RFI Comments Results
Public Access Request for Information (RFI)
As of 09/25/2018 at 08:05:31
Total Comments = 111

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Comments Listing - Public Access Request for Information (RFI) - March 28, 2008 to May 31, 2008
Entry Date Last Name First Name Degree Affiliation * City State Country Role
04/04/2008 at 03:36:56 PM Resnick Rachelq MS Abramson Ctr. for Jewish Life/Polisher Research Inst. North Wales PA USA Other
Question 2:  Follow up with grantees each year up to three years after the end of a project to request the citations and PMCID numbers of the articles that have resulted from the research. If none are provided after three years, bar all of the relevant grantee investigators' organizations from receiving further funding until they are in compliance.

05/30/2008 at 02:34:05 PM Russell Ian BSc ALPSP BRISTOL North Somerset UK Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  As mentioned in above, ALPSP believes that NIH should implement measures to ensure that manuscripts deposited in Pub Med Central in response to the Revised Policy are the correct version and that the Revised Policy is therefore implemented in a manner consistent with journal policies and copyright law.

To assist with version control, adherence to copyright law and to minimize duplication of costs, NIH should implement measures to ensure that where manuscripts are deposited by journals on behalf of their authors the submission of duplicate copies or different versions are not accepted for ingress into PubMed Central.

We believe that NIH should implement measures to detect inappropriate usage of manuscripts and other copyrighted material posted on PubMed Central and should immediately alert the publisher of any articles so abused. NIH should also implement specific safeguards to prevent copyrighted material available on PubMed Central from being altered, pirated, made into derivative works, redisplayed, republished, resold or used for any other commercial purpose.


File Link:  ALPSP_Response_to_NIH_RFI.txt
Description:  plain text version of response

05/28/2008 at 01:44:27 PM Case Kathleen MS American Association for Cancer Research Philadelphia PA USA Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  There is no way NIH will be able to monitor effectively the quality of thousands of deposited manuscripts without checking them against a final version on a publisher's website. Such version comparison cannot be automated and would require considerable human resources. There already exist on PubMedCentral papers that should not have been deposited under the previous mandatory policy (too old, wrong versions, not allowed by copyright agreements, etc.). If errors could not be monitored when there were only several thousand papers deposited under the voluntary policy, how could NIH monitor an eventual hundreds of thousands? Compliance would require sanctions to be available, such as lawsuits, fines, withholding grants, or reporting to institutions if a researcher: 1. Fails to load the papers within the timeframe required. 2. Makes mistakes in loading papers (partial text, etc.) or has serious text mistakes in the PMC-loaded papers (later corrected by copy-editing). 3. Publishes in a journal that does not allow deposit in PMC. Is this the role NIH wishes to assume: to punish researchers? If so, how much will NIH spend in becoming a watchdog of author compliance? Will NIH refuse to fund promising research that might lead to cures because the researcher previously failed to load an article on PMC? Consequences for complying with this mandate may cause more harm to the public than noncompliance.

05/30/2008 at 12:42:25 PM Pendleton Andrea   American Association of Anatomists Bethesda MD USA Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  Why Doesn?t Compliance = Compliant?

AAA?s scientific research journals?The Anatomical Record and Developmental Dynamics?are now fully compliant with the NIH?s current public access policy, as mandated by Congress. Upon publication of each issue, our publisher will deposit the final peer-reviewed version of all NIH-funded articles to PubMed Central (PMC) and authorize public availability 12 months after publication. Although we object to the mandate, we are abiding by it.

However, this compliance apparently does not make us compliant enough for NIH. Only journals that make the final published version of NIH-funded articles available to PMC within 12 months will appear on the NIH list of compliant journals, the list that researchers are encouraged to check prior to submitting a manuscript for publication.

Why doesn?t actual compliance with the law entitle a journal to appear on this list? Why is NIH misleading our prospective authors by not acknowledging that we are, indeed, compliant? Isn?t it NIH that is out of compliance for seeking to go beyond the law and penalizing those who are actually fulfilling the terms of the congressional mandate?


File Link:  AAA_Public_Access_Submitted_Response_5-30-08.txt
Description:  Letter on behalf of American Association of Anatomists

05/30/2008 at 10:23:00 AM Crawford Brian Ph.D. American Chemical Society Washington DC USA Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  The attached ACS comments broadly cover all four questions posed by NIH but by extension also cover many issues attendant to a larger more expanded response to each of the questions.


File Link:  ACS_RFI_Submission_053008.txt
Description:  ACS Response to NIH RFI on Implementation of the mandatory public access policy

05/28/2008 at 11:50:38 AM Goodell Heather MIS American Heart Association Dallas TX USA Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  Please see our letter

05/30/2008 at 02:03:36 PM Dylla H. Frederick PhD American Institute of Physics College Park MD USA Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  A useful way to minimize the negative unintended consequences of the current mandatory policy would be to establish, maintain and empower a working group of representatives from the publishing community and the NIH to help guide implementation and modifications to the current policy.

05/30/2008 at 03:15:25 PM Becker Mila JD American Society of Hematology Washington DC USA Other Member of the Public
Question 2:  The American Society of Hematology (ASH) strongly believes that the PMC (NIH Portfolio) Archive Program provides a better alternative for journals and authors than the newly mandated policy. Through this option, NIH obtains one hundred percent compliance in the policy by participating journals because the journals submit to NIH the final version of NIH funded research articles upon publication on behalf of their authors. NIH also has the ability to create a stable archive of peer-reviewed research publications resulting from NIH-funded research and a secure searchable compendium of these peer-reviewed research publications that NIH can use to manage research portfolios and set research priorities. In addition, this program protects the integrity of journal articles by allowing the journal to submit the final article, maintains journal business models by protecting the embargo period and the peer-review system, and, importantly, continues to allow enhanced access of science to researchers and the public. ASH believes NIH should take steps to increase its outreach to other nonprofit publishers to promote participation in this program.


File Link:  RFI_Comments_5-30-08.txt
Description:  ASH Response to NIH Public Access RFI 5-30-08

04/24/2008 at 07:45:43 PM Thiagarajan Balasubramanian Ph.D Annamalai University Annamalainagar Tamil Nadu India Other
Question 2:  No

05/28/2008 at 05:48:50 PM Reichel Mary Ph.D Appalachian State University Boone NC USA Representative NIH Funding Recipient Organization
Question 2:  Our library’s effort in informing more faculty about copyright and developing an institutional repository will work in tandem with the new Public Access Policy as we help to spread awareness of the policy and its importance. In most colleges and universities the library, as well as the institutional Office of Research would be a nexus of information about copyright and granting-agency policies, and help to ensure compliance with the new rules in a clear, consistent fashion.

05/30/2008 at 05:10:29 PM Israel Beth   Arizona State University Tempe Arizona USA Representative NIH Funding Recipient Organization
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.


File Link:  nih_public_access_policy.txt
Description:  nih public access policy.txt

05/29/2008 at 06:29:12 PM Watson Linda MLS Association of Academic Health Sciences Libraries Seattle WA USA Representative NIH Funding Recipient Organization
Question 2:  The process for monitoring is a concern for many of our members. We suggest that NIH consider providing routine communications to research offices on compliance issues.

05/21/2008 at 05:43:29 PM Tagler John Masters of Library & Information Science Association of American Publishers, Professional & Scholarly Publishing Division New York NY USA Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  Many publishers have already been providing free access to authors’ manuscripts or final published articles twelve months after publication or even sooner. NIH does not consider this access compliant with the NIH policy. Would NIH consider including author manuscripts only in its administrative database and archive, while providing public access via display only through publisher sites? If not, what is the rationale for maintaining an unedited manuscript for public consumption if the final, authoritative version has been made available for free access on the publisher’s site?

