Question 1 - Do you have recommendations for alternative implementation approaches to those already reflected in the NIH Public Access Policy?
 
The current embargo period of 12 months is longer than necessary to address the economic concerns of publishers who are interested in protecting their subscription revenue stream and is much too long to effectively promote the advancement of research in the sciences.   An embargo period of 6 months would better ensure that the public has access to the published results of NIH funded research.  A 6 month embargo would not endanger the revenues of the publishers because libraries will not cancel journal subscriptions because some articles from a journal will appear in PubMed Central after six months.  
 
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? 

If the NIH manuscript submission process could include a mechanism to notify the institutions of the article’s authors, that information would be very useful to the offices charged with overseeing NIH grant administration.  The notification could be at the time of submission or at the time of depositing in PubMed Central.  An alternative would be the ability to identify articles deposited in PubMed Central by author’s institution and whether funded by NIH.
 
 
Question 3 - In addition to the information already posted at http://publicaccess.nih.gov/communications.htm, what additional information, training or communications related to the NIH Public Access Policy would be helpful to you?
 
It would be helpful if the NIH webpage included an RSS feed so notifications of changes could be promptly distributed.  An RSS feed would help our institution ensure that the materials we have prepared for our faculty and researchers continues to include the most recent information from NIH.    We have found the updated FAQs to be very helpful, but would also appreciate having revisions to the FAQ noted by the date of the revision.  We have also shown some slides from the training PowerPoints in our information sessions with faculty and researchers.  
 
The list of journals that submit final published articles to PubMed Central is very helpful. A similar list of journals which allow submission to PubMed Central in the language of their publishing agreements would also be helpful to NIH grant-funded authors.    
 
Question 4 - Do you have other comments related to the NIH Public Access Policy?
 
Emory University appreciates the opportunity to express its support for the NIH Public Access Policy.  The implementation of this policy on our campus has included ensuring faculty and researcher awareness through a broadcast memo, websites, information sessions and newsletters.  The Libraries and the Office of Research continue to serve as resources for questions and to collaborate on incorporating compliance with the policy into training programs and information sessions for NIH grant recipients.   Implementation of the Public Access Policy has also provided an opportunity for faculty and researchers to more fully understand their rights as copyright owners as well as their obligations under this policy.  A greater understanding of copyright as a bundle of rights and the implications of following the traditional model of transferring ALL of their rights under copyright to publishers has provided an opportunity for faculty and researchers to more thoughtfully consider what rights they want and need to retain when publishing.
 
Although authors must take additional steps when publishing their research to ensure compliance with the NIH Public Access Policy, the availability and accessibility of their research in PubMed is appealing to some faculty members since this is their primary search tool (one faculty member asked how he could get all of his previously published articles deposited in PubMed).  The accessibility in PubMed of articles by members of the Emory community is congruent with Emory’s vision of working for positive transformation by making discoveries that benefit Emory, Atlanta, and the world.   With continued collaboration, the goal of the NIH Public Access Policy to ensure that the public has access to the published results of NIH funded research is both attainable and beneficial to our society.