NCSES_NSDS_study_Draft SOW.pdf

Dra� Statement of Work

THE NATIONAL CENTER FOR SCIENCE AND ENGINEERING STATISTICS AT THE U.S. NATIONAL

SCIENCE FOUNDATION

CONSENSUS STUDY ON

A STRATEGY FOR SCALING UP THE NATIONAL SECURE DATA SERVICE DEMONSTRATION

PROJECT FOR NATIONAL EVIDENCE BUILDING

1.0 OVERVIEW

The Na�onal Center for Science and Engineering Sta�s�cs within the U.S. Na�onal Science Founda�on requires convening a mul�-disciplinary consensus study commitee to inform how to scale up the Na�onal Secure Data Service (NSDS) Demonstra�on Project to a future NSDS whose goal is to facilitate sta�s�cal ac�vi�es for evidence-based decision making for the na�on.

The commitee will review and build upon findings from the NSDS Demonstra�on pilot projects and other key efforts pertaining to the NSDS. As part of informa�on gathering, the commitee will present one public workshop and hold addi�onal open mee�ngs to explore important considera�ons for a shared services model of na�onal data infrastructure. The workshop and other informa�on-gathering mee�ngs will include par�cipa�on from a wide range of stakeholders and experts, including from exis�ng models of data infrastructure, state, local, and tribal governments, representa�ves from under-resourced communi�es, data holders, educators, and researchers in privacy and risk management. Following informa�on gathering, the commitee will issue a study report offering well-considered, credible consensus advice on the feasibility of and a unified strategy for building a Na�onal Secure Data Service (NSDS), as well as on priori�es and implementa�on of key aspects of the NSDS.

2.0 BACKGROUND

The Na�onal Center for Science and Engineering Sta�s�cs (NCSES) within the U.S. Na�onal Science Founda�on (NSF) has been mandated to pilot a Na�onal Secure Data Service (NSDS) Demonstra�on Project, per Sec�on 10375 of the CHIPS and Science Act of 2022. The mandate directs the NSF via NCSES to “establish a demonstra�on project to develop, refine, and test models to inform the full implementa�on of the Commission on Evidence-Based Policymaking recommenda�on for a governmentwide data linkage and access infrastructure for sta�s�cal ac�vi�es for sta�s�cal purposes.” In order to establish the NSDS Demonstra�on Project, NCSES is directed to engage with “Federal and State agencies to collect, acquire, analyze, report, and disseminate sta�s�cal data in the United States and other na�ons to support governmentwide evidence-building ac�vi�es consistent with the Founda�ons for Evidence-Based Policymaking Act of 2018.” The mandate also covers the applica�on and use of systems and privacy-enhancing technologies to protect confiden�ality of data subjects, and the need to ensure transparency to the public.

The proposed consensus study commitee will inform and provide a holis�c strategy for scaling up of the NSDS Demonstra�on Project. The study commitee will review and build upon the findings and recommenda�ons from the NSDS Demonstra�on pilot projects,1 the Advisory

1 See https://www.americasdatahub.org/awards/.

https://www.americasdatahub.org/awards/

Commitee on Data for Evidence Building,2 the Na�onal Ar�ficial Intelligence Research Resource Pilot,3 the Interagency Council on Sta�s�cal Policy’s (ICSP) Standard Applica�on Process,4 and other key efforts related to the NSDS. The study will also gather informa�on on the following topics, to be considered and integrated into a unified strategy.

The study will focus on five key strategic areas to inform the scaling up of the NSDS Demonstra�on Project:

2.1 Building skills and capacity to meet 21st century data needs A 21st century data infrastructure like an NSDS will need a unique mix of staff skill sets to operate effec�vely. Moreover, the unique vision for an NSDS is to serve the en�re na�on and thus has unique goals, services, and products that complement those of exis�ng data infrastructures. No statement or blueprint currently exists. The study will consider the new skills and disciplines needed for a full-scale NSDS, for example, experts in data science, ethics, law, strategic communica�ons and engagement, data governance, data management, privacy-preserving techniques, data security, and related informa�on technology. Poten�al areas to be explored in capacity-building include iden�fying the technical and disciplinary needs for opera�ng the NSDS and delivering data concierge services5 to a variety of users, training and upskilling exis�ng staff, targeted hiring of new staff and what kinds of people need to be in the pipeline and educa�ng people in adjacent fields like computer science on sta�s�cal issues in order to form beter collabora�ons. The goals of a workshop on this topic would be to engage stakeholders, including those from exis�ng data infrastructure models, to understand the skills and types of backgrounds people need to conduct the data infrastructure work needed in the future, and to raise awareness of these capacity needs as an important challenge for the NSDS.

