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AIBS Comments on NSF's Draft Scientific Integrity Policy

September 2011

Dr. Subra Suresh Director National Science Foundation 4201 Wilson Boulevard Arlington, VA 22230

Re: Draft Scientific Integrity Policy

Dear Dr. Suresh,

Thank you for the opportunity to comment on the National Science Foundation’s (NSF) draft scientific integrity policy.

The American Institute of Biological Sciences (AIBS) is a nonprofit scientific association dedicated to advancing biological research and education for the welfare of society. Founded in 1947 as a part of the National Academy of Sciences, AIBS became an independent, member-governed organization in the 1950s. AIBS is sustained by a robust membership of individual biologists and nearly 200 professional societies and scientific organizations with a combined individual membership exceeding 250,000.

As is noted in the draft policy, NSF already has in place a number of policies to ensure the integrity of the merit review process and other agency actions. While it is commendable that NSF has been a leader in implementing a conflict of interest policy for investigators, this and other past actions are not sufficient to implement the guidance issued by the Office of Science and Technology Policy. NSF should make several changes to the policy in order to fully ensure the integrity of science.

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