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Date/Time: 05/28/2008 at 01:44:27

( * = These fields will be made publicly available )


*  Name:

 Kathleen Case

*  Degree:

 MS

*  Affiliation:

 American Association for Cancer Research

   Email Address:   

 [email protected]

   Mailing Address:   
  Street Address:   615 Chestnut Street, 17th floor
* City: Philadelphia
* State: PA
* Country: USA
  Zip: 19106

*  Role:


Publisher (including Commercial Organizations, Professional Societies and Journal Editors)

*  Question 1:


Q.  Do you have recommendations for alternative implementation approaches to those already reflected in the NIH Public Access Policy?

A.  Many publishers, especially not-for-profit publishers, make ALL of the final content of their journals available free at 12 months. These publishers have offered many times to have PubMed and/or PubMedCentral link to these final articles on the publishers' websites and to implement links from those websites to other NLM databases. Implementing this linking would save thousands of researchers from having to load articles on PubMedCentral because the publishers already load the articles on their websites. These publishers' websites are stable, archived, and are permanently available worldwide. Further, linking would ensure that there was only one version, the final and best version, of an article available to the public. Minimally, the mandatory deposit requirement should be waived for authors who publish in journals that make their articles available free online at 12 months or less. The NIH policy reflects a basic misunderstanding of the Internet--an article that is available online free on a website IS available to everyone. The mandatory deposit on PubMedCentral policy should apply only to articles reporting NIH-funded research that are not made freely availble by publishers. Double deposit of different versions of articles is wasteful, redundant, and potentially dangerous to the public.


*  Question 2:


Q.  In light of the change in law that makes NIH’s public access policy mandatory, do you have recommendations for monitoring and ensuring compliance with the NIH Public Access Policy?

A.  There is no way NIH will be able to monitor effectively the quality of thousands of deposited manuscripts without checking them against a final version on a publisher's website. Such version comparison cannot be automated and would require considerable human resources. There already exist on PubMedCentral papers that should not have been deposited under the previous mandatory policy (too old, wrong versions, not allowed by copyright agreements, etc.). If errors could not be monitored when there were only several thousand papers deposited under the voluntary policy, how could NIH monitor an eventual hundreds of thousands? Compliance would require sanctions to be available, such as lawsuits, fines, withholding grants, or reporting to institutions if a researcher: 1. Fails to load the papers within the timeframe required. 2. Makes mistakes in loading papers (partial text, etc.) or has serious text mistakes in the PMC-loaded papers (later corrected by copy-editing). 3. Publishes in a journal that does not allow deposit in PMC. Is this the role NIH wishes to assume: to punish researchers? If so, how much will NIH spend in becoming a watchdog of author compliance? Will NIH refuse to fund promising research that might lead to cures because the researcher previously failed to load an article on PMC? Consequences for complying with this mandate may cause more harm to the public than noncompliance.


*  Question 3:


Q.  In addition to the information already posted at http://publicaccess.nih.gov/communications.htm, what additional information, training or communications related to the NIH Public Access Policy would be helpful to you?

A.  If the articles on PMC are to be a public service, then there needs to be instruction to the public on how to interpret an animal study, a study with an insufficient number of subjects, a report of an experimental new drug that has not been proven in a trial, a phase 1 study versus a phase 3 study, etc. Also, there needs to be a VERY CLEAR warning that the articles in PMC are not final articles and do not represent all of the literature on a topic. For the public or anyone, a fragment of the literature could be a dangerous thing, and an unedited article could also be dangerous. There are few if any warnings on PMC now.


*  Question 4:


Q.  Do you have other comments related to the NIH Public Access Policy?

A.  The NIH public access mandate was made possible by convincing a few members of Congress that people were suffering and dying because publishers charge fees for subscriptions to journals. Free the literature and all will be possible, went one open access advertisement. Science deals with proof, and where is the proof that free journal articles will do anything? People are suffering and dying because there are no cures for some diseases; because even when preventive measures are possible they aren't applied (eliminating smoking will save lots of lives); because so many have poor or no access to medical care, including the over 47 million people who are uninsured in one of the richest countries in the world. Now that rich country is cutting research funding when other countries are increasing theirs. Surely more people will suffer and die because research funding is being cut than will ever be affected by access to any or all of the journal literature. For the past decade the NIH's National Library of Medicine (NLM), an organization that would simply not exist were there no publishers, has been leading an attack on commercial and not-for-profit publishers while NLM seeks to become one of the largest publishers in the world, first with eBioMed, then with PubMedCentral. The irony of this is apparent. In the latest implementation of its publishing plans--the mandatory deposit policy--NLM mandates that review articles by NIH-funded authors be deposited on PubMedCentral. Review articles are not original research and therefore not funded by research dollars but by publishers who commission them. They were not covered by the previous, voluntary deposit policy and never discussed by Congress. Thus the decision to require the deposit of review articles was made internally at NIH, without public discussion or legislative ruling. The NLM is funded by our tax dollars but there is no publicly available information on how much has been spent for PubMedCentral or how its effect will be evaluated. Taxpayers' assets should be put to better use than for redundancy--duplicating publishing services already provided by private funding. The real problems of health care have nothing to do with journal articles. We need more research, not more redundancy.


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Note: The comments you provide are collected voluntarily.  By providing comments you are consenting to their use and consideration by the NIH.  The following identifying information that you have sent will be made publicly available on the internet along with your comment:  Name (first and last), Degree (if provided), Affiliation, City, State, Country, Role, answers to any of the Questions and any Attachment.  NIH will not post comments that are not related to the Public Access Policy or are otherwise inappropriate or offensive.

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05/28/2008 at 01:44:27 PM