05/30/2008 at 05:49:30 PM White Patrick M.A. Association of American Universities Washington DC USA Representative NIH Funding Recipient Organization
Question 2:   We offer the following suggestions about how to improve NIH’s implementation of the Public Access Policy’s mandatory submissions requirement.

• We seek NIH’s help in negotiating a blanket permissions agreement with the publishers that will greatly ease the transaction costs that are currently borne not only by individual authors and, by extension their institutions, but also by publishers. What is needed is a modified standard copyright agreement acknowledging that the author retains the right to provide a copy of the final manuscript to NIH for posting by NIH on PubMed Central within 12 months of publication by a given journal. We request that NIH work to encourage publishers to adopt such agreements.

• If, as we hope, more publishers adopt such agreements over time, it would be helpful if NIH maintained and posted an easily accessible and authoritative list of publishers whose author agreements provide blanket permissions for authors to comply with the NIH Public Access Policy.

• NIH might also consider an automatic notification system for designated campus entities (an institution’s Office of Sponsored Research, for example) when a faculty member from that institution has deposited an article in PubMed Central. If the relevant institutional office is also notified when a faculty member receives electronic confirmation that his or her paper has been deposited, institutions would not have to go to additional and unnecessary effort to confirm the transaction.

• As institutions have put significant effort into establishing policies for the submission of articles to PubMed Central, educating and providing technical assistance to faculty, and requiring faculty to certify that they have complied, we would request that NIH develop a “safe harbor” for institutions that have met their responsibilities. If grantee institutions which have made good faith efforts to assure compliance of faculty, we believe such institutions should be shielded from the consequences of non-compliance, especially when that non-compliance arises from circumstances beyond the institution’s control.

• NIH should monitor (or perhaps have a third party such as the National Academies of Science analyze) the impact of the implementation of its Public Access Policy on scholarly publishing and trends in faculty publishing decisions as well as the costs associated with compliance under the new policy.

05/30/2008 at 02:46:02 PM Todaro Julie D.L.S. Association of College and Research Libraries Chicago IL USA Other
Question 2:  Individual campuses are in the best position to explain their needs and circumstances with respect to encouraging and monitoring compliance with the new policy. However, ACRL encourages the NIH to work with campuses on two fronts:

First, establishing routine communication with campus offices of research. These are the campus entities best positioned to ensure consistent, timely communication with investigators who might be planning an NIH grant application. Increasingly, campus offices of research are collaborating with their university libraries to help investigators understand the policy and comply with it, and NIH might consider encouraging such collaboration where appropriate.

Second, collaborating with the institutional repository community -- and with individual campuses that maintain open repositories of the scholarship of their faculty and students -- to identify ways to coordinate manuscript deposit between PubMed Central and institutional repositories, possibly in batch uploads or downloads.

05/28/2008 at 03:16:13 PM Adler Prudence MLS, MA Association of Research Libraries Washington District of Columbia USA Other
Question 2:  It would be helpful if NIH posted and routinely updated a list of publishers whose author agreements permit authors/institutions to comply with the NIH Public Access Policy. It would also be helpful if NIH could automatically notify the appropriate campus entity ( e.g. Office of Sponsored Research, the Library, etc.) when a manuscript or article has been deposited in PubMed Central (PMC). Finally, it would be helpful if NIH would work with academic institutions on coordinated manuscript deposit between PMC and institutional repositories.

04/01/2008 at 02:39:15 PM Rubin Ethel PhD BioFortis Columbia MD USA Other Member of the Public
Question 2:  The only thing for sure is that money talks. If non-compliance carried the penalty of failure or demotion for further rounds of funding, this NIH policy will be a success. Monitoring compliance is difficult. Program managers may need to routinely sweep Pubmed for any of the PIs citation which does not carry the biomed central ID to turn up 'noncompliant papers' before a grant award is made.

A policy without consequences for noncompliance (reward for compliance) is useless.

05/30/2008 at 09:57:40 PM Douglas Kimberly M.A., MSLS California Institute of Technology (Caltech) Pasadena CA USA Representative NIH Funding Recipient Organization
Question 2:  It will be helpful for the NIH to consider the following: 1) Automatic notifications of author institutions when papers are submitted to the PMC, 2)Straightforward search or link in PubMed to identify institution NIH funded papers, 3) Collaboration with institutional repositories to achieve the stated goal of public access in the most cost effective and persistent manner for all.

05/27/2008 at 01:15:09 PM Soules Aline MA, MSLS, MFA California State University, East Bay Hayward CA USA Representative NIH Funding Recipient Organization
Question 2:  One idea is to develop a standard communication process with research offices in institutions to facilitate compliance. One part of that might be an automatic notification system when an institution’s article has been deposited into PubMed Central. I also wonder if there could be some automatic means to create batch deposits/uploads between PubMed Central and institutional repositories. Creating an automated system would save time for all parties.

Finally, it would be helpful if the NIH grant application form/e-submission included a field requiring citation to all previously required PubMed Central deposits as part of ensuring that an application was complete.

05/27/2008 at 01:42:55 PM St. Clair Gloriana Ph.D. Carnegie Mellon University Libraries Pittsburgh PA USA Representative NIH Funding Recipient Organization
Question 2:  The best way to ensure the submission of articles and the inclusion of PubMed Central reference numbers in citations is to delay or prevent the distribution of funds. When investigators see that funding will be impacted, they will comply. The recent addition to the NIH FAQ that provides information about actions the NIH may take when investigators and institutions fail to take steps to ensure compliance with the NIH Public Access Policy is very helpful in this regard.

Concerns about investigators submitting articles to PubMed Central that are not covered by the NIH Public Access Policy can be addressed through education. Concerns about investigators retaining the necessary rights to submit to PubMed Central articles that are covered by the NIH Public Access Policy can be addressed through education and by developing partnerships with more publishers so that the publisher will submit final published articles on behalf of the authors. In the absence of publisher partnerships, NIH must trust the institutions and investigators they fund to comply with the Public Access Policy - just as publishers must trust the authors they publish to comply with the terms of the copyright agreement. Institutions are working to educate faculty about their copyrights and responsibilities, including the NIH Public Access Policy and publisher policies regarding open access.

Some publishers have suggested that NIH should closely monitor submissions to PubMed Central to prevent copyright infringement. This is not feasible because only the author and the publisher know what rights were transferred and what rights were retained. For this reason only copyright owners can legally claim copyright infringement. If copyright infringement occurs in PubMed Central, the copyright owner should notify NIH and the author(s) and the infringing work should be removed from PubMed Central.

Expecting a government agency to monitor and ensure that funded authors comply with publisher copyright transfer agreements introduces a new approach to copyright law enforcement that would have implications far beyond the implementation of the NIH Public Access Policy. Serious consideration of this approach would require a much broader discussion.


