On May 27, 2025, President Trump signed an Executive Order (EO) on “Restoring Gold Standard Science.” 90 Fed. Reg. 22601. The EO states that the Trump Administration “is committed to restoring a gold standard for science to ensure that federally funded research is transparent, rigorous, and impactful, and that Federal decisions are informed by the most credible, reliable, and impartial scientific evidence available.” The EO restores the scientific integrity policies of the first Trump Administration and “ensures that agencies practice data transparency, acknowledge relevant scientific uncertainties, are transparent about the assumptions and likelihood of scenarios used, approach scientific findings objectively, and communicate scientific data accurately.”
Restoring Gold Standard Science
The EO directs the Director of the White House Office of Science and Technology Policy (OSTP), in consultation with the heads of relevant agencies, to issue guidance within 30 days for agencies on implementing “Gold Standard Science” in the conduct and management of their respective scientific activities. The EO defines Gold Standard Science as science conducted in a manner that is reproducible; transparent; communicative of error and uncertainty; collaborative and interdisciplinary; skeptical of its findings and assumptions; structured for falsifiability of hypotheses; subject to unbiased peer review; accepting of negative results as positive outcomes; and without conflicts of interest. Once OSTP publishes the guidance, the EO directs each agency head to update promptly applicable agency policies governing the production and use of scientific information, including scientific integrity policies, to implement the OSTP Director’s guidance. Within 60 days of the publication of OSTP’s guidance, agency heads must report to the OSTP Director on the actions taken to implement Gold Standard Science at their agency.
Improving the Use, Interpretation, and Communication of Scientific Data
Within 30 days after the date of the EO, agency heads and employees must adhere to the following rules governing the use, interpretation, and communication of scientific data, unless otherwise provided by law:
- Employees shall not engage in scientific misconduct nor knowingly rely on information resulting from scientific misconduct;
- Except as prohibited by law, and consistent with relevant policies that protect national security or sensitive personal or confidential business information (CBI), agency heads shall in a timely manner and, to the extent practicable and within the agency’s authority;
- Make publicly available the following information within the agency’s possession:
- The data, analyses, and conclusions associated with scientific and technological information produced or used by the agency that the agency reasonably assesses will have a clear and substantial effect on important public policies or important private sector decisions (influential scientific information), including data cited in peer-reviewed literature; and
- The models and analyses (including the source code for such models) the agency used to generate such influential scientific information. The EO states that employees may not invoke exemption 5 to the Freedom of Information Act (FOIA) to prevent disclosure of such models unless authorized in writing to do so by the agency head following prior notice to the OSTP Director;
- The data, analyses, and conclusions associated with scientific and technological information produced or used by the agency that the agency reasonably assesses will have a clear and substantial effect on important public policies or important private sector decisions (influential scientific information), including data cited in peer-reviewed literature; and
- Risk models used to guide agency enforcement actions or select enforcement targets are not information that must be disclosed under this subsection;
- Make publicly available the following information within the agency’s possession:
- When using scientific information in agency decision-making, employees must transparently acknowledge and document uncertainties, including how uncertainty propagates throughout any models used in the analysis;
- Where employees produce or use scientific information to inform policy or legal determinations they must use science that comports with the legal standards applicable to those determinations, including when agencies evaluate the realistic or reasonably foreseeable effects of an action;
- Employees must be transparent about the likelihood of the assumptions and scenarios used. The EO states that “[h]ighly unlikely and overly precautionary assumptions and scenarios should only be relied upon in agency decision-making where required by law or otherwise pertinent to the agency’s action”;
- When scientific or technological information is used to inform agency evaluations and subsequent decision-making, employees shall apply a “weight of scientific evidence” approach;
- Employees’ communication of scientific information must be consistent with the results of the relevant analysis and evaluation and, to the extent that uncertainty is present, the degree of uncertainty should be communicated. The EO notes that “[c]ommunications involving a scientific model or information derived from a scientific model should include reference to any material assumptions that inform the model’s outputs”; and
- Once the guidance on Gold Standard Science is established and promulgated, it shall, among other things, form the basis for employees’ evaluation of all scientific and technological information called for in the EO except where otherwise required by law.