2.2 Challenges to data sharing and data-driven evidence building for subna�onal governments States’, locali�es’, tribal, and territorial data needs have become a high priority, both for use in their own decision making and to incen�vize them to share their data for other policy and programma�c purposes. However, such subna�onal governments o�en face legal and regulatory challenges to sharing, linking, and accessing data. Capacity issues such as skills shortages and lack of resources can further hinder subna�onal governments’ ability to share and leverage their own data for evidence building. State, local, tribal, and territorial governments need ac�onable ways to use a future data infrastructure like the NSDS to beter enable them to make beter use of data, for example, to improve the effec�veness of government programs. The study will review federal efforts and recommenda�ons on subna�onal governments’ data sharing, linkage, and evidence-based decision making, such as from the Advisory Commitee on Data for Evidence Building and the Chief Data Officers

2 See https://www.bea.gov/system/files/2022-10/acdeb-year-2-report.pdf.

3 See https://new.nsf.gov/focus-areas/artificial-intelligence/nairr.

4 See https://ncses.nsf.gov/about/standard-application-process.

5 The concierge services will be informed by the NSDS Demonstration pilot project, “Models for a Data Concierge Service for a National Secure Data Service (DCS).” See https://www.americasdatahub.org/award-dcs/.

https://www.bea.gov/system/files/2022-10/acdeb-year-2-report.pdf https://new.nsf.gov/focus-areas/artificial-intelligence/nairr https://ncses.nsf.gov/about/standard-application-process https://www.americasdatahub.org/award-dcs/

Council,6 as well as lessons learned from key subna�onal data sharing efforts.7 The study will explore targeted solu�ons for subna�onal data sharing, such as the elements of toolkits, templates, and services needed for state, local, tribal, and territorial governments to contribute more easily to the produc�on of na�onal sta�s�cs, as well as to engage with other jurisdic�ons (e.g., regional state partnerships) and overcome varia�ons in data sharing and privacy laws.

Engaging and suppor�ng tribal governments may reveal unique requirements and needs as well. Elements to be considered could include how to align cross-jurisdic�onal legal authori�es and quickly and effec�vely undertake data sharing (e.g., agreements), capacity and skills-building at the organiza�onal level and technical assistance needs, and evidence-based decision making and high-value data uses.

2.3 Sustainable incen�ves for data sharing

A key challenge to developing an NSDS is incen�vizing data sharing for data linkage, access, and use. In 2023, a Na�onal Academies report concluded that “data sharing is incen�vized when all data holders enjoy tangible benefits valuable to their missions, and when societal benefits are propor�onate to possible costs and risks.”8 Tangible benefits will naturally vary for different sectors (e.g., academia, private industry, governments at various levels) of data holders, depending on their missions, goals, and capacity to share data. For instance, private companies are not typically established to serve the public good. Even public sector en��es such as federal, state, local, and tribal governments, may not have the capacity or desire to share data on government programs. Academics may want to restrict access to proprietary data investments in order to support their research publica�ons. Solu�ons for overcoming disincen�ves and other barriers will vary for each type of data holder. Some data holders may want monetary compensa�on or to receive addi�onal data in return for sharing. Others may be mo�vated by the reputa�onal benefits from sharing data with the federal government. Yet other solu�ons may involve a tax or legal incen�ve that is outside of the NSDS’s purview. All data holders will likely require assurances of data security as a prerequisite for data sharing. The study’s public informa�on gathering sessions will gather input, lay out issues, and present case studies where people have found solu�ons and paths for data sharing, to learn what is valuable and important to data holders, show how progress can be made, and also learn from failures. The study will consider key stakeholders’ perspec�ves on fundamental ques�ons such as how to build trust and feedback loops for successful sharing with the NSDS.

2.4 Data ethics considera�ons and expanding and diversifying users of data infrastructure An important issue surrounding data linkage and access is ethics. These considera�ons include data subjects and informed consent about secondary uses of their informa�on, including data linkage. Further, many individuals represented in programma�c data are already vulnerable and under-resourced, i.e., they are par�cipa�ng in means-tested programs of the social safety net.