File Link:  NIH_RFI_May2008_948.txt
05/29/2008 at 04:31:54 PM Anderson Norman Ph.D. CEO, American Psychological Association Washington DC USA Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  NIH would be well advised to reconsider the burden that it is placing on investigators and institutions and to implement procedures and protections to secure the copyright interests of publishers. These specific concerns are addressed more fully below:

a) Undue Burden on Authors and Institutions

According to the relevant statutory provision, it is the responsibility of NIH, not the institutions or investigators as NIH contends, to “implement the public access policy in a manner consistent with copyright law.” Yet the policy states that “Principal investigators and their institutions are responsible for ensuring all terms and conditions of awards are met.” This even includes the submission of manuscripts that arise directly from the investigators’ NIH-funded research even if they did not author or co-author the publication. In fact, NIH-funded investigators and institutions are being held responsible for making sure that these other authors are “aware of and comply with” the NIH policy. This provision should be removed, because authors cannot reasonably be expected to comply with it.

b) Needed Procedural Changes

As a means to help protect the copyright interests of publishers, the following procedural issues need to be addressed. First, highly visible links need to be put in place in PMC to publishers’ copyright and disclaimer documents, not just to those developed by NIH. Second, any NIH revisions to the publisher-submitted, peer-reviewed manuscript need to be approved by the publisher, as well by as the author, prior to PMC posting, including links to databases and other resources. And third, when there is a publisher agreement in force, the author should not be able to designate an embargo date in PMC and thereby potentially alter an embargo date already agreed upon with the publisher; rather NIH should defer to the embargo policy of that particular publisher.

c) Needed Protections

Also, there needs to be a process in place to determine and monitor whether peer-reviewed manuscripts are and will be appropriately posted in PMC, and if improperly placed by authors, that manuscripts are promptly removed from PMC. In this regard, APA has identified close to 100 peer-reviewed manuscripts of articles published in our journals that have been improperly placed by authors in PMC in violation of copyright (prior to the implementation of the mandatory policy). Furthermore, protections need to be put in place to ensure that third parties cannot exploit PMC-posted content for commercial purposes and that publisher and society trademarks and branding are safeguarded.

04/01/2008 at 06:14:25 PM Snider Marc BS Computer Science citizen Merrimack NH USA Other Member of the Public
Question 2:  I suggest that all publications which [ever] publish articles based on research funded by NIH (public) funds be required to inquire the following of all article authors/co-authors:

1.) Was any of the research encompassed by your article funded using NIH or other public funds?

The aforementioned question should be answered in writing by *all* authors/co-authors listed on all published articles along with that author's/co-author's signature.

In the event that any author or co-author answers 'yes' to the question then the publication (publishing entity) should then be required to submit a copy of that paperwork to the NIH (or pubmed facility). In the event an author/co-author answers the question untruthfully then sanctions should be applied that individual. In the event the document is not properly procured by the publishing entity and/or not submitted to NIH (or pubmed) prior to publication then the sanctions should be attendant upon the publishing entity.

It should also be mandatory for all authors having answered 'yes' to the question to retain a copy of the signed disclosure form so as to indemnify themselves against sanction in such cases as the publishing entity neglected to submit the disclosure form to the NIH.

05/31/2008 at 04:49:09 PM Crews Kenneth J.D., Ph.D. Columbia University New York New York USA Representative NIH Funding Recipient Organization
Question 2:  No response to this question at this time.

05/28/2008 at 02:29:45 PM DeCrappeo Anthony   Council on Governmental Relations Washington DC USA Representative NIH Funding Recipient Organization
Question 2:  The process for monitoring compliance with the policy is built into the policy itself. The requirement for a PMC or NIH Manuscript Submission number on references included in applications, proposals or progress reports will serve as a useful reminder and monitor. Over time, these submission to PubMed Central will become a usual and customary part of process of article publication. We would urge NIH to avoid building a more elaborate monitoring mechanism and rely on the slow but inevitable change in culture.

The near-term problem will be how to address the compliance question with investigators who inadvertently fail to reserve their rights to submit to PubMed Central. We hope that NIH will recognize that this transition will take some time before it is complete. Institutions and investigators will not want to be forced into a position to violate signed copyright agreements

05/31/2008 at 11:49:24 AM Ruben George PH.D. Dartmouth College & Editor-chief-Microscopy Research & Technique Lebanon NH USA Representative NIH Funding Recipient Organization
Question 2:  Since journals are responsible for maintaining proof edited & corrected published paper on line, doesn't it make sense to ask the journals to deposit a web site link with pubMed on the date that an article is published in the paper journal version. The acknowledgements will have to state clearly that the work was funded by NIH for this to occur. This could eliminate a huge expense of independently putting papers onto a Pubmed website and maintaining that website into the future and the final version of the paper will be the same at the journal publisher and at Pubmed. This will also maintain the watermark of the original copyrighted paper.

05/23/2008 at 02:43:02 PM Andreadis Debra   Denison University Granville OH USA Representative NIH Funding Recipient Organization
Question 2:  There should be an automated way for grant offices in universities to be advised of the posting of their researchers' papers in PubMed Central. I also think that grant proposals from those who have previously received grants should require a section for the links to previously published work within PubMed Central.

05/31/2008 at 11:37:44 AM English Ray Ph.D. Director of Libraries, Oberlin College Oberlin OH USA Representative NIH Funding Recipient Organization
Question 2:  1. NIH should track and provide regular and frequent public updates on the percentage of eligible articles that are deposited and made public. 2. NIH should commission a study, or collect data, on any impact that the policy may have on journal subscriptions. Such a study could help resolve the issue of the policy's potential impact on journal cancellations and resultant threats to peer review. As a librarian, I am confident that libraries will not cancel journal subscriptions as a result of the policy. Final peer-reviewed manuscripts in scientific fields (biomedicine in particular) that become available well after publication are not an adequate substitute for current journals. A carefully crafted empirical study could document whether or not my view is valid. It could also document any potential effects from policies that incorporate shorter embargo periods. 3. NIH should maintain a list of publishers that have publishing agreements that are consistent with the policy.

05/29/2008 at 04:49:01 PM Smith Kevin J.D. Duke University Durham NC USA Representative NIH Funding Recipient Organization
Question 2:  Duke has already adopted policies and taken significant steps toward educating our faculty researchers about managing copyright and submitting articles, as detailed in our earlier submission of comments. The information we provide for researchers can be seen at http://www.mclibrary.duke.edu/nihpolicy. The most helpful thing that NIH can do to help us monitor and ensure compliance with the public access policy is to adopt a clear policy and stick with it without significant alteration. A consistent and stable policy will allow institutions to develop their own mechanisms for compliance. Institutions can also use the NIH policy as a part of overall efforts to managing the intellectual property assets created at a university in a more efficient and beneficial way.

04/02/2008 at 01:59:18 PM Labuhn Denis MD Einstein NY NY USA Other Member of the Public
Question 2:  I would suggest immediate and permanent halt of all funding to the investigator and his institution if they do not comply with this destruction of intellectual property. If Universities do not fight this idiocy then make them pay. They should know better than to go quietly but hey no one at a University understands money anyway. It has always come from the Government and the State, AND always will. Why protect the intellectual property they generate? All that counts is continuing to get NIH funding. So threaten to cut if off and see if they respond. They just might.

05/31/2008 at 02:56:21 PM Luce Richard MA Emory University Atlanta GA USA Representative NIH Funding Recipient Organization
Question 2:  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.


File Link:  Emory_University_NIH_Public_Access_Policy_comments.txt
Description:  Emory University NIH Public Access Polcy comments

05/30/2008 at 03:16:04 PM Goni Félix MD FEBS Leioa Bizkaia Spain Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  See our letter under "Question 1".

04/01/2008 at 02:09:30 PM Freytag Richard Masters Freytag & Company, LLC Reston VA USA Other Member of the Public
Question 2:  I suggest that NIH require all recipients of funds when publishing their research acknowledge both the NIH funding but the exact PubMed citation(s) (including URLs for the paper(s) on PubMed). The presence of these URLs will make checking compliance very easy. The absence of the citation will also make non-compliance easy to detect.

