NIH Increases Public Access Policy Compliance Efforts
Starting this month, NIH will be stepping up its efforts to ensure compliance
for the Public Access Policy as described in a recent NIH Guide Notice. To
ensure compliance with the Public Access Policy, NIH Program Officials will
check applications, proposals or progress reports to see if citations of papers
appearing to fall under this policy include a PubMed Central Identifier or
appropriate alternative. NIH staff will inform the Program Directors/Principal
Investigators (PDs/PIs) via an email if citations appear out of compliance
and will copy the Institutional Business Official on the email.
The PD/PI will be asked to respond via email to both the Program Official
and the Institutional Business Official with confirmation of compliance, or
an appropriate explanation. Confirmation is the citation for the paper plus
the appropriate identifier as described in the NIH Guide Notice.The NIH Guide
Notice also contains a summary of application instructions pertaining to citations,
and details on demonstrating compliance through the eRA Commons using eSNAP.
For slides, articles, and other training materials and communications about
the Policy, please see http://publicaccess.nih.gov/communications.htm.
Results of the Public Access Public Comment Process
Public comment on the Public Access Policy and NIH’s response is now available at http://publicaccess.nih.gov/comments.htm.
Overview of Feedback
In response to an open meeting and request for information on NIH Public
Access Policy, NIH received 613 unduplicated comments from a broad cross-section
of the public, including NIH-funded investigators, members of the general
public, patient advocates, professional organizations, and publishers. These
comments and NIH’s response are available at http://publicaccess.nih.gov/comments.htm.
Most comments offered broad support for the policy as written. Many comments
requested a reduction in the delay period before papers can be made publicly
available on PubMed Central. In some cases, comments expressed concern about
the Policy, others asked for clarification, and still others suggested alternatives
to NIH’s implementation. These questions and concerns fall into several broad
categories:
- The potential administrative burden on Program Directors/Principal Investigators
and grantee institutions;
- Details such as applicability, cost reimbursement,
compliance monitoring, and enforcement, and publisher support;
- Issues such as submission procedures, tracking submitted papers, version of the
paper submitted, and managing and protecting copyrights;
- The relationship of the Policy to copyright law and the Administrative Procedures Act.
- The potential impact of the Policy on publishers and NIH.
NIH also received
comments describing implementation efforts by numerous awardee institutions
and publishers. In some cases, libraries took the lead on educating their
faculty, and supporting them in interpreting publishing agreements and submitting
manuscripts to NIH. In other cases, offices of sponsored research provided
guidance on the NIH Public Access Policy disseminated to their faculty community
via the web, memos, seminars and VideoCasts. Still other institutions described
collaborations between libraries, offices of sponsored research, university
counsels, and technology transfer offices. Several universities and private
groups described the development of new policies on scholarly communications,
and new publishing forms and addenda that their faculty could use to ensure
compliance with the Policy.
NIH Response
The report details NIH's response to concerns and steps to facilitate compliance
with the law.
- In May, July, and September of 2008 NIH updated the Public Access website
to clarify the applicability, goals and anticipated impact of the policy,
the methods to submit papers, and document compliance.
- In June 2008, NIH updated the NIH Manuscript Submission System (NIHMS), the online mechanism
for submission of manuscripts to PMC, to allow Principal Investigators/Program
Directors (PDs/PIs) to delegate all aspects of submission tasks to authors,
and to allow publishers who submit manuscripts to the NIHMS on behalf of
authors to exert greater control over manuscript delay periods.
- In August 2008, the National Library of Medicine issued a new web tool to help the
scientific community obtain PubMed Central Identifiers in bulk.
- In September 2008, NIH issued a Guide
Notice reminding awardees about the compliance process and providing details concerning NIH’s monitoring plan for Fiscal Year 2008.
Results
These efforts appear to be working. NIH estimates approximately 80,000
papers arise from NIH funds each year, and this total serves as the target
for the Public Access Policy. During the voluntary policy, from May 2005
to December 2007, NIH was able to collect a total of 19% of targeted papers,
from all sources. Under the first five months of the new Policy (April to
August 2008), this rate jumped to an estimated 56% of papers per month.
Conclusions
These first few months show progress in implementing the Public
Access Policy requirement due to active support from the academic and publishing
communities. However, work still remains, as over 40% applicable papers
per month remain unsubmitted.
Implementation and process refinement will
continue in the coming months. NIH has established voluntary partnerships with many publishers to facilitate the depositing of manuscripts and final published papers, and expects these partnerships
to continue to expand, and the percentage of submitted papers to grow. For
example, as of October, approximately 475 journals now directly submit final
published articles arising from NIH funds directly to PubMed Central (see
http://publicaccess.nih.gov/submit_process_journals.htm). NIH will also continue to engage the
community to ensure implementation proceeds in the
most efficient and effective manner possible.
The NIH Public Access Policy, mandated by Congress, requires the results
of NIH-supported research to be publicly available through the National
Library of Medicine’s digital archive, PubMed Central, within 12 months
after the official date of publication. The Policy is intended to advance
science, provide public access to the published results of NIH-funded research,
and improve human health. In order to implement the law in a transparent
and participatory manner, NIH formally sought public input through an open
meeting and a Request for Information (RFI).
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