Interim Scientific Integrity Policies
Until the issuance of updated agency scientific integrity policies, the EO states that scientific integrity policies in each agency must be governed by the scientific integrity policies that existed within the executive branch on January 19, 2021. The EO directs agency heads to take all necessary actions to reevaluate and, where necessary, revise or rescind scientific integrity policies or procedures, or amendments to such policies or procedures, issued between January 20, 2021, and January 20, 2025. Under the EO, each agency head must promptly revoke any organizational or operational changes, designations, or documents that were issued or enacted pursuant to the Presidential Memorandum of January 27, 2021 (Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking), which was revoked pursuant to EO 14154 and shall conduct applicable agency operations in the manner and revert applicable agency organization to the same form as would have existed in the absence of such changes, designations, or documents.
In updating applicable scientific integrity policies, the EO directs agencies to ensure they:
- Encourage the open exchange of ideas;
- Provide for consideration of different or dissenting viewpoints; and
- Protect employees from efforts to prevent or deter consideration of alternative scientific opinions.
Agencies must review agency actions taken between January 20, 2021, and January 20, 2025, including regulations, guidance documents, policies, and scientific evaluations, and take all appropriate steps, consistent with law, to ensure alignment with the policies and requirements of the EO.
Scope and Applicability
The policies and rules set forth in the EO apply to all employees involved in the generation, use, interpretation, or communication of scientific information, regardless of job classification, and to all agency decision-making. Agency heads and employees must, to the extent practicable and consistent with applicable law, require agency contractors to adhere to these policies and rules as though they were agency employees. The EO’s policies and rules govern the use of science that informs agency decisions, but the EO notes that “they are not applicable to non-scientific aspects of agency decision-making.”
Enforcement and Oversight
The EO requires each agency head to establish internal processes to evaluate alleged violations of the requirements of the EO and other applicable agency policies governing the generation, use, interpretation, and communication of scientific information. Such processes will be the responsibility, and administered under the direction, of a senior appointee designated by the agency head and shall provide for taking appropriate measures to correct scientific information in response to violations, consistent with the requirements and procedures of Section 515 of the Information Quality Act (IQA). According to the EO, the designated senior appointee may also forward potential violations to the relevant human resources officials for discipline to the extent the potential violation also violates applicable agency policies and procedures. The designated senior appointee may consult appropriate officials with scientific expertise when establishing such processes.
Commentary
There is no serious disagreement with the idea of conducting and relying upon quality science. Quality science is non-partisan. The challenge is not with the goal, it is with defining “best available science” as, like so many qualitative terms, it is in the eye of the beholder. Too often, individuals rely on preferred science. It is human nature to be more open to data that confirm your perspective and less receptive to data that refute your view. Scientists must remain open to different views and different interpretations of data. Doing otherwise fundamentally undermines science.
The objection to “secret science” must also be carefully explored. It can be used to diminish the value of quality studies even though there are legitimate reasons for information in those studies to be maintained as confidential. Most would agree that individual identities in an epidemiological study, for example, are legitimately confidential based on individual privacy concerns. In a different case, the name of the sponsor that funded a study conducted according to Good Laboratory Practice (GLP) standards is not needed to evaluate the quality of the study. GLP protocols were established to minimize a study sponsor’s influence on the outcome or interpretation of a study. GLP protocols are arguably more protective of the best available science than peer review. One can reasonably assume that the sponsor of a GLP study has a financial interest in that study, so knowing the specific identity of the sponsor neither adds nor detracts from another’s interpretation of the study. If data are only valid if they align with your views, you are not relying on the best available science. We hope that the EO will be heeded by agencies and departments, and that decisions will be based on the best available science.
We, like many others, struggle with understanding a commitment to science with the Administration’s dramatic reduction in the executive branch’s scientific expertise. These are two realities difficult to rationalize. Can the goal be achieved when the means are undermined? Federal science agencies have been a bastion of outstanding science and scientists. Even if there are some examples of science generated by federal efforts (in-house or through contracts and grants) not perfectly meeting the standard of “best available science,” the solution can only be realized through better science.