05/29/2008 at 10:15:27 AM Green David MA, DPhil Global Journals Publishing Director, Taylor & Francis, Informa plc Milton Park Abingdon UK Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  NIH should establish a formal and ongoing consultative mechanism between NIH and publishers in which NIH and publishers commit to the following specific compliance goals:

1) Ensure that individuals post the correct manuscript version to PMC to be publicly available at the correct time, consistent with publisher agreements 2) For publishers who submit manuscripts directly into PubMed Central, ensure that articles will not be accepted from individuals or entities other than the publisher 3) Create and disseminate to publishers detailed and robust PMC bibliographic usage statistics to monitor and identify piracy and other inappropriate usage of manuscripts and other copyrighted material posted on PubMed Central 4) Identify and implement specific safeguards to prevent copyrighted material available on PMC from being altered, pirated, made into derivative works, redisplayed, republished, resold or used for any other commercial purpose 5) Establish specific procedures, including notification of publishers, that will be implemented if piracy is discovered as a result of downloading content from PubMed Central 6) Ensure that the Policy is, and continues to be implemented in a manner consistent with copyright law

05/12/2008 at 10:50:53 AM Van Orsdel Lee MLS Grand Valley State University Grand Rapids MI USA Other
Question 2:  Universities are prepared to take a role in facilitating compliance with NIH, and a link between the grantees' institutional repository and the NIH would facilitate both monitoring for compliance and the uploading of documents into PMC. Most universities have an office of research, even if the institution is not rated as a research institution. These university officers of research would be the logical contact to work with the NIH in an ongoing, routine manner.

05/18/2008 at 06:12:43 PM Fister Barbara MLIS, MA Gustavus Adolphus College St. Peter MN USA Other Member of the Public
Question 2:  I hope that the researchers involved will understand that their research will reach a wider audience through this process. That has both personal and public benefits.

04/22/2008 at 04:13:56 PM Tooey M.J. MLS Health Sciences and Human Services Library, University of Maryland, Baltimore Baltimore Maryland USA Representative NIH Funding Recipient Organization
Question 2:  One recommendation that I have heard from UMB's research office and from colleagues is that we would like to see a procedure where a notification is sent to the campus office of research when an article from that campus relating to research has been deposited into PubMedCentral. This would close the loop and involve the office of research more closely since the grants and contracts belong to the university, not the p.i. They would be made aware of the PMC ID and could reference it for future communication and tracking.

05/27/2008 at 11:58:14 AM Durniak Anthony BEE and MS IEEE Piscataway NJ USA Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  There are two compliance issues that will need to be monitored: 1) whether the article is submitted at all, and 2) whether the version posted on the NIH’s Pub Med Central is an accurate representation of the published article.

The IEEE sees significant complications in this second issue that will make ensuring compliance difficult. Although the NIH requires that NIH-funded investigators submit an electronic version of the author’s final manuscript resulting from the peer review process, this nuance is likely to cause a difference in the version posted to PMC and the final publisher’s version of the article. In addition, it is our experience that it is challenging to capture the attention of the author to review the copyedited version of the manuscript before it is finally published. Thus, the NIH’s practice of converting the article to XML and then requiring authors to again review the NIH version, after it’s been converted to XML, is redundant and will ultimately cause even a greater difference between the PMC and publisher’s own version of the manuscript. Experienced publishers are aware that conversion to XML needs to be done very carefully in order to avoid introducing errors. How will NIH monitor conversions that it undertakes, and how will it ensure that only errors introduced in the XML conversion process are corrected, while maintaining the integrity of the content itself?

If PMC linked metadata, in lieu of the full manuscript, to the publisher’s web site (for the final version of the manuscript), it will have accomplished its goal of ensuring compliance and meeting the directive to implement the public access policy in a manner consistent with copyright law. Moreover, it will ensure that the production qualities of the manuscripts to which it provides public access are as high as possible.

05/31/2008 at 07:15:53 AM Arunachalam Subbiah M Sc Independent Researcher / Writer Chennai Tamil Nadu India Other Member of the Public
Question 2:  It is OK to have a law in place, but it ill not be of much use if it is not implemented well. It is absolutely necessary to have a mechanim of monitoring compliance of the law and make sure that every author who receives NIH funding deposits the full text of all papers resulting from the NIH funds. There should be a penalty clause for those who fail to comply.

05/26/2008 at 02:39:35 PM Steele Patricia   Indiana University Libraries Bloomington IN USA Other Member of the Public
Question 2:  I believe that the plans for implementation that universities are developing will assure good compliance. Aside from plans NIH already has determined, I have no further monitoring usggestions.

04/01/2008 at 09:28:28 AM Milgram Eric Ph.D. Individual Wake Forest NC USA Other Member of the Public
Question 2:  By making publication on PubMed one of the conditions of receiving a grant, I believe that most people will comply. I recommend clearly stating what penalties a researcher will incur should they not comply with the policy. Also, grants currently are reviewed for progress, and as part of this review process, one of the items should be to check that all peer reviewed publications have been submitted in accordance with the NIH Public Access Policy.

04/28/2008 at 04:41:40 PM Taylor Russell PhD Johns Hopkins University Baltimore Md USA NIH-funded Investigator
Question 2:  See above.

It would help immensely if NIH can pro-actively enter into agreements with the major engineering and medical societies. Within engineering, key would include IEEE (publishes many biomed engineering, medical imaging, and other pertinent journals), ASME, MICCAI, CARS/CAS. There are any number of medical societies as well.

You should delay enforcement of this rule until these agreements are in place.

05/28/2008 at 01:40:09 PM Oliver Kathleen MSLS, MPH Johns Hopkins University Libraries Council Baltimore MD USA Representative NIH Funding Recipient Organization
Question 2:  We appreciate the opportunity to express our support for the NIH Public Access Policy and its implementation as currently stated, and supplement our expressions of support as submitted March 17. The continued engagement of NIH with its stakeholders is both wise and productive.

On May 15, 2008, the Johns Hopkins University Council of Deans voted to require Johns Hopkins University (JHU) researchers supported by NIH funds to retain sufficient rights to all papers published in the course of their NIH-sponsored research. Having retained rights to permit submission to PubMed, JHU faculty members must then submit their articles in a timely fashion. To retain rights, the Council of Deans recommended two alternate addenda and a notification letter that JHU faculty members can employ. The first addendum, http://openaccess.jhmi.edu/ADDENDUM1.pdf, constitutes the bare minimum for compliance with the NIH Public Access requirement. The second addendum, http://openaccess.jhmi.edu/AddendumToPublicationAgreement.pdf, allows faculty members to comply with the NIH requirement while retaining broader rights for their own benefit as apparent from the provisions of this addendum.

The Council of Deans voted to encourage faculty members to use Addendum 2 if possible as it is in every scholar’s interest to retain broader rights to their intellectual products. However, to assure compliance with the NIH mandate, the University requires that faculty members at a minimum use Addendum 1.

05/29/2008 at 12:51:22 PM Courtois Martin Master of Arts Library Science Kansas State University Manhattan KS USA Representative NIH Funding Recipient Organization
Question 2:  Authors/PIs should be responsible for ensuring compliance. Future funding should be contingent on compliance.

A possible avenue for compliance may exist by having authors submit to their academic institution's repository, then export those records and items to NIH. A researcher's local institution may be able to provide assistance with compliance, although this does raise some technical concerns about importing items from various repository platforms.