6 See https://www.cdo.gov/.

7 For example, see https://aisp.upenn.edu/.

8 National Academies of Sciences, Engineering, and Medicine. 2023. Toward a 21st Century National Data Infrastructure: Mobilizing Information for the Common Good. Washington, DC: The National Academies Press.

https://doi.org/10.17226/26688; page 49.

https://www.cdo.gov/ https://aisp.upenn.edu/ https://doi.org/10.17226/26688

Not only is this informa�on poten�ally sensi�ve, combining informa�on on these same individuals posi�ons them to have higher risk of iden�fica�on and poten�ally nega�ve outcomes from disclosure. This differen�al risk for individuals who are already in a vulnerable status presents serious ethical considera�ons for the NSDS infrastructure’s governance and rela�onship with data subjects as a stakeholder.

Ethical issues also include equity around which users have access to credible data for evidence building. Academic researchers have been on the forefront of combining and using linked data to provide new analy�c insights in the social and behavioral sciences. While other data infrastructure models have supported such access to restricted data, their users are o�en well resourced. The NSDS vision, however, is to support all users for government-wide evidence building, i.e., it is to be equitable towards users. Equity in access is even more important as the demand for data-driven decision- making increases and the variety of NSDS uses and users expand. The expanded group of users seeking access to linked data may have different requirements and uses.

The study will seek the perspec�ves of communi�es, small or vulnerable popula�ons, organiza�ons, and other en��es that may be at higher risk of iden�fica�on and poten�ally nega�ve outcomes from disclosure. The goal would be to understand beter some use cases around topics, scenarios, and contexts that make some data more or less sensi�ve, as well as how data subjects9 think about the tradeoffs of sensi�vity, risk, and the value of different uses of their informa�on. These perspec�ves could inform the study about the organiza�onal models, data governance, project ve�ng, data linkage and processing flows, and public engagement approaches that could build trust in the NSDS. The study commitee could also learn from ethicists, privacy officers, and other experts to grapple with how an NSDS can operate transparently and ethically towards its stakeholders, including the data subjects.

Regarding equity around user access to credible data for evidence building, the study will draw upon exis�ng efforts to expand the users and uses of data infrastructure, such as the NSDS Demonstra�on pilot project, “Expanding Equitable Access to Restricted-Use Data through Federal Sta�s�cal Research Data Centers.” 10 The study may seek addi�onal, complementary perspec�ves of users who have been underserved by exis�ng data infrastructure models, to beter understand their needs, data uses, and requirements to access the NSDS. Users could include people from different race groups and ethnici�es, prac��oners (i.e., non-academics), academics outside of well-resourced universi�es, researchers and analysts at think tanks and non-profit organiza�ons, graduate students, and other users who lack analy�c capacity.

Understanding the broad user base is an important element of the study’s unified strategy.

2.5 Leading and applying privacy-enhancing technologies and risk management measures A fundamental recommenda�on in establishing an NSDS is to protect the data subjects in the data infrastructure, including iden�ty and other individual informa�on, by producing sta�s�cal

9 The term “data subjects” refers to the people, entities, or organizations described by data files.

10 See https://www.americasdatahub.org/award-fsrdc/.

https://www.americasdatahub.org/award-fsrdc/ outputs. NSDS Demonstra�on Project is also mandated to explore and apply privacy-enhancing technologies, conduct privacy risk assessments, and deploy appropriate measures to minimize risk of iden�fica�on of individual en��es. The Commission on Evidence-Based Policymaking report (2017) recommended the NSDS also lead the development of privacy protec�on methods and their implementa�on, and the Advisory Commitee on Data for Evidence Building (2022) specifically recommended the NSDS provide privacy-preserving tools to users and support the development of innova�ve privacy protec�on protocols within the NSDS. The study will review findings from exis�ng NSDS Demonstra�on pilot projects such as, “Privacy Preserving Technologies Phase 1: Environmental Scan (PPT)”11 and “Evalua�on of Noise Infusion for Large-Scale Demographic Sample Survey (Survey of Doctorate Recipients) (SDRN).”12 Importantly, the study will also consider the social aspects that are layered with risk and use of privacy-enhancing technologies. Such social considera�ons could include ethical issues around data linkage and differen�al risk for data subjects who are under-resourced, appropriate uses of restricted data (e.g., for the common good), equity in data access across user types, user responsibili�es and role in risk management, disciplinary repercussions of data breaches, and transparency of opera�ons while also protec�ng confiden�ality. The study will examine the landscape of the development and use of confiden�ality protec�on methods, risk mi�ga�on approaches, and public engagement to explore how these technologies may be applied and adapted over �me in a full-scale, sustainable NSDS.

