Both President Trump’s and President Biden’s administrations have emphasized in executive orders and presidential memoranda the need for objective, science-based decision-making. However, Trump’s May 23, 2025, Executive Order 14303, titled “Restoring Gold Standard Science,” reverses Biden’s approach, which directed agencies to deliver equitable outcomes by incorporating diversity, equity, and inclusion (DEI) practices in the decision-making process. The executive order rejects such “equitable” approaches and refocuses science policy on data transparency regarding assumptions and the likelihood of scenarios, and on recognition of relevant scientific uncertainties underlying models adopted by agencies to set scientific policy.
Policy Goals, Scope, and Applicability
The executive order asserts that “over the last five years” public confidence in scientific research has fallen drastically and provides examples of what the Trump administration believes drove the loss of trust. These examples include the Centers for Disease Control and Prevention incorporating edits from the American Federation of Teachers to discourage in-person learning, overriding data supporting the reopening of schools with “reasonable mitigation” measures, and the National Marine Fisheries Service’s biological opinion that adopted a “worst-case scenario” projection of the North Atlantic right whale population in response to proposed actions that adversely affected Maine’s lobster industry. Similarly, the executive order criticizes environmental agencies’ adoption of assumptions concerning climate change that have adversely affected the use of coal.
The executive order attributes such outcomes to the Biden administration’s directive to incorporate DEI considerations in all aspects of science planning, execution, and communication, and it rejects incorporation of DEI considerations in setting scientific policy.
This executive order applies generally to all executive departments and agencies and their respective employees involved in the generation, use, interpretation, or communication of scientific information, except where precluded by law. Agencies are directed to require agency contractors and vendors to adhere to the policies as well. The executive order is not applicable to non-scientific aspects of agency decision-making.
“Restoring Gold Standard Science”
The executive order directs the director of the White House Office of Science and Technology Policy (OSTP) to issue guidance, within 30 days of the executive order, to agencies on implementation of its requirements in the conduct and management of scientific activities. The required criteria for the guidance are that the scientific conduct at issue be:
- 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
- Without conflicts of interest
Upon publication of the guidance, each agency head is required to update applicable agency policies and, within 60 days of publication, report to the OSTP director on actions taken to implement the new standards.
Use, Interpretation, and Communication of Scientific Data
Within 30 days of the executive order, agency heads and employees are required to comply with specific rules governing the use, interpretation, and communication of scientific data, unless otherwise provided by law. These include that employees may not engage in scientific misconduct nor knowingly rely on information resulting from scientific misconduct. Further, to the extent consistent with relevant policies that protect national security or sensitive personal or confidential business information, agency heads must make publicly available 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, as applicable, the source code for such models) that the agency used to generate such influential scientific information.
Agency employees are not permitted to invoke an exemption to the Freedom of Information Act (set forth in 5 U.S.C. § 552(b)(5)) to prevent disclosure of such models unless authorized in writing to do so by the agency head following prior notice to the OSTP director. However, risk models used to guide agency enforcement actions or select enforcement targets are exempt from this requirement.
The executive order requires agencies to acknowledge and document uncertainties, including how such uncertainties propagate through the model used in the relevant analysis. The executive order also requires transparency about the likelihood and assumptions used, and limits reliance on highly unlikely and overly precautionary assumptions to only where required by law. The order requires agencies to employ the “weight of scientific evidence” approach where scientific or technological information is used for agency evaluations and decision-making and requires communication of the relevant degree of uncertainty in the analysis. Further, agency communications involving scientific models must include the material assumptions underlying the scientific model.
Interim Scientific Integrity Policies
The executive order requires that until the updated policies are issued, changes implemented during the Biden administration are effectively revoked, and the integrity policies as of the date of the executive order must be governed by scientific integrity policies that existed on January 19, 2021. If there is a conflict between the earlier policy and the executive order, the executive order controls.
Agency heads are directed to reevaluate, and if necessary, revise or rescind scientific integrity policies or procedures issued between January 20, 2021, and January 20, 2025. The executive order specifically targets the Biden administration’s presidential memorandum of January 27, 2021 (“Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policymaking”) and requires agencies to operate in the same form “as would have existed” in the absence of the Biden memorandum. The Biden memorandum differs from the gold standard executive order in several key aspects, including its emphasis on structuring science policy and practices to provide equitable delivery of federal programs. The Biden memorandum also called for inclusion of “well-established processes for community engagement” and “other approaches that may be informed by the social and behavioral sciences and data science” for “the evidence-based and iterative development and the equitable delivery of policies, programs, and agency operations.”
Enforcement, Oversight, and Waivers
The executive order requires each agency head to establish internal processes to evaluate violations of the order. Such processes would be conducted by a senior appointee of the agency head and be responsible for taking action that is consistent with the requirements of section 515 of the Information Quality Act.
The executive order permits agency heads to request a waiver of requirements from the director of the Office of Management and Budget.
Takeaways
The executive order departs from Biden’s policies in significant ways. An important change is the express rejection of equitable outcomes and removal of factors such as diversity, inclusion, and community engagement in evaluating the data and assessment of uncertainties and risks in scientific models used by agencies. Importantly, the executive order requires agencies to immediately step away from Biden’s policies and revert to standards in place before the start of the Biden presidency.
The executive order’s emphasis on transparency in the decision-making process, requiring disclosure of data, assumptions, and uncertainties in scientific modeling, are not inconsistent with those of earlier administrations. However, from the policy objectives cited upfront, it appears that the executive order’s directives are designed to remove activist influence on science policy, especially with regard to health care and environmental issues, including by eliminating community engagement in the decision-making process.
