Editor's Note: The Department of Health and Human Services has requested comment on the "impact and prevalence of health misinformation in the digital information environment during the COVID-19 pandemic." The National Association of Scholars has provided the comment below encouraging the Department and Surgeon General to protect scientific inquiry and skepticism, especially during novel events, so that science may advance for all Americans and not for what is momentarily politically expedient.
Our concerns turn on the definition, determination, and adjudication of information deemed “misinformation.”
The very concept of misinformation is anathema to any scientific approach to serious health issues like the COVID-19 pandemic. Uncertainty is at the heart of any scientific approach to any question. What may be credible information on one day may be proven to be false the next. Claims deemed erroneous one week (“misinformation”) may, over time, be determined to be valid after all. For science to arrive at a correct answer, scientists must be free to ask any question they like, and to challenge prevailing wisdom (“information”) as they like, without restraint.
Federal authorities, even expert authorities, should never engage in defining or adjudicating what are properly scientific questions. To do so is to distort the proper place of science in guiding our society and government to rational policy recommendations.
The RFI correctly states that “the speed, scale, and sophistication with which misinformation has been spread during the COVID–19 pandemic has been unprecedented.” However, the major purveyor of misinformation in the COVID-19 pandemic has been the federal government itself.
Public health authorities have pushed policy recommendations that are inconsistent, only loosely based on scientific recommendations, and actively deleterious to the communities they are pledged to protect. The response of the public health authorities throughout the COVID-19 pandemic has been marked by spectacular failure. Any effort to control information and to define what is, or is not, “misinformation” is similarly bound to fail.
Moreover, federal agencies have withheld pertinent statistical and substantive data, and in at least one case, the NIH, acting at the request of Chinese researchers, removed from an online database key COVID-19 genetic sequences from China. “Misinformation” includes such efforts to mislead researchers about the existence and availability of pertinent data.
The failures of public health authorities have been exacerbated by the censorious actions of social media. The same caution applies to social media platforms as to public health authorities: what is today’s misinformation might be tomorrow’s conventional wisdom, and vice versa. Only scientists are in a position to explore these issues competently. When the censoriousness of public health authorities combines with the arrogance of moderators of social media platforms, the result has been demonstrably deadly.
Our hope at the National Association of Scholars is that the Surgeon General will abandon any such attempts to define “misinformation” in a manner that leads to censorship of views that some or even many scientists consider erroneous. Scientists are capable on their own of weeding out statements of fact that are irreproducible, fraudulent, or mistaken. Intervention by government agencies in efforts to label some views as invalid are, as we have seen throughout the pandemic, prone to bias, self-dealing, and compound errors.
The record of federal authorities to control information about COVID-19 has impeded our society’s ability to respond to this novel public health challenge, with devastating economical, societal, and health consequences.
HHS should assemble a bipartisan, ideologically diverse committee to consider this issue before issuing a rule. We suggest that members of this committee include a substantial number of reputable scientists and officials who have expressed skepticism about different aspects of federal policy to address COVID-19, such as Jay Bhattacharya (Stanford University), John Ioannidis (Stanford University), Martin Kulldorff (Harvard University), Joseph Ladapo (Surgeon General of Florida), and Harvey Reisch (Yale University). We also suggest that this committee include nominees from institutions devoted to issues of academic free speech, such as the Academic Freedom Alliance, Foundation for Individual Rights in Education (FIRE), and Heterodox Academy.
Peter Wood
President
National Association of Scholars
