the commitment of scientists to objectivity and the open sharing of results. Scientific principles value transparency and replicability of data which requires putting research data in the public domain.

The ethics of statistical agencies. Agencies like the CDC’s National Center for Health Statistics are part of a network of federal statistical agencies that generate data for decision-making in most sectors of society. These agencies prize transparency and impartiality — while stubbornly resisting outside influence. Protections for these agencies are built into guidelines issued by the OMB and include measures that establish standards for data quality and allow the release of data independent of political clearance.

Non-governmental associations and watchdogs. Professional associations and affiliates, like the Council of Professional Associations on Federal Statistics, serve as watchdogs for public access to information. They exert external pressure and keep governmental agencies accountable.

Professional standards. Many science and public health agencies, and the professions from which their staff are drawn, develop practices that make clear the difference between basic scientific information and policy pronouncements to avoid the perception that evidence itself is the product of a policy process.

What Public Health Officials Can Do

Clarity and credibility of public health information is critical. It is important that we pay attention at every level of government, and take steps like the following before transitions take place:

Model objectivity. Ensure that public health data is objective and bipartisan. Once public health surrenders this high ground, it is defenseless against politically-motivated officials who would seek to manipulate data for their own purposes. At the same time, public health advocates need to accept that the same set of facts may lead to different policy conclusions.

Make the case for independence. Help political appointees and elected officials understand importance of impartial, objective science, and emphasize the bipartisan nature of public health. Every administration needs to ensure that programs under their jurisdiction can attract the scientific talent needed to do their legislatively mandated work, regardless of policy position. Providers of data — hospitals, businesses, and individuals — won’t share critical data if it is viewed as subject to manipulation. Skilled analysts and researchers won’t work in an environment inconsistent with their training and professional ethics. It is in the long-term self-interest of any Administration to maintain the credibility of their science.

Promote transparency: This is a value in its own right, but also the best defense against charges of bias or manipulation. Make underlying data available in public use form, make transparent how data/evidence is gathered (including methods and analytic approaches), and be clear in how these are communicated.

Promote predictability of the timing of research findings. Signal in advance plans to do research and collect information, and make public a timetable for issuance of routine data series, establishing an expectation of release that would be noticed if not kept.

Formalize protections. Adopt formal protocols at state and local levels for protecting the integrity of public health data, like those that exist at the Federal level.

Thomas Jefferson wrote that information is the most certain and the most legitimate engine of government, and that freedom is the first-born daughter of science. We will only live up to this promise if we take steps to preserve the integrity of science and information.