On May 13, 2024, the Social Security Administration (SSA) released a request for information for the “Plan for Increasing Public Access to the Results of Federally Funded Scientific Research (SSA-2023-0039).” The Association of Research Libraries (ARL) is pleased to offer the following comments in response to this request.
ARL Comments on the Request for Information for the Social Security Administration’s Plan for Increasing Public Access to the Results of Federally Funded Scientific Research
June 12, 2024
US Social Security Administration
1200 New Jersey Avenue SE
West Building
Washington, DC 20590-0001
Request for Information: Social Security Administration’s Plan for Increasing Public Access to the Results of Federally Funded Scientific Research (SSA-2023-0039)
On behalf of the members of the Association of Research Libraries (ARL), thank you for the opportunity to provide comments on the Social Security Administration’s “Plan for Increasing Public Access to the Results of Federally Funded Scientific Research.” ARL and its member libraries 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 SSA’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. ARL acknowledges that SSA conducts and funds critical research on disability policy, a key area of interest to the Association’s policy portfolio.
We submit the following comments on the SSA “Request for Information: Increasing Public Access to the Results of Federally Funded Scientific Research.”
- Scope and Applicability—Our public access plan defines the scope of what research will be publicly accessible, including limitations to protect privacy of personally identifiable information. As we implement our public access plan, is there additional public access we should consider?
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- Accessibility—Ensuring that final published PDF versions are accessible is essential for equitable delivery of federally-funded research results. While publishers of scholarly works are best positioned to incorporate accessible features efficiently, PDFs provided by publishers are not always Section 508 compliant. We recommend that public access plans include a strategy for remediating non-compliant works in accordance with US copyright law. This law explicitly provides a broad exception for the remediation and distribution of accessible works to individuals with print disabilities, an exception further supported by the Marrakesh Treaty.
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- Rights and Reuse—The SSA plan states that, “Researchers must ensure that the final publication is permitted to be available in an SSA-designated repository.” We recommend final publications, research data, and other published outputs carry full reuse rights, such as those provided by a CC BY 4.0 International License or its functional equivalent, not just the right for the publication, data, or other output to be made available in the repository. Full public reuse enables broad secondary analysis, allowing others to build on the original work, extend research findings, and apply innovative methodologies, including text and data mining, AI deployment, and other computational technologies.
To grant the public full reuse rights, the SSA could explicitly state that it relies on its existing Federal purpose license under 2 C.F.R. § 200.315(b). Through the Federal purpose license, the agency already receives a license to any copyrighted work which authorizes it to make broad use of the work for federal purposes and to authorize others to do so.
- Digital Repositories—We will require that federally funded scientific research results are publicly accessible for free, including final scientific research reports, peer-reviewed scholarly publications, and the underlying scientific research data used to produce reports and publications, to the extent permitted by applicable law. We will require that final research publications are permitted to be available in an SSA-designated repository that we will select in 2024. Underlying scientific research data must be deposited in a repository and in a form that meets SSA’s requirements. What types of digital repositories do researchers prefer for providing public access to research data? What should SSA consider as we develop requirements for which data repositories researchers may use?
ARL’s member research libraries, which include public, academic, and government libraries, support researchers across disciplines to store, preserve, and make their publications and research data publicly accessible. Many provide infrastructure, typically through institutional repositories or institutional data repositories, also known as generalist repositories. Beyond meeting technical requirements, libraries provide the invaluable assistance of local librarians or other professional staff to guide researchers on compliance with public access policies and gold-standard FAIR data sharing. Researchers value this local support of institutional repositories that offer robust infrastructure, comprehensive metadata standards, and strong data preservation and accessibility features. Many institutional repositories and institutional data repositories meet these criteria and align well with the criteria outlined in the Desirable Characteristics of Data Repositories for Federally Funded Research report.[1]
As the SSA develops requirements for data repositories, it is crucial to clearly identify the characteristics and features that repositories must have beyond those mentioned in the Desirable Characteristics of Data Repositories for Federally Funded Research report. This includes establishing clear, objective guidelines for what would not constitute an SSA-designated repository. Consideration should be given to institutional repositories, as they often meet the necessary requirements and can provide reliable, secure, and long-term access to research data. The SSA may also want to determine if certification from a third party, such as CoreTrustSeal which certifies repository trustworthiness, could be a mechanism to determine suitability for SSA repository designation.
Ensuring these repositories offer features such as user-friendly interfaces, compliance with FAIR and CARE principles, and robust security measures will be essential. Additionally, repositories should have a proven track record of maintaining data integrity and providing support for data curation and management. By setting these standards, the SSA can ensure that researchers have access to high-quality repositories that facilitate the broad dissemination and reuse of research data.
- Costs—For the expenses that researchers incur for providing public access, we may allow reasonable costs as part of a contract, grant, cooperative agreement, or other research award. What information is available to help us estimate the costs associated with providing public access to scientific research publications and data? How can we minimize those costs to maximize the funds available for research awards?
