Joint Response to RFI on the NIH Plan to Enhance Public Access to the Results of NIH-Supported Research

April 28, 2023



Shelley O’Brien

Joint Response to RFI on the NIH Plan to Enhance Public Access to the Results of NIH-Supported Research

As representatives of the American scientific community, the undersigned scientific societies and associations welcome the NIH’s efforts to enhance public access, in line with the recent OSTP guidance aimed at making federally funded research publications and supporting data publicly available. We further applaud the NIH for emphasizing equity in its approach to public access policy development.

As a critical component of its public access plan, we urge the NIH to focus on creating an environment that balances reader access to published work with researchers’ ability to publish. This will require transparency and recognition of the costs borne by researchers and research funders. We must strive to create a system wherein scientists are not required to pay additional fees to publish and where grants are not required to bear the brunt of publishing costs. Otherwise, we risk creating heavy cost burdens not only for researchers and their institutions, but also for funders of research, including taxpayers. Our organizations and others are experimenting with various sustainability models for public access, including diamond, green, and Subscribe to Open. These represent potential pathways towards the goal of optimizing equity for researchers and readers. We are open to other models that achieve NIH’s equity goals.

Scientists’ ability to communicate their scientific results through publication is critical to the incorporation of their expertise into the scientific enterprise and the progression of their careers. Monitoring implementation of changes to the public access policy, and how researchers and institutions pay publishing costs, will be critical to ensuring that public access plans do not create new systemic inequities or reinforce existing ones. Careful and continued study will be essential for understanding the near- and long-term effects of related changes. A study of cost effects at the researcher, institution, and enterprise levels is needed. It may also be valuable for NIH to survey researchers and institutions about publishing costs and about tradeoffs made to pay such costs.

Adaptation of federal grant agreements to require reporting on the payment of publication fees and reliance on transformative agreements (in instances where authors avoid payment of a fee because their institution has a transformative agreement with their journal of choice) represents one logical approach to monitoring fees. All analyses of and reporting on costs paid by institutions or researchers for publication should examine potential variability in costs across disciplines, career stages, and institution types, as well as variability based on researcher backgrounds.

As representatives of the scientific community, we believe we are at a crucial moment in the timeline of public access policy development, and we continue to share our view that public access should optimize equity for researchers and readers. We appreciate your consideration of these comments, and are committed to collaborating with NIH, other federal research agencies, and OSTP to develop public access policies that balance access to published work with the ability to publish.


American Anthropological Association

American Association for the Advancement of Science

American Association for Anatomy

American Association for Dental, Oral, and Craniofacial Research

American Institute of Biological Sciences

American Society of Tropical Medicine and Hygiene

Association for Women in Science

Association of Independent Research Institutes Biophysical Society

Federation of Associations in Behavioral and Brain Sciences

Human Factors and Ergonomics Society


Sigma Xi, The Scientific Research Honor

Society Society for Research in Child Development

The American Society for Biochemistry and Molecular Biology

The American Society for Cell Biology

The Gerontological Society of America


About AWIS: Founded in 1971, AWIS has been the leading advocate for women in science, technology, engineering, and mathematics (STEM) to achieve business growth, social change, and innovation. We are dedicated to driving excellence in STEM by achieving equity and full participation of women in all disciplines and across all employment sectors. In addition to scholarships, AWIS provides career resources, professional development, as well as networking, mentoring, and volunteer opportunities to build leadership skills. To learn more, visit and @AWISNational.