The study will bring together these topics, consider them in the context of the NSDS’s unique value to the na�on and its role in the federal data ecosystem, and provide a holis�c set of conclusions and recommended strategies for building a full-scale NSDS.

3.0 SCOPE OF WORK

The Contractor shall gather and establish a consensus study panel of experts to develop a consensus report on a strategy for scaling up the NSDS Project for na�onal evidence building.

The Contractor shall follow the work plan, �meline, and deliverables described below.

Statement of Task The Contractor shall convene an ad hoc commitee to develop a holis�c strategy for scaling up the Na�onal Secure Data Service (NSDS). The commitee will consider how a shared services data infrastructure model can best facilitate access to integrated data for sta�s�cal ac�vi�es to build evidence and enable decision making for the na�on. The commitee will review and build upon findings from the NSDS Demonstra�on pilot projects and other key efforts related to the NSDS. Specific topics the commitee will explore as part of its informa�on gathering include:

• Skills-building and capacity building needs for data infrastructure and evidence building, including government stakeholders and student pipelines

• Challenges to data sharing and data-driven evidence building for state, local, tribal, and territorial governments

11 See https://www.americasdatahub.org/award-ppt/.

12 See https://www.americasdatahub.org/award-sdrn/.

https://www.americasdatahub.org/award-ppt/ https://www.americasdatahub.org/award-sdrn/

• Sustainable incen�ves for data sharing, especially with the private sector and state and local governments

• Data ethics considera�ons for data subjects and expanding and diversifying users of data infrastructure

• Applica�ons of privacy-enhancing technologies and risk management measures, and related public engagement

The commitee shall convene one public workshop and addi�onal open mee�ngs to explore these topics and seek input from key stakeholders, exis�ng data infrastructure models, and other relevant external experts. The study report will provide conclusions and recommenda�ons on a unified strategy for building, implemen�ng, and sustaining key services to be considered for a future, full-scale Na�onal Secure Data Service (NSDS). The strategy will include the services provided, approaches for stakeholder engagement and partnerships, governance structure, and the human capital, methods, and technologies needed to facilitate sta�s�cal ac�vi�es for evidence building for the na�on. The report will also make recommenda�ons on the priori�es and implementa�on of key aspects of the NSDS, in the context of the role of the NSDS within the broader federal data ecosystem.

Ac�on Plan Task 1: Schedule and hold a kick-off meeting, schedule regular progress meetings, and deliver status reports In coordina�on with the COR, the Contractor shall conduct an open (virtual) mee�ng with relevant NCSES staff. The purpose of the mee�ng will be to review and clarify the project objec�ves and requirements. The Contractor shall deliver summary notes and recommenda�ons to the COR.

Following the kick-off mee�ng, the Contractor shall conduct periodic progress mee�ngs with NCSES throughout the course of the award, cadence to be decided in consulta�on with the COR.

One of these mee�ngs, following the in-person workshop (discussed below) shall be designated as a mid-course mee�ng, during which NCSES and the Contractor will discuss whether modifica�ons are necessary to the work plan or statement of task, due to insights from the workshop and informa�on gathering or other reasons.

The Contractor shall submit quarterly status reports to NCSES. Quarterly status reports will include the following: (a) a descrip�on of work accomplished during the repor�ng period; (b) a brief summary of an�cipated work during the following period; (c) current management and administra�ve issues, risks, and mi�ga�on strategies; and (d) a summary of the costs incurred during the repor�ng period and cumula�vely.

Task 2: Appoint a committee The Contractor shall appoint a consensus panel of 10-12 experts who will serve pro bono. The Contractor shall seek nominees from a variety of sources, issue a public call for nominees, seek input from NCSES staff, research poten�al experts for the commitee, assemble names of experts, and submit nomina�ons for internal review and approval. Care will be taken to ensure a balance of experience and a range of perspec�ves, which is cri�cal for comprehensive considera�on of the issues and solu�ons. Targeted areas of exper�se include: sta�s�cs, data science, government and policy data needs, ethics, (sta�s�cal) educa�on, privacy-enhancing techniques, data sharing and linkage, sociology and other social sciences, and other relevant areas. NCSES staff will be consulted to provide sugges�ons for the consensus panel. The Contractor shall ensure that the commitee will be free of conflicts of interest and ensure the credibility and independence of the panel and its recommenda�ons.

