[SPARC comments on NIH Public Access Policy]

"We applaud NIH for removing the previously allowed 12-month embargo on publications resulting from federally funded research....

We also offer our strong support for the proposed language in the draft policy that clearly states that submission of manuscripts to PubMed Central (PMC) remains free for authors and that any fee requested during the publication process for submission to PMC (e.g., “article development charges” or similar) is not an allowable cost....

To further strengthen this aspect of NIH’s draft policy, we encourage the agency to clearly communicate to grantees that there is a no-cost compliance option available to all researchers and institutions. We consistently hear from our member institutions that many on their campuses mistakenly assume that compliance with the new policy requires the payment of a publishing fee to a journal. It is incumbent upon the agency, with support from the research community, to educate grantees about the free option available to authors so that they do not end up paying unnecessary publication fees.... 

The Memorandum also asks agencies to clarify what use and reuse rights accompany these articles, and we recommend that NIH make adjustments to its draft policy to explicitly authorize the public to fully reuse publications resulting from its research....

We recommend that NIH’s draft policy include language that would allow for the deposit of the author’s manuscript into local, institutional repositories—not just PMC. We recognize that technical developments to fully support this option are ongoing, and also suggest that NIH engage with the USRN to develop a pathway for identifying additional repositories for authors to deposit their manuscripts into...."