A plan for more accountable public health agencies

Public Health agencies should be required to mention the logic and assumptions behind their guidance.

Let me explain with an example. When the CDC reduced its guidance for COVID quarantines to 5-days, it wrote in its press release, “The change is motivated by science demonstrating that the majority of SARS-CoV-2 transmission occurs early in the course of illness.” Which “science?”  We don’t know. There’s no link, no source, no study, no data.

This is bad, for many reasons.

First of all, not having to justify its guidance allows the CDC to issue its guidance on political rather than scientific grounds.

This might lead to wrong recommendations. And when their guidance is correct, some of the population might argue it’s incorrect, and there’s no easy way to know whether it’s true. This lowers trust in the institutions and reduces policy compliance.

Secondly, not having to justify its guidance allows the CDC to shield politicians from accountability. In an ideal world, the CDC would have only said, “if we reduce quarantines to 5-days, X% of people will be allowed to go to work while infectious,” and would have let politicians decide whether it’s worth it. This way, politicians can be held responsible for their policies.

Thirdly, not having to justify its guidance leads to worse guidance. They can issue incorrect guidance (because it’s not falsifiable), and incorrect guidance will stay in place for longer.

Imagine a world in which the CDC had to write, “data from studies X and Y suggest that only 5% of people are still infectious after 5 days.” This is a falsifiable statement. If later data, or data from a new variant, shows that 20% of people are still infectious after 5 days, the guidance is immediately invalidated. Politicians must then retract their policies that were based on incorrect guidance or assume responsibility for continuing them.

Fourth, allowing public health agencies to withhold the bases for their guidance prevents us from evaluating decisions based on their merit. We are left judging them on their outcome, and that might lead to learning the wrong lesson. For example, were lockdowns a good idea? It’s debatable, but the debate should only consider what was known at the time, not later. Recent information should only be used to decide whether lockdowns are a good idea onwards, but cannot be used to determine whether it was a good decision then, when the properties of the novel virus were unknown. (Why does it matter to know whether it was a good idea then? To inform our decision-making processes under uncertainty – which are different from the decision-making processes under certainty – and to decide whether those who took decisions then should be held accountable for them.)

Because of these four reasons, we should all demand public health agencies be required to mention the logic and assumptions behind their guidance. There’s only one reason not to do so: to provide plausible deniability to politicians.