AAU, COGR, and APLU recommend that OMB require all Federal agencies subject to OSTP’s 2013 policy memorandum, “Increasing Access to the Results of Federally Funded Scientific Research,” to harmonize the procedures by which extramural grantees submit final peer-reviewed manuscripts or final published documents and data to the agencies’ public access repositories. We believe that this harmonization process may most effectively be accomplished under the auspices of the National Science and Technology Council (NSTC).
A multiplicity of divergent public access policies will substantially increase the administrative burden on grantees as they will be required to comply with an array of different terms and conditions across multiple funding agencies. Accordingly, we urge the creation of a single governmental portal through which federal grantees can submit their final peer-reviewed manuscripts or final published documents and data via a uniform compliance procedure to all funding agencies. Alternatively, but less optimally, we would propose that all funding agencies be required to seamlessly and non-redundantly integrate their public access submission requirements into their existing progress reporting procedures.
We also suggest that every federal funding agency include in its public access policy an “opportunity to cure” provision that would afford grantees with proven compliance track records a reasonable grace period within which to correct any errors or omissions relating to their public access submissions before any funding under the applicable grant is suspended or terminated or any other punitive measures are applied. If a given agency conditions the continuation of funding on prompt public access compliance, this grace period should also permit funding to continue where the grantees’ timely compliance is hindered by technical difficulties at the agency level.
We have already heard from grantee universities that have incurred costly delays in NIH funding due to minor and/or inadvertent errors in their submissions to NIH’s PubMed Central or due to technical challenges uploading materials to PubMed Central that are beyond the control of the universities or investigators involved. These costs are not only financial; they also impede the forward momentum of the research and science being pursued under the grants. Thus we believe there must be mechanisms in public access policies to ensure that funding streams are not interrupted – to the detriment of both grantees and funding agencies – by readily remediable submission mistakes or technical obstacles at the agency level.