The AAMC Nov. 14 submitted a letter to the Commission on Evidence-Based Policymaking in response to a Sep. 14 request for comments on how data and research can be used to build evidence, improve public programs, and inform policy design and implementation while protecting confidentiality and privacy. The 15-member bipartisan commission was formed through the Evidence-Based Policymaking Commission Act of 2016 (P.L. 114-211) and the commission’s findings and recommendations will be presented to congress and the president.
The AAMC’s comments emphasize that biomedical research is an area “for which there are limited but promising mechanisms and proposed frameworks for incorporating evidence into policies and programs.” Using three reports from the AAMC, National Academies of Sciences, Engineering, and Medicine [see Washington Highlights, Sep. 25, 2015], and the Government Accountability Office, the association underscores the need for federal agencies to streamline regulations, reduce regulatory workload and costs, and consider evidence-based approaches. In its letter, the AAMC recognizes that the documented increase in regulatory burden highlights the need for thoughtful and deliberative evidence-based policymaking and proposes the following:
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Government programs and policies are hindered by a lack of data and evidence-based evaluation to determine whether agency goals are being met. Efforts like the AAMC Conflicts of Interest Metrics Project demonstrate how, when appropriate, “objective, rigorous, and systematic evaluation can be used as a framework for evidence-based review of government programs, policies, and regulations” but also as a model for the prospective assessment of proposed regulation and policy; and
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Robust evidence-based evaluation mechanisms should be considered for inclusion in agencies’ proposed rulemaking processes to ensure that regulatory decisions are made using the best and most current evidence available.
As stated in the AAMC letter, “Without data to understand the need for or likely impact of new initiatives, regulations or policies may be ineffective, inefficient, or unduly burdensome without achieving intended aims.”