Preparing for Upcoming Federal Public Access Policies: What Does it Mean for School of Medicine Researchers?

By , , , , and — October 18, 2023

In August 2022, the White House Office of Science & Technology Policy (OSTP) issued a memo: Ensuring Free, Immediate, and Equitable Access to Federally Funded Research (OSTP 2022 Nelson Memo), that directs federal agencies to update their public access policies per OSTP 2013 Holdren Memo.

The policies pertain to publications, scientific data underlying publications, and scientific and research integrity which includes identifiers for researchers. The good news is that the proposed policies for publications and scientific data mirror existing NIH policies.

We expect research projects funded by federal agencies in 2025 and beyond to be affected by new policies and procedures.

Publications

  • All scholarly publications resulting from federally funded research should be made freely available and publicly accessible upon publication in agency-designated repositories.
  • Zero embargo.[1]
  • Federal agencies will be required to publish their policies no later than December 31, 2024.
  • Federal agencies will be required to implement updated policies no later than December 31, 2025.

Scientific Data

  • All scientific data resulting from federally funded research should be made freely available and publicly accessible upon publication in agency-designated repositories.
  • Zero embargo.[2]
  • Federal agencies will be required to publish their policies no later than December 31, 2024.
  • Federal agencies will be required to implement updated policies no later than December 31, 2025.

Scientific and Research Integrity: Identifiers for Researchers

  • Federally funded researchers will be instructed to obtain a Digital Persistent Identifier (DPI) that meets the common/core standards of a digital persistent identifier service defined in the NSPM-33 Implementation Guidance, and include it in published research outputs.
  • Federal agencies will be required to publish their policies no later than December 31, 2026.
  • Federal agencies will be required to implement updated policies no later than December 31, 2027.

What is Known as of October 2023

Publications

  • The proposed policy plans for publications mirror the current NIH Public Access Policy which has been required since 2007, with the removal of the embargo period. School of Medicine researchers have been successfully complying with the NIH Public Access Policy since 2007.
  • As with the current NIH Public Access Policy, there is no fee or article processing charge (APC) required to comply with the new federal policies.
  • Publications will need to be made available upon publication without an embargo period.
  • There is no requirement as to a specific publishing model (i.e., Open Access) or specific license (i.e., Creative Commons).
  • Per FAQ released by the White House on December 21, 2022, “the requirement for sharing scholarly articles can be achieved . . . with the final peer-reviewed manuscript.”
  • NIH is expected to continue to use PubMed Central (PMC) and enhance established workflows.
  • Some publishers have announced their support for the new policies and removed embargo periods for the final peer-reviewed manuscript such as AAAS and JAMA.
  • Per FAQ released by the White House on December 21, 2022, scholarly publications “may include peer-reviewed book chapters, editorials, and peer-reviewed conference proceedings published in other scholarly outlets that result from federally funded research.”

 Scientific Data

  • The proposed policy plans for data mirror the NIH Data Management and Sharing (NIH DMS) policy implemented as of January 25, 2023. If you are already in compliance with this policy, you will have little, if any adjustments to make.
  • NIH will retain the expectations for data sharing and the timing of data availability contained in the NIH DMS policy: 1) shared scientific data is to be made accessible as soon as possible, and no later than the time of an associated peer-reviewed scholarly publication; 2) scientific data that are not associated with peer-reviewed scholarly publications should be made accessible as soon as possible, and no later than the end of the performance period for the research award.
  • The NIH DMS policy strongly encourages the use of established repositories to the extent possible for preserving and sharing scientific data and encourages NIH-supported investigators to select data repositories that exemplify desired characteristics consistent with the National Science and Technology Council’s Desirable Characteristics of Data Repositories for Federally Funded Research.
  • For selecting suitable data repositories or cloud-computing platforms for preserving and sharing scientific data, NIH issued NOT-OD-21-016.
  • Agencies will designate the repository to be used for data.[3]
  • The NIH DMS Policy allows costs associated with data management and data sharing to be included in budget requests for the proposed project. Please see the NIH Notice NOT-OD-21-015 for allowable DMS costs.

Scientific and Research Integrity: Identifiers for Researchers

  • A Digital Persistent Identifier (DPI) will be required of researchers. The ORCID iD is the likely DPI to be recommended by federal agencies. The ORCID iD is currently required for select applicants for NIH awards.
  • Requirements for DPIs may not be available until 2027.

Recommendations for School of Medicine Researchers

  • Retain copies of final, peer-reviewed manuscripts, and tables, figures and supplemental materials associated with the work.
  • Develop Data Management and Sharing Plans (DMSPs) for your research.
  • Confirm that publisher policies allow you to comply with publication and data policies.
  • Communicate with co-authors about publication decisions early.
  • Researchers who receive federal funding (or current applicants) should have an ORCID iD, with current affiliation information and at least one publication noted on their ORCID profile.

Becker Medical Library is here to help you comply with the new policies.

Publications Cathy Sarli or Amy Suiter White House Office of Science and Technology Policy (OSTP) Memo
Data Management and Sharing Plans  Seonyoung Kim Data Management and Sharing
ORCID iD Brittney Sandler ORCID

OSTP 2022 Memo Timeline

OSTP 2022 Memo Timeline

Want to learn more about the OSTP Memo requirements from NIH, NSF and NASA?

Join us for the Open October keynote (virtual) on Thursday October 19th, 3-4 pm, to hear from NIH, NSF, and NASA representatives about the forthcoming public access initiatives to make federally funded publications and research data openly available. The representatives will share an overview of policy guidance and discuss plans for advancing open science, followed by a Q&A session. To learn more and register see: Open October: Expanding public access: Perspectives from NIH, NSF and NASA.

The recording of the Open October keynote can be viewed here. Captions are available.

Readings

Subscribe to the Becker Newsletter for updates related to the new public access policies and other requirements.

[1] An embargo is the delay, specified by the publisher, between when the article is published and when its full version can be made freely available. Modified from: PMC FAQ: https://www.ncbi.nlm.nih.gov/pmc/about/faq/#q19.

[2] Currently, NIH and other funders allow data to not be released until publication of a manuscript. It is not known whether this practice will continue or data will be required to be shared before publication of a manuscript. We encourage you to reach out to your Program Officials if you have concerns about this requirement.

[3] Currently, there are NIH Supported repositories (https://sharing.nih.gov/data-management-and-sharing-policy/sharing-scientific-data/repositories-for-sharing-scientific-data) for some but not all types of data. It currently is not known if all data types will have an NIH supported repository by 2025. As of this blog posting, the NIH recommends an Institutional Repository if no NIH Supported, Domain Specific Repository exists.