05/29/2008 at 03:42:57 PM Goetsch Lori MLS Kansas State University Manhattan Kansas USA Representative NIH Funding Recipient Organization
Question 2:  Institutions like my own have already committed to compliance as currently outlined, and the library is part of the effort to inform and educate our university community. I encourage efforts to develop and support automated means of deposit such as batch uploading or downloading to facilitate compliance.

05/17/2008 at 10:15:31 AM Firnhaber Gina MSN, MLS Laupus Library, East Carolina University Greenville NC USA Other
Question 2:  I think ensuring public access should be included as part of the grant process, not left up to individual researchers or organizations to police. If this requirement is written into the grant and followed up as such compliance will not be an issue.

05/30/2008 at 04:45:26 AM Herrmann Guido F. PhD, MBA Managing Director Thieme Chemistry, Thieme Publishers Stuttgart Germany Germany Publisher (including Commercial Organizations, Professional Societies and Journal Editors)
Question 2:  NIH should establish a formal and ongoing consultative mechanism between NIH and publishers in which NIH and publishers commit to the following specific compliance goals:

1)Ensure that individuals post the correct manuscript version to PMC to be publicly available at the correct time, consistent with publisher agreements 2)For publishers who submit manuscripts directly into PubMed Central, ensure that articles will not be accepted from individuals or entities other than the publisher 3)Create and disseminate to publishers detailed and robust PMC bibliographic usage statistics to monitor and identify piracy and other inappropriate usage of manuscripts and other copyrighted material posted on PubMed Central 4)Identify and implement specific safeguards to prevent copyrighted material available on PMC from being altered, pirated, made into derivative works, redisplayed, republished, resold or used for any other commercial purpose 5)Establish specific procedures, including notification of publishers, that will be implemented if piracy is discovered as a result of downloading content from PubMed Central 6)Ensure that the Policy is, and continues to be implemented in a manner consistent with copyright law

05/22/2008 at 01:31:10 PM Canizares Claude Ph.D. Massachusetts Institute of Technology (MIT) Cambridge MA USA Representative NIH Funding Recipient Organization
Question 2:  While MIT applauds this new Public Access Policy, our recent implementation efforts have suggested several approaches that would be useful moving forward: • To the extent that publishers can be encouraged to reduce or eliminate delays in public access from the current 12-month maximum, MIT’s and society’s goals will be more fully served, without any impact on library subscriptions. (The NIH policy, which affects only some articles in some journals, will not alter the purchase of subscriptions at MIT.) • The development of inter-institutional partnerships could simultaneously support authors, universities, and the overall goals of the policy: o Collaboration between NIH and universities to develop methods for exchanging data and papers between PMC and institutional repositories could maximize efficiencies in making research openly available. o Collaborations between publishers, universities, and NIH to develop institutional policies and systems would reduce the burden on individual authors in complying with the policy. During this phase, while compliance with the policy lies largely in the hands of individual authors and relies on adequate rights retention when publishing, we need the full cooperation of publishers, particularly in smoothly accepting amendments to standard publisher agreements. • More immediate, smaller changes from NIH would smooth efforts to comply with the policy, including: o Notifying the grantee when a relevant paper is submitted to PubMed Central (whether by publisher, author, or third party). o Altering workflows such that it would be possible to construct a simple PubMed search that consistently offers an exhaustive list of papers affiliated with an institution and funded by NIH. o Indexing all NIH funded papers, not just those published in life sciences journals, in PubMed.

04/04/2008 at 02:24:06 PM Reinhard Robert M.A. Member Community Advisory Board, ACTG and HVTN within NIH San Francisco CA USA Patient or Representative of a Public Health Advocacy Organization
Question 2:  In any future grant applications, the application form or electronic submittal should include a field requiring citation to all previoulsy required pubmed central deposits, failure to cite would be considered reason to return the application as incomplete

04/04/2008 at 10:25:41 AM Buchwald Stephen Ph.D. MIT Department of Chemistry Cambridge MA United States NIH-funded Investigator
Question 2:  Although at first blush it sounds like a bad idea, requiring publishers to do this in order to submission to their journals will quickly get everyone to go along with my suggestion in question 1.

04/27/2008 at 11:58:10 PM Burack Jeffrey J.D. n/a New York NY USA Other Member of the Public
Question 2:  Create an easy-to-use form/link that allows members of the public to easily and anonymously report access violations. For instance: "report an access violation," or "Having trouble gaining access?"

05/16/2008 at 03:34:01 PM Emmett Ada   n/a Lawrence KS USA Other Member of the Public
Question 2:  In addition to the methods currently in place perhaps the institution/agency that monitors the grant for the individual researcher, should supply documentation of compliance.

04/04/2008 at 11:25:23 AM sanders pat ged na bennington nh USA Other Member of the Public
Question 2:  no

04/04/2008 at 11:25:28 AM sanders pat ged na bennington nh USA Other Member of the Public
Question 2:  no

05/22/2008 at 02:15:09 PM Roberts Richard Ph.D. New England Biolabs Ipswich MA USA Other
Question 2:  NIH must talk to the publishers so that they assist in this endeavour. The sooner the publishers are convinced that this move to open access is inevitable then the sooner they will be prepared to help make it happen. This will require talk and good faith negotiations. Ultimately, it is funding agencies like the NIH that has the clout to make it work. We sacientists can only help by publishing in compliant joournals, refereeing for compliant journals and serving as editors for them. This does give us some bargaining chips, but far less than the NIH and the other finding agencies.

04/01/2008 at 04:29:25 PM Silterra Jacob B.S. None Cambridge MA USA Other Member of the Public
Question 2:  I would recommend that any institution which receives a certain level of funding from NIH be required to notify NIH whenever any research, even non-NIH funded research, is published. They wouldn't need to send the article, or make it publicly available, just notify NIH they published something. This would make sure that NIH could track publications, so they could easily monitor whether works being published privately should also be published publicly.

04/01/2008 at 03:38:07 PM Hulbert II Leland   None Gloversville NY USA Other Member of the Public
Question 2:  Any applicant for NIH funding can be searched for previous NIH funded projects. These projects would then be checked to verify that their final results exist in the public repository. Any previous publicly funded project that has not been already published in the public archive would bar the applicant from receiving any future funding. This will make the applicants themselves responsible for policing the policy.

05/27/2008 at 09:02:42 AM Eaton Nancy MLS Penn State University University Park PA USA Representative NIH Funding Recipient Organization
Question 2:  While Penn State University recognizes the concerns expressed by the publishing industry and others we feel these are largely unfounded. We reiterate the following: • Encourage publishers to reduce barriers to submission and work with authors to ensure compliance with both the policy and copyright law. • The NIH Policy affects only articles supported by NIH funding. This is a subset of all the articles published and affects only certain articles across a large cross-section of journals. University Libraries has no plans to cancel journals as a direct result of the policy. In addition both the 12 month embargo and the requirement for the author’s final peer-reviewed manuscript prevent this. • Retain a list of publishers whose publishing agreements take into consideration the need for depositing with PubMed Central consistent with copyright law. Continue to update the list of publishers who directly submit articles to PMC. • Consider developing a process for communicating with campus offices of research in order to ensure compliance. • Consider developing an automated approach to coordinating deposit between PMC and institutional repositories. • Consider some type of automated notification that would be sent to the institution/campus office for research when articles are submitted. • Provide a mechanism to construct a simple PubMed search that would provide an exhaustive list of papers affiliated with an institution and funded by NIH.

