30
Mar2020

In 2015, NIH solicited public input on an agency-wide strategic plan framework for the subsequent five years in response to a request from Congress in anticipation of increased NIH funding. That feedback contributed to the creation of what would become the NIH-Wide Strategic Plan, Fiscal Years 2016–2020: Turning Discovery Into Health. That plan focused on “advancing opportunities in biomedical research,” priority-setting, and stewardship, among other areas.

Now, as that plan is set to come to a close at the end of this year, NIH has asked for comment on its next set of planning priorities: Inviting Comments and Suggestions on a Framework for the NIH-Wide Strategic Plan for FYs 2021-2025. The framework, which will be used to build out a full strategic plan, outlines five cross-cutting themes and three broad objectives for the NIH over the next five years, and NIH is seeking public comment (by April 1) on their strength as agency guideposts for the next half-decade. Earlier this week, PRIM&R submitted comments to NIH on the plan framework. You can read them in full here (PDF).

PRIM&R is generally very pleased with the breadth and aims of the framework. The framework’s third objective, which emphasizes integrity, accountability, and social responsibility in the conduct of science, demonstrates NIH’s clear commitment to the idea that good science is responsible science. This is a welcome development, in light of PRIM&R’s comments on the 2015 plan (PDF), which urged the agency to “emphasize the centrality that ethics plays in the research enterprise.” And while we commend this commitment, we suggest there are a number of ways that NIH refine some of its ideas in developing the full strategic plan.

One way is to clarify what the Agency means by “a culture of good scientific stewardship.” Presumably, this includes the attitudes and practices that foster responsible stewardship of the resources required to conduct good science. As such, the plan should articulate an explicit commitment to the protection of the rights, interests, and welfare of the human beings who contribute their selves, their bodies, and, increasingly, their data to the advancement of science.

Data is now one of the most valuable contributions a participant can make to science. The NIH should acknowledge this reality by explicitly including the stewardship of data as an element of good scientific stewardship. The full Strategic Plan should commit to responsible, respectful use and handling of participant-contributed data.

We also urge NIH to make clear that fostering a culture of good scientific stewardship intersects with ongoing efforts to advance rigor and reproducibility in preclinical research involving animals and animal models, while maintaining the highest standards of animal welfare.

Finally, we hope the framework’s cross-cutting theme of “promoting collaborative science” includes not just scientists collaborating with other scientists, but also oversight bodies, the public, and research participants. Partnerships with these other groups are crucial to driving science forward. The scientific enterprise will not succeed or advance without the trust of the public, as consumers of, funders for, and potential participants in, that endeavor. To that end, we urge NIH in further iterations of its strategic plan to make clear that accountability is not only to the principles of good science but also too the populations whom science is meant to serve and on whom it relies.

We encourage you to submit comment before the due date of April 1. You are welcome to use some or all of our language or thinking in your response. For directions on how to submit comments, see the Request for Information here

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