December 2024

On December 13, AERA submitted comments on a Request for Information (RFI) from the National Science Foundation (NSF) seeking input on research ethics. The RFI responds to a provision in the 2022 CHIPS and Science Act for NSF to incorporate ethical, social, safety, and security considerations into the merit review process that is used to evaluate research projects or other activities for funding. The RFI also represents one way that NSF is working with stakeholders to promote best practices for governance of research in emerging technologies.

NSF sought input on potential ethical, social, safety, and/or security risks from current and emerging research activities; approaches for identifying risks and balancing risks against potential benefits; and strategies for encouraging research teams to incorporate ethical, social, safety, and/or security considerations into the design of their research approaches. NSF also sought feedback on its approach to ethical, social, safety, and/or security considerations through work with stakeholders, incorporation into the merit review process, and other measures that the agency could consider for identifying and mitigating risks.

The AERA comments included references to transparency for projects that include code, algorithms, and metadata associated with research that incorporates emerging technologies; attention to appropriate human research protections; and research ethics training as part of NSF work. The AERA comments also highlighted strategies for advancing ethical and social considerations for NSF-funded research, such as through research teams that include diverse voices and diverse conceptual and methodological expertise; developing authentic partnerships; and funding mechanisms that would support interdisciplinary research that cuts across the directorates.

The comments also responded to questions to inform NSF’s own role in fostering ethical, social, security, and safety considerations for research and activities that NSF funds. Examples include supporting a resource hub of practices and toolkits drawn from recipients of the Ethical and Responsible Research (ER2) program; developing best practices in partnership with other federal agencies to inform the research and use of emerging technologies in STEM education and in education research broadly; and furthering NSF’s role to fund research that seeks to mitigate bias and discrimination in the use of artificial intelligence and that seeks to scale up promising evidence-based STEM education research.

The comments also emphasized the role that NSF’s merit review process can play to account for ethical, social, and security considerations.

AERA Executive Director Felice J. Levine wrote: “In the development of solicitations, NSF should emphasize the need for proposals to explicitly address ethical, societal, and safety considerations. Emphasizing these considerations at the outset of the grant application process would encourage grant applicants to account for how they will elevate and incorporate ethical practices and consider societal impact in the course of their research.”

The comments highlighted the importance for peer reviewers across NSF to receive training in examining broader impacts in the merit review process to help ensure that the criteria are applied consistently across NSF programs. The comments also encouraged NSF to emphasize appropriate representation and expertise on peer review panels.