Michelle Crosby, ASA Science Policy Fellow, and Steve Pierson, ASA Director of Science Policy
Dating to the 1840 decennial census, the American Statistical Association has worked to safeguard the integrity and objectivity of the scientific process and government statistics, both of which are crucial for informed policymaking. To this end, the ASA has formally responded to the Office of Personnel Management’s proposed rule, Improving Performance, Accountability, and Responsiveness in the Civil Service. This proposed rule is a direct action based on President Donald Trump’s Executive Order 14171, Restoring Accountability to Policy-Influencing Positions Within the Federal Workforce, issued January 20. The OPM’s proposal would reclassify excepted service positions considered “policy-influencing”—defined as those with a “confidential, policy-determining, policy-making, or policy-advocating character”—into Schedule Policy/Career, previously termed Schedule F. According to the rule, the Schedule Policy/Career designations would “allow agencies to quickly remove employees from critical positions who engage in misconduct, perform poorly, or undermine the democratic process by intentionally subverting Presidential directives.”
Distinguishing the role of scientific and statistical agency positions from policy-informing functions, the ASA submission urges that explicit exceptions be made in the final rule for the following three categories of statistical and scientific positions: (i) all employees of federal statistical agencies, units, offices, and the OMB Office of the Chief Statistician; (ii) positions in research funding agencies and offices that carry out solicitations, oversee proposal reviews, and rank proposals after research funding priorities are determined; and (iii) positions in the federal government that evaluate and assess scientific findings and converge scientific evidence.
The ASA argues that blurring the lines between policy informing and policy-influencing would undermine the objectivity and accuracy of the statistics and science that are an important input to policymaking, which, in turn, could lead to substantial public harm, including loss of specialized talent; diminished international competitiveness; undermined public safety; and repercussions for policymaking, democracy, and economy,
The ASA’s justification for the exceptions is that the three categories of positions “are by design one or more steps removed from the policymaking process and provide one input among many to the policymaking process.” The ASA submission also explains that policy-informing refers to the process by which scientific evidence, research findings, and expert advice are provided to policymakers to help them understand complex issues, assess potential impacts, and explore various options. The response goes on to discuss the definitional and cultural, statutory mission, and procedural firewalls—if not outright legal prohibitions—in place between policy-informers’ work and policy making.
For instance, the Bureau of Labor Statistics is mandated to “acquire and diffuse among the people of the United States useful information,” not to influence policy directly. The National Center for Education Statistics must ensure its data is “objective, secular, neutral, nonideological, and free from partisan political influence.” The Confidential Information Protection and Statistical Efficiency Act defines statistical purpose as “description, estimation, or analysis of groups,” explicitly omitting policy advocacy or formulation. The Foundations of Evidence-Based Policymaking Act also reinforces this separation, tasking agency heads with identifying policy questions and developing evidence, while statistical agencies produce information “useful to policymakers” without being policymakers themselves. Statistical Policy Directives Nos. 3 & 4 require “policy-neutral” data releases.
To learn more, read the ASA’s 13-page response. The Office of Personnel Management is expected to release the final rule in the next several months.
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