Assurance cases for evidence-based COVID-19 policy
As a highly salient example, we consider Report 9 by the Imperial College COVID-19 Response Team (‘the impact of non-pharmaceutical interventions (NPIs) on the reduction of COVID-19 mortality and healthcare demand’).9 This is an example of epidemiological modelling based on microsimulation to provide primary evidence that can have significant policy implications. We can view the structure of a COVID-19 policy assurance case as an integration of the following, as illustrated in figure 1:
A. Scientific evidence, such as data from epidemiological modelling (in this case: microsimulation).
B. Scientific conclusion, often referred to as ‘scientific advice’, concerning the effect of the different public health strategies based on the scientific evidence.
C. Policy decisions concerning the chosen public health strategy based on the scientific conclusion, but also considering national values, policy goals and so on.
Figure 1Overall assurance case structure for a COVID-19 policy.
Distinguishing between scientific conclusions and policy decisions is important because policy decisions about how to manage the risk of COVID-19 are risk-informed rather than risk-based.10 This means that policy decisions involve broader considerations than just scientific conclusions about risk—examples include ethical, economic and societal concerns and tradeoffs (eg, the debate about reopening of schools). This perspective also helps explain why—given the same scientific evidence and conclusions—different countries might rationally and justifiably adopt different policies to manage COVID-19 risk.10
It is important that the relationship of these structural elements of the assurance case (scientific evidence, scientific conclusions and policy decisions) is explained through well-reasoned and sound arguments:
D. Scientific argument explaining the extent to which the scientific evidence (A) supports the scientific conclusions (B).
E. Policy argument explaining the extent to which the scientific conclusions (B) are sufficient to support the policy decisions (C).
F. Confidence argument explaining the trustworthiness of the scientific evidence (A), for example, the trustworthiness of the epidemiological model.
Scientific evidence
An important part of the scientific evidence comes from epidemiological models, even though there will be other sources of scientific evidence, such as literature reviews. Epidemiological models are engineering artefacts. For use in safety-critical decision making, they should be systematically specified, implemented and tested. The rigour with which this is performed should be proportionate to the criticality of these models to the decision-making process. Given the prominence and importance of epidemiological models in determining a response to COVID-19, the criticality of the models is extremely high.
The COVID-19 model used by the Imperial team is based on a modified individual-based simulation that was developed to support pandemic influenza planning. Models can be intended for a specific purpose, and therefore, a confidence argument would need to justify the suitability of the model for the new context, including the continued validity of the original parameters. This is important because ad-hoc reuse and modification of designs have been associated repeatedly with catastrophic accidents in other safety-critical domains (eg, the recent Boeing 737 Max accidents11).
The quality of the software design and the code of the simulator is an important factor, particularly its amenability to inspection and testing.4 For instance, Neil Ferguson, the lead author of the Imperial report, stated the following: ‘For me the code is not a mess, but it’s all in my head, completely undocumented. Nobody would be able to use it… and I don’t have the bandwidth to support individual users’.12 In a safety-critical context, this would significantly undermine confidence in the simulation results. It is actually common practice in high-risk software engineering to employ different software teams to produce different versions of the same software programme to guard against mistakes. That indicates how important—and how difficult—it is to get the software design and coding done without errors.
The validity of the simulation results hinges on large uncertainties and many societal assumptions, for example, about population behavioural changes. In large part, this is because COVID-19 is a novel virus, which is still relatively poorly understood.2 The developers of the model made many of their assumptions explicit by listing the corresponding parameters and where data exist to support the chosen parameter values. This is useful and enables an independent assessment and evolution of the model. However, decision makers also need to know how confident they can be that these parameters and assumptions are adequate. For example, the report states an assumption that 30% of patients with COVID-19 who are hospitalised will require critical care (invasive mechanical ventilation) based on early reports from cases in the UK, China and Italy. We now know that this was a significant overestimate due to a combination of miscommunication (‘critical care’ in many other countries includes non-invasive measures such as continuous positive airway pressure devices) and the effects of the initial official UK advice to ‘intubate early’.
Scientific conclusion and argument
Given the novelty of COVID-19 and the large uncertainties around the design of the model and its underpinning data, the transition from the scientific evidence to the overall scientific conclusion is not straightforward.13 There are usually multiple sources of evidence, neither of which fully supports a conclusion by itself, and each of which has associated uncertainty. It is important, then, to explain through an argument why the evidence provides sufficient support to the conclusions and how confident we can be.
Figure 2 illustrates how the scientific argument can be captured and represented in a structured way through identifying the claims that are made, the evidence that supports those claims and the relationships between them.
Figure 2An example of part of a structured scientific argument for COVID-19 simulation. ICU, intensive care unit.
In figure 2, only a very simplified structured argument is shown as an example (adapted based on9). The results of modelling for different NPIs are used as evidence to support claims about the impact these interventions will have on the number of deaths. This is accompanied by evidence about the suitability for repurposing the model for COVID-19, evidence coming from independent inspection of the software code and evidence about the reliability of the model outputs. Such evidence is used to support an epidemiological claim that a specific combination of NPIs will result in a certain number of deaths with reasonable confidence.
The full argument would be much more comprehensive and draw on further evidence. For example, while we have referred to practices for increasing confidence from the high-risk software engineering domain, these could be complemented with reference to existing best practices for simulation model building and validation.14 15 The assurance case provides a structure for representing the diverse evidence but does not prescribe what evidence is provided. This is for the developers and assessors of the assurance case to reflect on.
To represent the scientific argument in a structured way, we have used a graphical notation, the Goal Structuring Notation,16 which is widely used in safety-critical domains for creating and communicating structured assurance arguments.
Policy decisions and argument
Moving from scientific advice and evidence to a policy decision requires that policy-makers consider assumptions, risk acceptance beliefs and tradeoffs (such as between economic and medical impact) that are not often direct and amenable to rigorous scientific examination.13 The transition from scientific conclusions to a policy decision should therefore involve a complex and diverse policy argument that builds on the scientific conclusions, but also brings to bear these additional considerations.17 Imperial College Report 9 contains some explicit suggestions for policy (decisions), but it does not contain a policy argument.9
A good policy argument should justify the reliance on particular sources of scientific advice and models and acknowledge the extent to which the underlying sources of uncertainty in the evidence were considered. The policy argument should make clear how tradeoffs were made and how evidence concerning the economic, legal and ethical implications of the chosen policy was generated and appraised. In the COVID-19 context, such evidence should also incorporate estimation of non-COVID-19 health harms, for example, potential delays in cancer diagnosis and treatment.