Intramural Academic Freedom Guidance

Guidance for Scientific Publications and Communications from the NIH Intramural Research Program

This Academic Freedom guidance integrates existing longstanding NIH research communications processes with new practices under a single harmonized framework.

Background

Open debate is the cornerstone of scientific progress; interrogating evidence and challenging the status quo are essential for ensuring scientific rigor and meaningful results. Academic freedom is the ability to respectfully and openly express ideas, perspectives, and discordant views about scientific data and scholarly research without risk of official interference, professional disadvantage, or workplace retaliation. Many current policies support facets of academic freedom for NIH Intramural Research Program investigators, but this framework is intended to address gaps and harmonize best practices to ensure these policies are consistently implemented across the NIH.

Applicability

This framework applies to all NIH Intramural Research Program (IRP) researchers who are federal employees1. IRP researchers must be able to freely share their scientific expertise and to communicate their respective scientific findings through manuscripts, presentations, media interviews, etc., as part of their official duties.

New Practices

Manuscript Clearance Reviews Focus on Policy and Regulatory Compliance

The existing IRP manuscript and abstract clearance process on scientific publications and products, which includes perspectives and commentaries in scientific journals, was revised to enact a review process that focuses on NIH’s role as the institutional authority overseeing NIH-conducted research. Reviewers are not to serve as an additional layer of scientific review, but instead, ensure appropriate policy and regulatory reviews and/or compliance measures are included/described (including but not limited to human subject protections, animal study procedures, dual use or select agent research regulations, citation of NIH funding, data management and sharing requirements). This covers publications submitted as an official duty.

  • IRP manuscript authors must add the following disclaimer on scientific publications stating the contents do not represent views of NIH, HHS. This research was supported [in part] by the Intramural Research Program of the National Institutes of Health (NIH). The contributions of the NIH author(s) are considered Works of the United States Government. The findings and conclusions presented in this paper are those of the author(s) and do not necessarily reflect the views of the NIH or the U.S. Department of Health and Human Services.
  • The IRP manuscript clearance form has been updated to a manuscript review form that contains an additional field for certifying when NIH’s communications, policy, and/or legislative offices should be notified.

Media Inquiries

For the NIH Intramural Research Program, the process for responding to requests from the media has shifted from pre-clearance to notification and coordination. For more information, please review the Academic Freedom Implementation Guidance(external link). Per the implementation guidance, IRP researchers must:

  1. Submit the request via the designated NIH Intramural Media Request Form(external link). Required fields are marked with a red asterisk, including the following:
    • Researcher Name: Your name
    • NIH Email: Your email address
    • IC Name
    • Topic: A brief description of the topic of inquiry
    • Talking Points: 3-5 main points (2-3 sentences each, ideally) that will help frame your discussion on your research or topic of expertise
    • Reporter First Name, Last Name, Email
    • Media Outlet: Name of reporter’s employer (e.g., The New York Times, USA Today, NBC News, MedPageToday, etc.)
    • Title, Topic Summary
    • Original Request: Copy/paste the content of the email or describe the request you received from the reporter for reference and context for the NIH Press Team
    • Deadline: If the reporter provides a deadline, enter it here. If no deadline is provided, please select a minimum of 48 hours.
  2. Once form is submitted, wait for acknowledgement from the Media Relations Team. Do not confirm an interview or respond until the Media Relations Team has acknowledged your submission.
    • The Media Relations Team will share your notification with HHS ASPA as an FYI.
  3. Proceed with the interview/response once acknowledged.
    • When speaking with media, clarify that your comments reflect your research and may not reflect the views of the NIH, HHS, or the U.S. Government.
    • For proactive outreach to the media, consult with the Media Relations Team in advance.

Exceptions

Scientists may speak about their scientific findings and conclusions as part of their official duties but may not advise on the following areas without prior Agency approval: NIH program/policy priorities or strategies; NIH pre-deliberative discussions, judgments or positions; U.S. Government, HHS, or NIH policies; regulations with relevance to NIH; legislation with relevance to NIH; or implications for international collaborations or policy discussions. Additionally:

  • When scientific findings have legislative or policy implications, scientists must work with the NIH central offices [Office of Science Policy (OSP), Office of Legislative Policy and Analysis (OLPA)] to ascertain if/how to address.
  • Scientists must continue to follow established policies and practices through OLPA to engage with members of Congress as part of their official duties.

Scientists must follow existing policies (e.g., ethics, personal social media use) to communicate about their science in their personal capacity.

Ethical Considerations

IRP researchers may have real or perceived conflicts of interest (COIs) in their communications. In these instances, full disclosure and complete transparency is always the best policy. The NIH Ethics Program has specific policies and rules concerning COIs, outside activities (such as consulting and speaking), gifts, etc., which IRP researchers must follow.

Reporting Concerns and Allegations

Scientists must be able to respectfully and openly express ideas, perspectives, and discordant views about scientific data and scholarly research without risk of official interference, professional disadvantage, or workplace retaliation. Open scientific debate and disagreement are expected. Differences in perspective and interpretation do not on their own equate to misconduct. Staff should report allegations related to the suppression of academic freedom to the Deputy Director for Intramural Research. Appeals will be taken to the NIH Principal Deputy Director.

For allegations related to whistleblowing, misconduct, etc., staff should report through the appropriate channels as outlined in the below resources.

Policies and Resources2

Publications

Media

Ethics, Integrity, Oversight

Allegations

1 When relevant, NIH has separate policies for non-federal employees to uphold the principles of academic freedom while carrying out activities on behalf of NIH.
2 These resources include existing relevant policies NIH employees are subject to, but this is not an exhaustive list.