The NIH Public Access Policy is a legal requirement, as well as a term and condition of award. Awardee institutions may wish to consider the following issues as they implement the Policy.
- The Public Access Compliance Monitor, user guide, an excerpt of an August 2014 webinar for librarians, and a Jaunary 2013 podcast.
- Points of Consideration for Awardee Institutions:
- NIH Applications, proposals and reports: Who ensures that NIH applications, proposals and reports are compliant with the NIH Public Access Policy?
- Training: How are your authors and Principal Investigators (PIs) trained on the NIH Public Access Policy, its requirements and its implementation?
- Publishing Agreements: Who supports authors and PIs in ensuring that publishing agreements comply with the NIH Public Access Policy?
- Monitoring: How can you monitor public access compliance?
On all NIH applications, proposals and reports, PIs are to include the PMC reference number (PMCID) at the end of the full citation of all papers that fall under the Public Access Policy and are authored by them or arise from their NIH award. NIH expects institutions will not send NIH applications, proposals and reports that are inconsistent with the terms and conditions of their NIH awards.
NIH program staff check for compliance with the Policy in the same way that any institutional signing official can- they look for a PMCID at the end of each applicable citation. NIH staff pay particular attention to the progress report publication list and PI biosketches. See http://publicaccess.nih.gov/include-pmcid-citations.htm for more information.
At many universities, libraries have taken on this task. Some train any author or PI upon request, and others work to ensure there is at least one person in every department or unit who can answer author and PI questions. NIH offers training materials that can be downloaded and adapted for your institution.
Also note My NCBI simplifies compliance monitoring. PIs and authors using My NCBI will have an easier time complying with the public access policy and completing their progress reports.
There are many approaches and experts institutions could use to help with this issue. At NIH, we found we needed to change our authorship policies for our employees. We created a publishing addendum and asked our technology transfer coordinators, with help from our counsel, to support our employees in interpreting and negotiating any publishing agreement issues. We require applicable papers to be submitted in accordance with the NIH Public Access Policy before we count them as productivity for an employee or research unit. Our guidance to our employees is publically available. Other institutions have developed similar approaches.
In addition to reviewing applications proposals and reports to NIH for compliance with the NIH public access policy, institutions may wish to use the Public Access Compliance Monitor.
The Public Access Compliance Monitor provides the current compliance status of all journal articles that NIH believes a particular institution is responsible for under the terms of the Public Access Policy. This Compliance Monitor is provided as an information resource only, and does not substitute for official reporting from the institution to the NIH (e.g. a non-competing continuation award). Public access compliance status and grant-paper associations described in the compliance monitor will not impact NIH's evaluation of public access compliance of individual awards. To gain access to the Public Access Compliance Monitor, institutions must first assign a "PACR" role to one or more individuals in their organization. See the user guide for more information.