COAPI response to 2020 RFI – Public Access to Scholarly Information

Text below sent as email attachment to [email protected] on
April 22, 2020

We, the Coalition of Open Access Policy Institutions (COAPI) Steering Committee, thank the Office of Science & Technology Policy for requesting stakeholder information on this extremely important and timely topic. Our membership consists of librarians at over 110 colleges and universities that have implemented or are actively pursuing open access policies, requiring faculty to make a version of each of their peer-reviewed articles openly available for all to read. As active participants in the movement to make products of research more available and reusable, we submit our responses to your questions.

What current limitations exist to the effective communication of research outputs (publications, data and code) and how might communications evolve to accelerate public access while advancing the quality of scientific research? What are the barriers to and opportunities for change?

Federal agencies have the power to set new best practices, standards, and/or behavioral norms for researchers that will allow for more open and transparent sharing of research outputs. As representatives from colleges and universities whose faculty have decided to adopt open access policies, we can attest to the fact that barriers to research outputs and publications are a constant frustration for these faculty members. When researchers cannot easily and affordably exchange knowledge about new developments in their fields, the quality and efficiency of the research enterprise suffers. These barriers to publicly funded research are especially frustrating for our authors who have chosen careers in higher education–careers that are largely motivated by an interest in sharing scholarly knowledge. At the same time, faculty working at our institutions are keenly aware of an uneven playing field for researchers. Those working at large, well-funded universities are more likely to have access to subscription resources; while researchers in largely rural states, hospital systems, and many state-funded colleges and universities are less likely to have ready access to important research findings and resources. Even among some of our larger and better funded members, our faculty are aware of financial burdens carried by their libraries. As the cost of subscribing to resources continues to outpace library budgets, scholars know that they are likely to lose access to an increasing number of journals and other resources in the future.

It is for these reasons that the faculty at our member institutions have decided to adopt open access policies. These policies enable authors to make their accepted, peer-reviewed articles freely available in open access repositories. Some of our members have successfully implemented their policies for over a decade; the benefits to their faculty (increased readership, exposure to potential collaborators, and satisfaction in fulfilling a mission to share the fruits of scholarship) have compounded, as has their faculty’s support for the immediate open access to research. Our member institutions have demonstrated that authors can flourish when their research data and works are made freely available for others.

What can Federal agencies do to make taxpayer funded research results, freely and publicly accessible?

The COAPI Steering Committee encourages the Federal Government to implement a strong national policy that provides immediate, barrier-free access to the full results of taxpayer-funded research. Such a policy would align with efforts at our member institutions. We would welcome Federal policy that has the following characteristics:

  1. Immediate access to published articles without embargoes
  2. Articles should be openly licensed and made available in open and machine-readable formats that fully enable productive reuse including text/data mining and computational analysis
  3. Data (and code, software, etc.) needed to validate/replicate the conclusions of articles should be made immediately available
  4. Other appropriate data should be FAIR (Findable, Accessible, Interoperable, Reusable)
  5. Free public access to and long-term preservation of these research outputs should be provided via either a digital repository maintained by the funding agency or in an appropriate institutional or disciplinary repository.

A clear statement from Federal funding agencies requiring immediate public access to research outputs would strengthen existing institutional policies by eliminating embargo periods and developing a national standard for managing and sharing data. Our member institutions already have workflows that streamline the process of complying with existing policies, and are poised to implement a new Federal policy. Using existing repository infrastructure provided by universities, funders, and scholarly societies would be a cost-effective method to immediately provide access and preservation to these research outputs, with no additional cost to authors or funders.

How would American science leadership and American competitiveness benefit from immediate access to these resources?

Open access to outputs of publicly funded research is a widely accepted international policy strategy to increase the government’s return on investment in research. The U.S. is being left behind; other countries including China, Canada, EU members, India, and Brazil are adopting open access policies to accelerate their scientific research, boost innovation and increase competitiveness. Furthermore, private funders such as the Gates Foundation and the Wellcome Trust also have policies mandating open access of their funded research

Open access to research boosts innovation, increases national competitiveness and provides a better return on taxpayer investments in research. America cannot play a leadership role in science if our scholars routinely cannot access critical research articles and data.

A government-wide open access policy will support informed, transparent, federal budget and policy decision-making. It will increase Federal agency accountability and provide agencies with an improved accounting on the outcomes of their research. It will help appropriators, and authorizers more accurately assess the value of existing expenditures, and to target funding on the most promising research areas. An open access policy will improve the rigor and reliability of taxpayer-funded research by providing more transparency and the ability for easier verification of results. This will in turn improve the public trust in science and in research funded by the Federal Government in particular. Now, as the country works to address the COVID-19 pandemic, the transparency, rigor, and speed that open access policies facilitate are vitally important. Open research practices have benefited the responses to Ebola, H1N1, Zika, and other public health crises. A Federal policy with the characteristics supported in this response would position our country to best address similar challenges in the future.

Thank you for your time, consideration, and attention on this important topic. The COAPI Steering Committee is ready to address any questions you might have about our support for an expanded public access policy.

Respectfully,

Anali Maughan Perry, COAPI Steering Committee Chair,
on behalf of the Coalition of Open Access Policy Institutions

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