On April 19, 2023, the Agency for Healthcare Research and Quality (AHRQ), US National Institutes of Health (NIH), released a request for comments on an AHRQ Plan for Updating the Policy for Public Access to Scientific Publications and Scientific Data Resulting from AHRQ Funding. The Association of Research Libraries (ARL) is pleased to offer the following response to this request.
ARL Comments on AHRQ Plan for Updating the Policy for Public Access to Scientific Publications and Scientific Data Resulting from AHRQ Funding
May 31, 2023
Agency for Healthcare Research and Quality
5600 Fishers Lane
Rockville, MD 20857
Re: Request for Information on AHRQ Plan for Updating the Policy for Public Access to Scientific Publications and Scientific Data Resulting from AHRQ Funding
On behalf of the members of the Association of Research Libraries (ARL), thank you for the opportunity to provide comments on “Request for Information on AHRQ Plan for Updating the Policy for Public Access to Scientific Publications and Scientific Data Resulting from AHRQ Funding” ARL and its members are committed to the advancement of open scholarship and open access to accelerate scientific advances and to expand diverse, public participation in federally funded research. We appreciate AHRQ’s commitment to making the results of federally funded research widely available without embargo, leveraging persistent identifiers to support scientific integrity, and ensuring equitable access.
We submit the following comments on the AHRQ request for information (RFI) “Plan for Updating the Policy for Public Access to Scientific Publications and Scientific Data Resulting from AHRQ Funding”
In addition to the specific actions below, overall, we recommend that AHRQ:
- Minimize administrative and financial burden on researchers and institutions for compliance by working with campus-based service providers to educate and support the preparation of materials for sharing for public access
- Monitor costs and expenses for public-access policies by tracking not just expenses included in the grant, but across the institution (from campus IT, research library, and research office) through a grant close-out report or commissioned study
- Collaborate with scholarly societies, researchers, and libraries to define a public-access deposit package that is inclusive of policy requirements (such as manuscript, protocols, reports, data, metadata and documentation, etc.)
Publications
With regard to AHRQ’s commitment to public access to scientific research results, and it support for authors in their responsibility to work with publishers before publication rights are transferred, ARL recommends that the agency policy:
- Provide rights-retention language (for investigators to use upon submission of manuscripts to journals) that encourages authors to retain their copyrights and assign a Creative Commons Attribution (CC BY) or similar license to their work in order to enable full reuse rights. Open licenses are easy to understand for both researchers and users, so more users can access and reuse content, and more researchers can provide access to and reuse of their work.
- Consider using the following language, modeled after the Wellcome Trust language:
This research was funded in whole or in part by the Agency for Healthcare Research and Quality [grant number]. For the purpose of public access, the author has applied a CC BY public copyright license to any author-accepted manuscript version arising from this submission.
According to cOAlition S funders, “In the two years or so since this [rights retention] approach was introduced by many cOAlition S funders, [the funders] are only aware of one example where a publisher rejected a manuscript due to the existence of a prior licence.”[1]
Accessibility and Section 508 Compliance
Ensuring final publisher PDF versions are accessible is critical to enable equitable delivery of federally-funded research results. While publishers of scholarly works are able to add accessible features most effectively and efficiently, PDFs provided by publishers are not always 508 compliant. We recommend that AHRQ include a plan to remediate non-compliant works in accordance with U.S. copyright law, which explicitly grants a broad exception for remediation and distribution of accessible works to people with print disabilities. This exception is bolstered by the Marrakesh Treaty. Copying and distributing works in accessible formats is not constrained by copyright law, and we recommend the agency remove “due to copyright constraints” from this sentence in the plan: “AHRQ will provide an accommodation for final publisher PDF versions that are not 508 compliant but cannot be remediated due to copyright constraints.”
Scientific Data and Data Management Plans
ARL recommends that AHRQ staff work with researchers and institutional experts, including librarians, to select non-profit community governed data repositories, including disciplinary and institutional data repositories that share “Desirable Characteristics of Data Repositories for Federally Funded Research” to deposit their data upon publication.
ARL commends AHRQ for its recognition that “in some cases, software and other tools such as interview protocols, measures, coding guides, or manuals may be necessary to interpret data. In such cases, the data management plan will be expected to include a description of these tools.”
Persistent Identifiers
The Association of Research Libraries recommends that AHRQ:
- Adopt the Implementing Effective Data Practices report recommendations from higher education associations[2], including the adoption of the following persistent identifiers (PIDs) at a minimum:
- Digital object identifiers (DOIs) for each publication and research output (data, code, software, etc.)
- Open researcher and contributor identifiers (ORCID IDs) to uniquely identify authors
- Research Organization Registry (ROR) IDs to link authors with known organizations
- Crossref Funder Registry IDs to associate a research output with a granting agency
- Crossref Grant IDs to uniquely identify a research award with an author, an organization, and a funding agency
Managing and Tracking Cost
ARL recommends:
- Surveying researchers and/or institutions at closeout for additional information on publication costs, or commissioning a study that would incorporate both researcher costs and additional data from global registries of article-processing charges (APCs) and other publication fees
- Monitoring publication trends across publication formats, including journal articles, book chapters, and other peer-reviewed publications
- Reviewing the publication costs of journal titles that AHRQ-supported researchers most commonly publish in
We look forward to continued engagement with AHRQ during the development of the agency’s public access plan. We are happy to work with AHRQ to identify ARL member institutions to participate in conversations regarding any of these specific topics. Please feel free to contact me or my colleague Cynthia Hudson Vitale, director of Science Policy and Scholarship, cvitale@arl.org, with any questions about these comments.
Sincerely,
Mary Lee Kennedy
Executive Director
Association of Research Libraries
Endnotes
[1] “Making Full and Immediate Open Access a Reality,” cOAlition S, April 11, 2023, https://www.coalition-s.org/wp-content/uploads/2023/04/cOAlitionSresponseForNIH.pdf.
[2] Chodacki, John, Cynthia Hudson-Vitale, Natalie Meyers, Jennifer Muilenburg, Maria Praetzellis, Kacy Redd, Judy Ruttenberg, Katie Steen, Joel Cutcher-Gershenfeld, and Maria Gould. Implementing Effective Data Practices: Stakeholder Recommendations for Collaborative Research Support. Washington, DC: Association of Research Libraries, September 2020. https://doi.org/10.29242/report.effectivedatapractices2020.
