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Thursday, October 02, 2008

NIH responses to public comments on its OA policy

The NIH has released its Analysis of Comments and Implementation of the NIH Public Access Policy, 2008.  The document doesn't include a month and date, but it was apparently released in the last day or two.  Excerpt:

...The current Public Access Policy is the culmination of years of effort and community interaction. Prior to passage of Section 218 [of the Consolidated
Appropriations Act of 2008], NIH undertook extraordinary public outreach concerning the issue of public access to the published results of NIH-funded research. These outreach efforts included a review of over six thousand public comments and the establishment of an independent advisory group to review NIH’s implementation of a voluntary Public Access Policy. Additionally, as part of the process to implement Section 218 in a transparent and participatory manner, NIH formally sought public input through an open meeting and a Request for Information (RFI) seeking public comment. This open meeting occurred on March 20, 2008 and was designed to ensure that a discussion of stakeholder issues could occur. The feedback from the open meeting helped define questions for an RFI, which was published on the NIH web site on March 28, 2008 and in the Federal Register on March 31, 2008. The RFI was designed to seek input on the NIH Public Access Policy, as it was revised to incorporate Section 218, and the responses to frequently asked questions (FAQs) concerning it. The RFI was open for sixty days following publication in the Federal Register, from March 28 to May 31, 2008.

OVERVIEW OF FEEDBACK ...

In response to the open meeting and RFI, NIH received 613 unduplicated comments from a broad cross-section of the public....

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, commenters expressed concern about the Policy, others asked for clarification, and still others suggested alternatives to NIH’s implementation....

NIH also received comments describing implementation efforts by numerous awardee institutions and publishers....

NIH RESPONSE

NIH carefully considered the views expressed by publishers, patient advocates, scientists, university administrators and others in the comments submitted. Throughout the course of its analysis, NIH undertook various efforts to respond to concerns as it identified them....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 available methods to submit papers, and planned methods to document compliance. In June 2008, NIH updated the NIH Manuscript Submission System (NIHMS)....In August, 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 (NOT-OD-08-119) reminding awardees about the compliance process and providing details concerning NIH’s monitoring plan for Fiscal Year 2008.

These efforts appear to be working. NIH estimates approximately 80,000 papers arise from NIH funds each year, and this total serves as the 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 (see Page 27 current status, in conclusion section for more details). Under the first five months of the Section 218 requirement (April to August 2008), this rate jumped to an estimated 56% of papers per month....

However, work still remains, as over 40% applicable papers per month remain un-submitted....

The body of the report summarizes the individual comments, including objections to the policy (without attribution), along with the NIH's responses.  For example:

...Many comments touched on potential financial impacts of this Policy on publishers. Some claimed that the Policy would be harmful. A subset of these commenters further argued that if Journals are adversely impacted by the Policy, it would harm peer review as a whole. No data demonstrating harm to journals or peer review was submitted.

Some commenters claimed the Policy would not be harmful to publishers. A few publishers described their experience making papers publicly available at 12 months or less, both on or off PubMed Central, without adverse financial impact....

PS:  For background, see our blog post on the NIH's March 2008 meeting and call for comments, our post on the subsequent RFI, a 2 hour 40 minute video of the March meeting, the full-text comments received by the NIH (with attribution), and various slide presentations from the NIH on the comments, including a preliminary version of the new document.

Update.  The document is still undated, but the NIH had added a date to the link on the comments page, September 30, 2008.

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