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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