NIH Public Access Plan: Laudable Goal, Misguided Approach
American Physiological Society Analysis
The NIH public access plan is intended to expand
public access to the scientific literature. However, it could have the
unintended consequence of reducing the availability of that literature
because it entails practices that may be economically unsound for many
journals. NIH seeks to impose a “one-size-fits-all” solution, whereas the
publishers of the scientific literature are a large and disparate group.
Furthermore, many publishers already provide the public with some form of
free access to their content.
Although the American Physiological Society (APS)
supports the principle of public access, the NIH approach is a mallet rather
than a scalpel. It is likely to harm publishers, which will in turn harm the
dissemination of science through the literature.
The NIH has offered three rationales for the its
proposal to request that NIH-funded researchers deposit a copy of their
accepted manuscripts in PubMed Central, where they will be made freely
accessible to the public 6 months after publication. Those rationales
include the need to (1) provide the public with access to the science the
agency funds; (2) improve the agency’s ability to manage its research
portfolio, and (3) create an archive of the results of NIH funded research.
The APS responses to these rationales are as follows:
(1)
Since publishers have the responsibility for the financial viability
of journals, they ought to make the determination when to grant access to
content.
(2)
Portfolio management is an internal function that should not involve
public access.
(3)
NIH has not presented compelling evidence why it should create an
additional
biomedical research archive, especially when Society publishers have amply
demonstrated their commitment not only to archive their journals but also to
move into the electronic age by making the content of print journals
electronically accessible.
An additional point of concern is the potential cost of
this ambitious proposal.
Since 2000, the American Physiological Society has
provided free access to back issues of its journals after a 12-month embargo
period. Free access on a timetable consistent with a publisher’s
cost-recovery requirements is one of the basic tenets of the DC Principles
of Free Access to Science (http://www.dcprinciples.org).
The DC Principles coalition currently includes 57 not-for-profit publishers
who publish 125 journals. The DC Principles Coalition also supports a
variety of measures to make content available on an expedited basis for
patients and others who have compelling needs.
NIH officials have asserted that between 30-40% of
biomedical science articles published each year are derived from NIH-funded
research. These relatively low percentages are used to support the claim
that allowing public access to accepted manuscripts after 6 months will not
have undue economic impact on journal revenues since only a minority of
articles will be subject to the NIH policy. Consequently, NIH assumes that
subscriptions and therefore advertising income will be unaffected by its
proposed policy.
However, these assumptions do not hold true across all
journals, and journals that publish basic rather than clinical research are
likely to have a higher percentage of NIH-funded manuscripts. More to the
point, these assumptions do not hold true for the APS journals. In the first
place, the APS journals attract only a trivial amount of advertising
revenue. Secondly, 50% of the articles published in APS journals in 2003
were based upon NIH-funded research. Furthermore, utilization patterns for
physiology research are such that many articles are cited 12 months or more
after publication. Given that the APS already makes back issues free after
12 months, there is good reason to fear that an NIH requirement to make half
our content free after 6 months will lead to a drop-off in subscriptions.
In addition to the harm it may cause to journals, it is
also worth noting that the NIH plan will do little to solve the public
access problem. If only 30-40% of research is funded by the NIH, then the
remaining 60-70% will remain out of reach to the public.
Furthermore, the NIH plan would have negative impacts
on scientists’ opportunities to publish their work. Some journals might
cease publication, while others might have to increase author fees to make
up for lost subscription revenue. According to its September 17, 2004
Federal Register notice
http://www.nih.gov/about/publicaccess/federalregister.pdf, NIH “will
carefully monitor requested budgets and other costing information and would
consider options to ensure that grantees’ budgets are not unduly affected by
this policy.” NIH Deputy Director for Extramural Research Norka Ruiz Bravo
told a September 27 meeting of the FASEB Science Policy Committee that NIH
might impose a cap on how much grantees can spend on publication costs. This
would have the effect of penalizing productive researchers and possibly
delaying the publication of important findings.
NIH claims that it needs copies of manuscripts for
portfolio management and as well as a permanent archive of the research it
has funded. However, these should be purely internal functions. The APS
rejects the notion that NIH should turn PubMed Central into a manuscript
distribution center for the world. It is worth noting that MedLine, which
offers a searchable database of the abstracts of 4,500 journals, is already
widely recognized as an authoritative source of biomedical information. At
present, some 3,000 of those journals – including the APS journals – already
provide links from Medline abstracts to full articles on journal websites.
This is the appropriate arrangement because the published article ought to
be the version of record.
The APS is also concerned about the potential cost of
this ambitious proposal. NIH officials have offered a succession of cost
estimates without supporting details. The most recent estimate was $2
million in FY 2005 and $2-$4 million in subsequent years. There is
skepticism among some publishers about how realistic those estimates are,
which leads to the important question as to whether NIH ought to divert its
increasingly scarce research dollars to this project.
Even beyond immediate consequences, there is reason to
be concerned about the long-term implications of this proposal. Once a
precedent for government intervention in scientific publishing has been
established, publishers will be forced to change how they do business. They
are likely to become more reluctant to make technological investments, to
experiment with innovative policies, or to establish new journals. Their
first duty will be to conserve journals that can survive, and they may
jettison those that are marginal.
In conclusion:
§
The APS believes that the NIH plan represents a misguided
approach that will harm journals without remedying the access problem that
NIH has offered as the primary rationale for the proposal.
§
The APS further believes that its current policy of providing
public access after 12 months through Medline while granting immediate free
access to those with compelling needs fulfills the objectives of NIH
proposal without compromising the financial sustainability of its APS
journal program.
§
To the extent that the NIH policy has the foreseeable
negative impacts described above, the net result will be better access to
less science.
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