Task 3: Convene one workshop and hold additional information-gathering meetings (open) As part of its informa�on-gathering ac�vi�es, the commitee, under guidance by the Contractor and in consulta�on with the COR, will organize one 1.5- to 2-day public workshop and hold addi�onal informa�on-gathering mee�ngs (open to the public), to explore important considera�ons for a shared services model of na�onal data infrastructure. The topics will include:

• Workshop topic o Skills-building and capacity building needs for data infrastructure and evidence building, including government stakeholders and student pipelines

• Addi�onal topics for informa�on gathering o Challenges to data sharing and data-driven evidence building for state, local, tribal, and territorial governments o Sustainable incen�ves for data sharing, especially with the private sector and state and local governments o Data ethics considera�ons for data subjects and expanding and diversifying users of data infrastructure o Applica�ons of privacy-enhancing technologies and risk management measures, and related public engagement

The commitee may explore any other topics it deems necessary to complete the Statement of task.

The Contractor shall hold an ini�al open mee�ng between the commitee and NCSES staff to discuss the scope of work, objec�ves, and goals. A�er the ini�al mee�ng, the Contractor shall host addi�onal closed mee�ngs for the commitee to develop the workshop and other informa�on-gathering mee�ng agendas and discuss poten�al speakers, discussants, and moderators. The workshop and other open mee�ngs will be used to gather informa�on on the issues in the statement of task and iden�fy a wide range of stakeholder and public perspec�ves on the topics.

The Contractor shall hold closed mee�ngs with poten�al speakers, as needed, to tailor comments towards areas that would be most informa�ve and applicable to a full-scale NSDS.

The Contractor will arrange and provide transporta�on, lodging, and any other logis�cal support for in-person mee�ng par�cipants, including commitee members.

The Contractor shall keep the COR apprised of progress and work to ensure mutually viable dates for the workshop and other open mee�ngs to ensure maximum par�cipa�on. The Contractor shall publicly announce the �me, loca�on, and agenda of the workshop and open mee�ngs at least 10 business days beforehand.

The Contractor shall adver�se the workshop announcement and registra�on widely to the sta�s�cal and social science research and user communi�es, and other relevant stakeholders.

The Contractor shall also provide the announcement to the COR and NCSES staff to circulate to the Interagency Council on Sta�s�cal Policy (ICSP) and federal sta�s�cal agencies.

The Contractor shall host and professionally webcast the workshop. Within 30 days of the workshop, the Contractor shall post the webcast of the workshop on Contractor’s website, including video with audio, presenta�on slides, and other workshop materials.

Task 4: Produce Proceedings of a Workshop – In Brief For the workshop, the Contractor shall prepare a Proceedings of a Workshop – In Brief, a document that will provide a high-level summary of the presenta�ons and discussions that took place at the workshop, including sugges�ons made by authors, presenters, discussants, and moderators. The descrip�ons of each presenter’s remarks will be fact-checked with the speaker, and the document shall be submited for external peer review. This review process further ensures the Proceedings-In-Brief accurately reflect the content of the workshop.

The Contractor shall work to prepare the Proceedings of a Workshop – In Brief for final printing and publication. The Contractor shall post the final Proceedings of a Workshop –In Brief on the project websites for free download and will produce printed copies.

Task 5: Produce a consensus report The study committee will develop findings and recommendations in a consensus report addressing its statement of task. The committee will deliberate in closed session, which preserves the independence and credibility of the recommendations, and come to consensus on conclusions and recommendations.

The report will consider any presentations and documentation provided by NCSES, findings from the NSDS Demonstration projects, lessons learned from the ICSP’s NSDS activities and efforts, past reports and analyses by professional associations and other organizations, and information gathering activities of the committee including the workshop. The committee will hold closed-session meetings to discuss the key themes that emerged from the workshop and other open sessions, review additional information, and determine what additional information is needed. The committee will hold further closed-session meetings to deliberate extensively on the information gathered, come to consensus on a path forward, and draft the report. The committee will produce a comprehensive study report that will provide conclusions and recommendations on a cohesive strategy for building a full-scale National Secure Data Service.