04/01/2008 at 12:46:10 PM Dante Doug Bachelors Personal Detroit MI USA Other Member of the Public
Question 2:  All NIH funded grants subject to the public access requirement should be available to the public on a web site with information at the time that the grant is made. All grants not subject to that requirement should also be listed and a reason why they can't be given to the public should be included. (e.g. National Security)

04/01/2008 at 03:42:50 PM Cook Andrew PhD Physics Eugene OR USA Other Member of the Public
Question 2:  Let professionals in the field report on transgressions. Let the NIH without a portion of funds from researchers who don't allow their material to become publicly available.

05/30/2008 at 12:24:58 PM Connolly Anne   Research Foundation of SUNY (RF) Albany NY USA Representative NIH Funding Recipient Organization
Question 2:  The Research Foundation of State University of New York (RF) provides these thoughts as recommendations for the NIH to consider for monitoring and ensuring compliance, from actions being discussed by some of the State University of New York (SUNY) campuses. 1. SUNY campuses have discussed adding questions to their application routing forms and the yes/no questions of the COEUS system to identify if investigators have and/or plan to publish manuscripts supported by NIH grants. 2. SUNY campuses also plan to implement a review process when investigators submit their noncompetitive continuation applications to assure the publications are duly noted along with the PubMed Central numbers.

05/13/2008 at 09:00:24 AM Miller Jonathan MLS Rollins College Winter Park Florida USA Other
Question 2:  See my answer to question 1.

04/01/2008 at 02:44:18 PM Ritchie Thomas B.S. of Biology Rutgers University New Brunswick NJ USA Other
Question 2:  Provide a means for the scientific community, even individuals acting independently from their organization, to anonymously report to the NIH any compliance violations. There are enough of us interested in keeping the scientific knowledge gained open and available to the public that this should provide a good level of oversight without much overhead cost.

05/30/2008 at 04:46:29 PM Boyle Jeanne MLS Rutgers University Libraries New Brunswick NJ USA Representative NIH Funding Recipient Organization
Question 2:  We have invested considerably to ensure that Rutgers scholars comply with the requirements of the current legislation. The libraries have played a lead role in formulating university policies on copyright and ensuring that scholars and library services conscientiously observe copyright. Copyright education needs to be a part of every institution’s compliance with the policy. It is to the benefit of both authors and publishers that this conversation takes place. The NIH Open Access policy has enabled our education efforts as no other event has before.

We believe the rate of compliance would benefit from two developments: 1) having the final PMC version of an article sent for verification to both the principle investigator and the lead author listed on the article and accepting verification from one or the other, and 2) developing a strategy for working with publishers which use click through licenses that allow no negotiation.

05/22/2008 at 10:07:06 AM Van Kampen Doris Ed.D Saint Leo University New Port Richey FL USA Representative NIH Funding Recipient Organization
Question 2:  Streamline the process and put strings on some of the funding - if needed, mandate within the grant that the researcher and the publisher not be allowed to publish the article until it is also available through the NIH, or some funding will be withheld.

04/04/2008 at 05:27:23 AM Salamon Peter PhD San Diego State University San Diego CA USA Other Member of the Public
Question 2:  No.

05/30/2008 at 01:19:29 PM Sinn Robin MS Sheridan Libraries; Johns Hopkins University Baltimore MD USA Other Member of the Public
Question 2:  Not particularly. NIH has been very good about providing opportunities for feedback from everyone involved. If the current procedures don't work, I'm sure NIH will involve everyone in improving those procedures.

05/29/2008 at 10:34:08 PM Dobbs Aaron MSLS, MSM Shippensburg Univeristy of Pennsylvania Shippensburg PA USA Other Member of the Public
Question 2:  Consider developing routine communication process with campus offices of research to collaborate on ensuring compliance

Consider automatic notification to be sent to the campus office of research when an article from that institution has been deposited into PubMed Central

Consider automatic means of coordinating manuscript deposit between PMC and institutional repositories, possibly in batch uploads or downloads. (Indicate if you or your institution would be willing to help facilitate).

All future grant NIH applications should include a field requiring citation to all previously required PubMed Central deposits; failure to cite would be considered reason to return the application as incomplete

05/31/2008 at 03:01:06 PM Newcomb Douglas Master of Science Special Libraries Association Alexandria VA USA Other
Question 2:  It would be usefull to have the NIH produce a list of publishers whose author publishing agreements provide for deposit with PMC in a manner that is consistent with copyright law.

05/30/2008 at 11:15:43 AM Joseph Heather MS The Scholarly Publishing and Academic Resources Coalition Washington DC USA Other
Question 2:  We encourage the NIH to closely monitor key aspects of the Public Access Policy’s implementation, including: 1) Experience of publishers with six-month or shorter embargos: It is in the public's interest to reduce the duration of the public access embargo to as short a period as possible. NIH should collect data on the sustainability of biomedical journals that offer open access within six months of publication in order to evaluate the potential to reduce the maximum PubMed Central embargo. and 2) Extent to which eligible articles are captured in PubMed Central: For the policy to succeed, it is imperative that deposit of articles from NIH-funded research be nearly universal. We trust the agency will track this and take reasonable, appropriate steps to ensure success.


File Link:  SPARC_NIH-PA_RFI_FINAL_TXT.txt
Description:  SPARC Response to NOT-OD-08-060

05/13/2008 at 03:39:18 PM Koopman Ann M.A. Thomas Jefferson University Philadelphia PA USA Other
Question 2:  I am concerned that some researchers will regard the policy as just so much busy work, and will ignore it or seek ways to avoid compliance. Early feedback from our research staff includes a fair amount of irritation at the additional requirement.

05/29/2008 at 04:53:38 PM Graves Diane MLn Trinity University, San Antonio, TX San Antonio TX USA Representative NIH Funding Recipient Organization
Question 2:  RE: the proposal of an alternative implementation of the Public Access Policy, with NIH acting as a dark archive, providing links to publishers' web sites. In effect, this would limit public access and thereby defeat the intent of the program. From a library perspective, I don't see this as an effective, feasible, or reliable alternative. Public access to a collection of publicly funded research is what is needed, not a dark archive. In many cases, PORTICO is answering that need, which addresses long-term preservation, not public access.

04/30/2008 at 03:49:03 PM Lackner andrew DVM, PhD Tulane University Covington LA USA NIH-funded Investigator
Question 2:  NIH should rely more on the journals to have the materials submitted and strongly discourage people from submitting to journals that don't follow the policy.

04/09/2008 at 09:25:24 PM Kobertz William Ph. D. UMASS Medical School Worcester MA USA NIH-funded Investigator
Question 2:  Compliance is going to be poor since the current help on the NIH website is confusing for even the most computer savvy person. Compliance could be improved if the uploading process was included in the eSNAP portion of the progress report.

04/03/2008 at 04:37:20 PM Williamson Peter MD/PhD Univ IL at Chicago Chicago IL USA NIH-funded Investigator
Question 2:  Providing funding by NIH for the increased burden of this regulation to the investigator would serve to improve compliance.

04/01/2008 at 11:09:13 PM DuBose Terry MS, RDMS Univ. Arkansas for Medical Sciences Little Rock Arkansas USA Representative NIH Funding Recipient Organization
Question 2:  The more widely available the publications, the better.