Researchers typically incur direct costs related to data management and sharing activities throughout the life cycle of their projects. Recent ARL research[2] has found that the average expenditure for research data management and sharing activities is, on average, $29,800 per award throughout the life cycle of their award (from pre-award to closeout) projects (Figure 1).
Figure 1: Breakdown of average annual cost for DMS services by staffing and infrastructure for institutional service areas.
This research has also found that the average yearly institutional expense (researcher expense plus institution-based service provider expenses) for data management and sharing is $2,500,000 with a range from approximately $800,000 to over $6,000,000.[3] While researcher direct costs may be included in grant budgets, overall institutional expenses are not yet well accounted for through institutional direct or indirect cost reimbursement.[4]
Notably, as seen in Figure 2, when leveraging institutional services, such as institutional repositories for data sharing, researcher expenses for data management and sharing have a lower average expense when compared to the average expense when using a different data-sharing location.
Figure 2: Average DMS costs per funded research project by how research data were shared.
Based upon the information above and to ensure researchers have support to meet requirements, ARL recommends that the SSA:
- Minimize the administrative and financial burden on researchers and institutions for compliance by working with institution-based service providers to educate and support the preparation of materials for sharing for public access.
- Specify allowable (and unallowable) costs for data management and sharing activities. This includes explicitly stating if data storage and repository expenses post-award are allowed.
- Develop a mechanism to ensure that funds are available post-closeout for publication and research data storage and/or sharing expenses. Post-award funding is particularly important for early-career, postdoctoral, and graduate student researchers whose publication and data-sharing costs may not have been factored into the original grant budget.
- SSA Research Information and Training—Our public access plan provides information about our existing website where we describe our research programs. We will consider providing a new web page as a single point of access for information about our research programs, including how to find publicly accessible research publications and data. What information, guidance, or training about public access could we provide to help researchers and their institutions, beginning with applying for a research opportunity through the time of final publication?
To support researchers and their institutions in navigating public access requirements, ARL recommends the SSA consider clearly identifying the preferred persistent identifiers (PIDs) that researchers should be using. Providing specific guidance on PIDs offers clear direction for researchers and helps build a cross-discipline research infrastructure. The report, Implementing Effective Data Practices, includes recommendations from higher education associations[5] and recommends the following PIDs:
- 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, including Funder IDs
ARL also recommends working more closely with research librarians to educate and inform researchers at their institutions and organizations about the public-access policy and compliance workflow.
- Equitable Research—How can we ensure equity in research opportunities and access as we implement public access requirements, and what challenges might certain institutions face with public access, including costs and publishing opportunities?
ARL recommends that SSA allow the use of preprint services under the scope of “Peer-Reviewed Scholarly Publications.” Utilizing preprints can accelerate the sharing of research findings. SSA should consider recognizing peer-reviewed preprints that are substantially similar to author-accepted manuscripts for policy compliance. This approach provides an immediate avenue for researchers to disseminate their work widely. Preprints can increase equitable access to the broad public, as preprints repositories do not charge a fee for access. Preprint deposit benefits researchers, as their scholarly articles will be made more broadly available, increasing the likelihood of use and citation. ARL encourages SSA to work with research institutions and their libraries to coordinate educational publishing efforts for investigators. These efforts could focus on informing researchers of their options for no-fee manuscript deposit, helping to alleviate financial barriers to publication.
We look forward to continued engagement with SSA during the development of the agency’s public access plan. We are happy to work with SSA to identify ARL member institutions to participate in conversations regarding any of these specific topics. Please feel free to contact me (andrew@arl.org) or my colleague Judy Ruttenberg, senior director of Scholarship and Policy (judy@arl.org), with any questions about these comments.
Sincerely,
Andrew K. Pace
Executive Director
[1] For instance, see the September 6, 2022, Data Curation Network blog post, “DCN is Ready to Support Policies Resulting from OSTP Public Access Memo.” https://datacurationnetwork.org/2022/09/06/dcn-is-ready-to-support-policies-resulting-from-ostp-public-access-memo/.
[2] Hofelich Mohr, Alicia, Jake Carlson, Lizhao Ge, Joel Herndon, Wendy Kozlowski, Jennifer Moore, Jonathan Petters, Shawna Taylor, and Cynthia Hudson Vitale. Making Research Data Publicly Accessible: Estimates of Institutional & Researcher Expenses. Washington, DC: Association of Research Libraries, February 2024. https://doi.org/10.29242/report.radsexpense2024.
[3] Hofelich Mohr et al., Making Research Data Publicly Accessible: Estimates, 19.
[4] Steinhart, Gail, and Katherine Skinner. “The Cost and Price of Public Access to Research Data: A Synthesis.” Invest in Infrastructure (IOI), February 29, 2024. https://doi.org/10.5281/zenodo.10729575.
[5] 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.