The report will follow institutional guidelines and undergo rigorous peer-review process prior to release. The reviewers will reflect the expertise of the committee and are subject to non-disclosure. This process further ensures that multiple perspectives are considered in the study report.

The pre-publication (uncorrected proofs) version of the final report, which includes all final conclusions and recommendations, is anticipated to be released 11 to 12 months after the workshop. The Contractor shall transmit the report to NCSES and hold a briefing for NCSES with panel members. Within 10 days after transmitting the report, an electronic version of the pre-publication report will be made public and available for download free of charge on the Contractor website. After the pre-publication copy is made public, the Contractors shall disseminate the report widely, e.g., via electronic media of multiple forms, and engage target audiences to facilitate implementation of the recommendations. Engagement could include follow-up briefings with government agencies and presenting at public events such as professional conferences and other venues important to this topic.

The Contractor shall implement the final proofing, composition, and layout to produce a printed, bound version of the report and a 508-compliant electronic version of the report.

Printed copies of the final report are anticipated to be available within another six (6) months after pre-publication.

Post report release, the Contractor shall also work with the COR and NCSES leadership to engage with target audiences and participate in up to two strategic engagement activities, including but not limited to NSF and OMB briefings of the report findings.

4.0 Deliverable Schedule

Item Deliverable Due

1. Kick-Off meeting Within 1 month of contract award

2. Quarterly Status Reports Quarterly

3. Mid-Course Meeting Month 13-14 after contract award

4. Ad-Hoc Meetings As determined in consultation with

COR

5. Hosted open committee meeting to discuss project scope and goals

Month 5 after contract award

6. Hosted closed meetings for workshop planning and information gathering meetings;

invite workshop participants and speakers

Months 5-13 after contract award

7. Hosted one 1-2 day workshop Month 8-9 after

8. Hosted additional open information gathering meetings to inform report

Months 9-13 after contract award

9. Proceedings of Workshop (website posting) to include videos, presentation slides, and other workshop materials

Month 9-11 after contract award

10. Proceedings of Workshop (printed/bound copies)

Month 9-11 after contract award

11. Hold closed information meetings to deliberate conclusions and draft report

Months 6-15 after contract award

12. Pre-release report briefing Month 20 after contract award

13. Pre-publication version of consensus report (uncorrected proofs)

Month 20 after contract award

14. 508-compliant version of consensus report (final layout)

Month 21-26 after contract award

15. Printed, bound copies of final report

Month 21-27 after contract award

16. Final report posted on website Month 21-27 after contract award

17. Strategic Engagement Briefings and Outreach

Month 21-27 after

5.0 PLACE OF PERFORMANCE

Na�onal Academy of Sciences, 2101 Cons�tu�on Ave. NW, Washington, DC 20418

6.0 PERIOD OF PERFORMANCE

The period of performance for this effort is approximately 27 months.

7.0 TRAVEL

Travel may be required for study panel commitee members.

8.0 POST AWARD CONFERENCE

The Contractor must atend a Post Award Conference with the Contrac�ng Officer and the COR no later than 10 business days a�er the date of award. The purpose of the Post Award Conference is to discuss technical and contrac�ng objec�ves of this contract.

FEDERAL ADVISORY COMMITTEE ACT (FACA)

The Na�onal Academy of Sciences has developed policies and procedures to implement Sec�on 15 of the Federal Advisory Commitee Act, 5 U.S.C. App., Sec�on 15. Sec�on 15 includes certain requirements regarding public access and conflicts of interest that are applicable to agreements under which the Academy, using a commitee, provides advice or recommenda�ons to a Federal agency. Sec�on 15 provides that an agency may not use any advice or recommenda�on provided by the Academy unless the commitee used in the development of the advice or recommenda�on was not subject to any actual management control by an agency or an officer of the federal government. Moreover, its obliga�ons under its Congressional Charter require the Academy to provide independent, unbiased advice without actual or perceived interference or management of the outcome (findings and recommenda�ons). In accordance with these requirements, the Academy requires the right to publish all unclassified materials without any restric�on over content and release, including any restric�on that may require prior approval from the sponsoring agency. In accordance with Sec�on 15 of FACA, the Academy shall submit to the government sponsor(s) following delivery of each applicable report a cer�fica�on that the policies and procedures of the Academy that implement Sec�on 15 of FACA have been substan�ally complied with in the performance of the contract/grant/coopera�ve agreement with respect to the applicable report.