Question 1

Do you have recommendations for alternative implementation approaches to those already reflected in the NIH Public Access Policy.

The descriptive information about PMC explains that PMC is not intended to replace the original publication of the journal article, rather to archive them and make them accessible in a particular way.  The integrity of the contents then continues to rely on the editorial selection processes, peer-review processes, and to some extent on the editorial and production work provided by the journal editorial advisors and on the publishers.  In order to present PMC readers with complete information about each article, we recommend that PMC incorporate the name of each journal’s publisher in the primary citation of each article.  Publishers should be offered the opportunity to provide a link through which readers could access the journal’s and publisher’s editorial policies, peer-review standards, and funding sources. 

We are aware of a proposal for an alternative implementation of the Public Access Policy, where NIH would act as a dark archive and provide links to publishers’ web sites.  This proposal would NOT achieve a major goal of the NIH, which is to provide a free, digital and permanent stable archive of biomedical and life sciences journal literature.  For a database to be effectively curated and for the quality of material it contains preserved, it must be used regularly.  Libraries have a long history in dealing with archiving and preservation issues.  We can say emphatically that a dark archive that links to publishers’ web sites is an unacceptable alternative to PMC that NIH has consistently and wisely rejected. 
 
Arizona State University fully supports the NIH Public Access Policy in its current form, and commends the NIH’s extensive efforts to seek input from the full range of stakeholders. ASU also supports the efforts of all to move to implement this congressionally approved policy.  This policy is supportive of our institution’s and higher education’s commitment to making the results of scientific inquiry available as well as enabling the building on the discoveries of others to enhance understanding.  Simply put, the public, as the funding source of this research, is entitled to have free access to the discoveries.  One of ASU’s faculty members commented, “I think NIH’s recent policy of open-access to research results is long overdue.”   

Several parts of ASU worked together to insure our ability to comply with this mandate.  The Office of the Vice President for Research and Economic Affairs communicated multiple times with faculty members already receiving support and has established a mechanism for timely reminders to researchers of the requirement to deposit.  This office worked with the University Libraries to develop useful web pages.  Both of these units encouraged researchers to become familiar with the requirements of the mandate and a webinar on the topic was well-attended.  The Office of General Counsel advised all of us on the issues of copyright management.  

There is mixed opinion at ASU regarding a six month or one-year embargo.  However, it is the case that journals would not be cancelled at ASU for the reason that articles are available in open access repositories.  The pace of science renders ASU faculty members less competitive when subscriptions are canceled.  It was further noted by a faculty member that publisher archives are “more tidy” than the current PUBMED Central. 

It would be useful if NIH would maintain a list of publishers whose author publishing agreements are consistent with deposit to PMC, without additional copyright addendums.  This enables faculty members to “do science” and not be troubled by bureaucracy.

Question 2

In light of the change in law that makes NIH’s public access policy mandatory, do you have recommendations for monitoring and ensuring compliance with the NIH Public Access Policy?

Recognize that it is difficult for institutions to monitor compliance with this policy.  Manuscripts and articles are written and submitted by the principal investigator.  The sponsored projects office does not get involved in this process.  A potential way to monitor compliance is to have NIH ensure that all NIH grant application forms or electronic submission sites include a prompt or field for inclusion of the PMCID on the PI’s cited references that fall within the policy.  Perhaps a routine communication process with campus offices of research could be established to ensure compliance.  

We recommend advice for researchers who encounter one-click copyright agreements during article submission.  

Developing an automated system for alerting institutions when an article has been submitted would be a terrific way to allow institutions to track the submission.  Additionally we would like to harvest or be sent the metadata to place in a local repository to link to research generated at our institution-specific, searchable record of compliance and success in publishing research results.

Advice for researchers who encounter one-click copyright agreements during article submission should be made available.

PMC should develop the functionality to identify how many times a particular article has been accessed in order to add to the growing evidence of increased use of publicly accessible research.

Question 3  

Enhanced and updated FAQs and current information on the NIH Public Access site to help keep researchers well informed.

Update and maintain lists of journals that comply with NIH policy and that do not charge a fee.

Advice directed to publishers.

Question 4  

These comments were prepared by Beth H. Israel, Associate Vice President for Research Administration and Sherrie Schmidt, University Librarian, in consultation with ASU faculty members.