04/01/2008 at 12:53:03 AM Ammann Arthur MD Univeristy of California San Rafael CA USA Patient or Representative of a Public Health Advocacy Organization
Question 2:  you may already have in place a reporting procedure. I review many articles for our web site www.womenchildrenhiv.org - we are frustrated by not being able to provide the full text articles. As you know the abstracts are often inaccurate and often are not supported by the data in the text. It is essential that individuals with limited access to the Internet such as in resource poor countries be provided fulltext PDF articles.if after one year such articles are not available to who would report a violation and would receive a response so that we could go ahead with publication of fulltext articles?

03/31/2008 at 02:03:22 PM Harnad Stevan PhD Universite du Quebec a Montreal & Southampton University Montreal Quebec Canada Representative NIH Funding Recipient Organization
Question 2:  Yes. The optimal way to monitor and ensure compliance is by making it part of the fulfillment conditions for the fundee's institution that it must monitor and ensure that the deposit is made.

The best and easiest way that an institution can monitor and ensure deposit -- and at the same time encourage or mandate the self-archiving of all the rest of the institution's research output in all disciplines (not just NIH-funded research) -- is to require direct deposit in the institution's own IR.

See: "How To Integrate University and Funder Open Access Mandates" http://openaccess.eprints.org/index.php?/archives/369-guid.html

05/31/2008 at 02:44:29 PM Gallant Caroline Ph.D. Universities Allied for Essential Medicines & McGill University Cambridge Massachusetts USA Representative NIH Funding Recipient Organization
Question 2:  In order for the policy to be effective, enforcement needs to carry a true penalty for failure to comply. For example, in all future NIH grant applications, it should be mandatory that references are included to all previously required PubMed Central deposits. Lack of monitoring and ensuring compliance has led to regular underreporting of university inventions to federal funding agencies under the Bayh-Dole Act.

04/28/2008 at 11:52:47 PM Cutter Gary PhD University of Alabama Birmingham AL USA NIH-funded Investigator
Question 2:  Yes, NIH take a stand, state the policy and boycott journals that do not adhere to this principal.

05/27/2008 at 07:43:51 PM Lee Daniel M.A., M.L.S. University of Arizona Tucson Arizona USA Representative NIH Funding Recipient Organization
Question 2:  Easing the submission process will help ensure compliance. In general, researchers want to share their results. The low rate of participation in the voluntary program is a reasonable indication that the submission process is/was seen as a barrier.

05/30/2008 at 06:39:32 PM Hume Wyatt R. Ph.D. University of California Oakland CA USA Representative NIH Funding Recipient Organization
Question 2:  The development of the simplified procedures described Question 4 below and in the attachment would represent a great stride in reducing barriers to compliance for PIs and institutions and consequently would significantly diminish the need for case-by-case monitoring. In addition, in view of the complexities discussed above, we believe it important for NIH to acknowledge that full implementation of the policy and associate compliance measures will require an extended period of transition from current practices. It will be important not only to provide clarifications that will be helpful to investigators and their institutions, as suggested in the response to item 3 below, but to provide assurances that any penalties for non- compliance will not be unreasonably applied as long as significant uncertainties remain.


File Link:  U-Cal_public-access-policy_2008-05-30.txt
Description:  University of California comments on the NIH public access policy

05/29/2008 at 12:53:47 PM Butter Karen ML University of California, San Francisco San Francisco CA USA Representative NIH Funding Recipient Organization
Question 2:  Citing the PMCID in regular grant reports and new grant proposals is an effective step toward monitoring compliance with the Public Access Policy.

One way to increase incentives for compliance is for NIH to collaborate closely with campus research officers, who have more direct contact with researchers. Whenever an article from any institution is successfully deposited in PubMed Central or the NIHMS, the appropriate campus research office should be notified.

04/30/2008 at 02:59:24 PM MacLennan John PhD University of Cincinnati Cincinnati OH USA NIH-funded Investigator
Question 2:  No

04/01/2008 at 01:50:27 PM Foster Ryan PhD Candidate University of Florida College of Medicine Gainesville FL USA NIH-funded Investigator
Question 2:  Ensuring compliance is quite simple really. In grant renewal applications, only allow researchers to cite their own papers from the public access database.

When applying for grant renewals, researchers cite the papers that resulted from the last iteration of that grant. Kind of a track record proving that the grant generated real advances in the field and thereby making a case for continuing to fund that grant. If researchers were compelled to cite only their public access papers they would fall all over themselves to do so.

05/16/2008 at 02:50:17 PM Lewis Margaret   University of Illinois Champaign Ill. USA Other Member of the Public
Question 2:  No

05/30/2008 at 12:03:02 PM Case Mary MALS University of Illinois at Chicago Chicago IL USA Representative NIH Funding Recipient Organization
Question 2:  We recommend advice for researchers who encounter one-click copyright agreements during article submission.

05/29/2008 at 01:25:46 PM Newman Kathleen PhD University of Illinois Library Urbana IL USA Representative NIH Funding Recipient Organization
Question 2:  I think the current plan of tying compliance to the possibility of obtaining future grants is adequate.

05/27/2008 at 04:00:09 PM Baker Nancy MLS, MA University of Iowa Iowa City Iowa USA Representative NIH Funding Recipient Organization
Question 2:  As noted above, an automatic, routine process for communicating with campus research offices when an article has been deposited into PubMed Central would assist compliance. For those universities with institutional repositories, some automatic way that manuscripts could be submitted jointly deposited would be helpful. Any additional ways that NIH might make the submission of articles easier for authors in the future as technologies improve would be welcomed.

05/15/2008 at 10:25:28 AM Mercer Holly MLIS University of Kansas Lawrence KS USA Representative NIH Funding Recipient Organization
Question 2:  It would be helpful if NIH posted and routinely updated a list of publishers whose author agreements permit authors/institutions to comply with the NIH Public Access Policy. It would be helpful if NIH could automatically notify the Office of Research and Graduate Studies or the KU Libraries when an article has been deposited in PubMed Central.

It would be helpful if NIH would work with academic institutions on coordinated manuscript deposit between PubMed Central and institutional repositories.

05/28/2008 at 04:00:29 PM Galea Sandro MD, DrPH University of Michigan Ann Arbor MI USA NIH-funded Investigator
Question 2:  The integration of PMIDs in progress reports and the links between PMIDs to the public repository should take care of compliance. It is hard to see how an NIH funded investigator can get around this.

05/29/2008 at 05:04:56 PM Lougee Wendy MA, MLS University of Minnesota Libraries Minneapolis MN USA Representative NIH Funding Recipient Organization
Question 2:  We urge the NIH to work with all stakeholders to reduce the administrative burden of compliance on institutions and authors, and to streamline the process wherever possible. One example would be for NIH to generate a message to the institution upon the deposit of a manuscript for their respective authors. Ideally, over time, our authors will have ensured the right to deposit these manuscripts in institutional repositories as well as PubMed Central. When that is the case, we would like to see an efficient mechanism for the PubMedCentral manuscript to also be deposited in our own IR.

The submission process would be facilitated by the availability of a comprehensive, up-to-date location for recording individual publisher policies. NIH could work with SHERPA and others to create and maintain this and integrate it with the submission system. NIH should work to influence additional publishers to participate as “fully compliant” partners.

In addition, NIH should ensure that all NIH grant application forms or electronic submission sites include a prompt or a field for inclusion of the PMCID on the PI’s cited references that fall within the policy.

PubMed Central 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.

05/28/2008 at 12:38:31 PM Mullaly-Quijas Peggy PhD University of Missouri - Kansas City Kansas City MO USA Other
Question 2:  I would make this policy no different than the other policies that PIs must follow when receiving NIH funding.

