January 28, 2020

Chloe Kontos
Executive Director
Joint Committee on the Research Environment
National Science and Technology Council
Office of Science and Technology Policy
The White House
Via: JCORE@ostp.eop.gov

RE: Comments in Response to Request for Information on the American Research Environment

Dear Ms. Kontos:

Thank you for the opportunity to provide comments on the American Research Environment. The following recommendations from the American Institute of Biological Sciences primarily relate to the request for information about enhancing research rigor and integrity.

The American Institute of Biological Sciences is a non-profit professional society promoting informed decision-making that advances the biological sciences for the benefit of science and society. Our members include more than 130 scientific societies, research centers, and related organizations representing the breadth of the biological sciences. The collective membership of our community exceeds 100,000 individuals.

We appreciate the committee's interest in identifying opportunities for federal agencies to work in partnership with the broader research community to strengthen the rigor and integrity of research while recognizing the need for discipline-specific flexibility. The importance of flexibility cannot be understated. In addition to cultural differences among fields, it is imperative to remain cognizant that financial resources and community infrastructure vary greatly across the sciences and within different fields of study. One-size-fits-all solutions often cause disproportionate and irrevocable harm to smaller fields. A government mandate for immediate open access to scientific articles, for instance, is an example of a one-size-fits-all mandate that jeopardizes the sustainability of smaller professional communities and scientific journals. Policies that threaten the viability of these publications weaken scientific rigor and integrity.

A concern of many editors and society journal publishers is that open access mandates may necessitate a transition to a business model driven by volume rather than quality. In an immediate open access environment, organizations may be forced to compete to publish a high volume of articles to secure adequate page charges to support the operations of the publication. In essence, this model is akin to vanity publishing - those with resources can find a location for even a poor quality or flawed research study, because some publication will need the financial resources resulting from publishing the questionable article. This will weaken the scientific enterprise and cause consumers of scientific information, including the general public, to question the quality and integrity of all research. Thus, to promote research quality, integrity, and rigor, the federal government must refrain from changing its current open access policy to one requiring immediate open access for all federally-funded research. The free market is already working to identify sustainable solutions for increasing public access to research findings. Please permit the market to solve this problem.

Peer- or merit- review of research is critical to evaluating research protocols, quality, and reproducibility. The peer-review process is sustained by vibrant professional societies. With additional training, which is possible via professional societies, peer reviewers can play a more integral role in evaluating the ethical dimensions of research. Given the increasingly global nature of science, there is a need for new training related to bias. Federal agencies can help to strengthen the peer-review process by supporting new research on best practices in peer-review and by providing grants and contracts to professional communities to enable them to implement best practices and to provide peer-review training to their communities.

Importantly, as the American Institute of Biological Sciences learned during a 2016 meeting it organized of professional society leaders, publishers, scholars of peer-review, and other researchers, the peer review system, particularly as it relates to scholarly publishing, is under stress (https://doi.org/10.1093/biosci/bix034). Among the threats identified is an increase in the number of predatory journals, the increased frequency of requests of scientists to review manuscripts, and the growth of interdisciplinary research that strains the capacity of peer-reviewers (including reviewers of research proposals). There are also growing challenges for journal editors to secure a full complement of reviewers for articles. The federal government can provide valuable leadership in efforts to strengthen and sustain the peer review system by working with professional societies and academic research organizations to incentivize and reward scientists who actively contribute to our peer review system. As we have repeatedly heard from members of our community, academic institutions do not reward professional community service in the same way they did a few decades ago. Consequently, individual scientists - particularly early career scientists - are reluctant to allocate much time to the peer-review of scientific manuscripts (or other professional community service). This biases science because fewer early career researchers contribute to the process.

As exemplified by Extending U.S. Biodiversity Collections for Research and Education (https://bcon.aibs.org/wp-content/uploads/2019/04/BCoN_March2019_FINAL.pdf and https://doi.org/10.1093/biosci/biz140), a community-informed call to action issued by the Biodiversity Collections Network, access to data and data integration offer new opportunities to advance science as well as to provide linkages to the physical specimens needed to validate or reproduce biological research. To further increase the rigor and quality of biological research, the federal government should work with domestic data centers and aggregators to support the development of best practices in data curation, care, and use.

The U.S. science community needs the federal government to negotiate and support the implementation of international agreements that support the global exchange of scientific data, such as genetic sequence data, physical specimens, and digital data. Our ability to advance research, prevent and respond to pandemics or other public health problems, sustain biodiversity and ecosystem services, and identify new products that contribute to the bioeconomy requires international data exchange.

Thank you for your efforts to strengthen the American research environment and your consideration of these recommendations. The American Institute of Biological Sciences welcomes future opportunities to work with your committee or other agencies on these matters. Please do not hesitate to contact me at (202) 628-1500 x 250 if you have any questions or require additional information.

Sincerely,

Robert Gropp, Ph.D.
Executive Director

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