05/30/2008 at 02:41:48 PM Giesecke Joan Doctorate University of Nebraska-Lincoln Lincoln Nebraska USA Other
Question 2:  Anything NIH can do to notify the campus research compliance office when an article is deposited would be helpful. While the faculty will be notified, it will help campus accounting to have the information directly from NIH.

05/29/2008 at 03:46:16 PM Michalak Sarah MLS University of North Carolina at Chapel Hill Chapel Hill NC USA Representative NIH Funding Recipient Organization
Question 2:  UNC-Chapel Hill has signaled our commitment to open access and to the NIH open access policy by providing institutional education, training, and financial support (http://www.hsl.unc.edu/scholcom/OAFundAnnounce.cfm) to facilitate compliance by our researchers. It would be a benefit to our office and our efforts to receive automatic notification whenever an article has been deposited by a UNC researcher.

UNC is also developing an institutional repository and would welcome a means to coordinate manuscript deposit between PubMed Central and the repository. We would eagerly participate in, facilitate, test, or otherwise help to advance such an arrangement.

05/29/2008 at 03:46:52 PM Michalak Sarah MLS University of North Carolina at Chapel Hill Chapel Hill NC USA Representative NIH Funding Recipient Organization
Question 2:  UNC-Chapel Hill has signaled our commitment to open access and to the NIH open access policy by providing institutional education, training, and financial support (http://www.hsl.unc.edu/scholcom/OAFundAnnounce.cfm) to facilitate compliance by our researchers. It would be a benefit to our office and our efforts to receive automatic notification whenever an article has been deposited by a UNC researcher.

UNC is also developing an institutional repository and would welcome a means to coordinate manuscript deposit between PubMed Central and the repository. We would eagerly participate in, facilitate, test, or otherwise help to advance such an arrangement.

05/30/2008 at 04:01:53 PM Johnson JQ M.A. University of Oregon Libraries Eugene OR USA Representative NIH Funding Recipient Organization
Question 2:  - Change electronic forms to require PMCID as appropriate.

See response to Q4 for expansion.

04/15/2008 at 01:14:45 PM Myers Gary MD University of Rochester Medical Center Rochester NY USA NIH-funded Investigator
Question 2:   A simple search of the literature by a central office on each investigators name would determine compliance and then reminders could be sent.

04/03/2008 at 02:32:40 PM Watson Cheryl PhD University of Texas Medical Branch Galveston TX USA NIH-funded Investigator
Question 2:  Keep it simple. Require that all publications be made available immediately. Then you will not have to manage it in such a complicated way.

05/29/2008 at 12:12:03 PM Mower Allyson MA University of Utah Salt Lake City UT USA Representative NIH Funding Recipient Organization
Question 2:  The current method seems sufficient.

05/29/2008 at 06:54:21 PM Ogburn Joyce MSLS, MA University of Utah, University Librarian Salt Lake City UT USA Representative NIH Funding Recipient Organization
Question 2:  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 our repository to link to research generated at our institution. We would then have an institution specific, searchable record of compliance and success in publishing research results. The Marriott Library has developed software to enable easy deposit of articles and we would be interested in working with the NIH on envisioning an alert system that works with repositories.

04/28/2008 at 03:55:37 PM Emery David PhD University of Washington Seattle WA USA NIH-funded Investigator
Question 2:  See answer to Question 1 above. The NIH should take the responsibility of implementing the public access policy, not individual investigators.

05/29/2008 at 12:19:39 PM Cameron-Vedros Crystal MLS Univesity of Kansas Medical Center Kansas City KS USA Representative NIH Funding Recipient Organization
Question 2:  Consider developing routine communication process with campus offices of research to collaborate on ensuring compliance Consider automatic notification to be sent to the campus office of research when an article from that institution has been deposited into PubMed Central Consider automatic means of coordinating manuscript deposit between PMC and institutional repositories, possibly in batch uploads or downloads. (Indicate if you or your institution would be willing to help facilitate). Make sure that, in all future grant NIH applications, the application form or electronic submission includes a field requiring citation to all previously required PubMed Central deposits; failure to cite would be considered reason to return the application as incomplete

05/19/2008 at 12:33:39 PM Reiter Allan PhD US DoD, Defense Threat Reduction Agency Ft. Belvoir VA USA Other
Question 2:  A web site where apparent lapses can be reported for compliance and follow-up.

04/01/2008 at 12:18:33 PM Romans Ehs PhD UT Arlen TX USA NIH-funded Investigator
Question 2:  `NOW YOU LISTEN TO ME. PUBLIC TAX PAYER MONEY MEANS YOU NEED TO KEEP THE SYSTEM ___OPEN___

04/01/2008 at 08:33:01 PM yu hong phd uw-milwaukee Milwaukee WI USA NIH-funded Investigator
Question 2:  Since PubMed is widely used by biomedical researchers, NIH may demand that an article can only be indexed by PubMed if it is compliant with the PAP.

05/02/2008 at 05:53:11 PM Boothby Mark M.D., Ph.D. Vanderbilt University Nashville TN USA NIH-funded Investigator
Question 2:  Yes.

First, honestly consider and implement ways of using PubMed / PMID with autouploads to PMC as a mechanism - the simpler things are, the less the time, and the more transparent (and less high-handed) NIH behaves, the better the compliance will be).

Second, as noted above, monitor whether the NIH-funded investigator’s work becomes publicly accessible (free of charge other than internet access) within a year of publication date (or, in cases when journals use an e-publication date that is earlier than the print date, set the clock going at the ePub date.

Third, minimize the loss of precious $$$ that will be wasted on pig-headed insistence on imperfect, cost-wasteful means of implementing the policy by using accepted principles of statistical sampling (auditing) for purposes of reporting to Congress on the progress each year from 4% compliance (NIH Open Access voluntary) to xy % compliance (Open Access mandatory).

Fourth, during at least the first two years, monitor and ensure compliance in line with principles used for monitoring and accepting compliance with laws such as the speed limit on interstate highways (speed kills, short-term shortfalls in public access do not).

If the NIH and Congress are really serious about enhancing research, and making taxpayer $$$ be used in the most effective ways possible, it should direct its effort more toward effective enforcement of the mandate that unique reagents (mouse lines, plasmids, etc) be shared in a timely and effective manner, in line with written investigator assurances that they will do so [and, for that matter, better screening for overlap in funding between R01’s and PPG’s, etc] than toward the flawed NIH choice of system for achieving Open Access.

05/01/2008 at 10:59:25 AM Sweet Douglas PhD VCU Richmond VA USA NIH-funded Investigator
Question 2:  N/A

05/28/2008 at 12:58:30 PM Baker Shirley K. MA, MA Washington University St. Louis Missouri USA Representative NIH Funding Recipient Organization
Question 2:  Ensure that publishers cooperate with the NIH in implementation of this Policy. Monitor the information publishers are providing to authors to make sure it accurately represented the Policy.

03/31/2008 at 06:09:49 PM Gudas Lorraine PhD Weill Cornell Medical College New York New York USA NIH-funded Investigator
Question 2:  No, I don't think the policy is wise or necessary.

04/28/2008 at 03:19:38 PM Brash Douglas PhD Yale School of Medicine New Haven CT USA NIH-funded Investigator
Question 2:  no

05/23/2008 at 03:36:05 PM Brash Douglas PhD Yale School of Medicine New Haven Connecticut USA NIH-funded Investigator
Question 2:  no; inclusion of our own PMCID numbers in our grants is ok

Total Comments = 111

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