ACP: Governmental Affairs and Public Policy - ACP Comments on Proposed NIH Public Access Policy

Advocacy

ACP Comments on Proposed NIH Public Access Policy

November 16, 2004

Elias A. Zerhouni, MD
Director
National Institutes of Health
Public Access Comments
Office of Extramural Research
6705 Rockledge Drive Room 350
Bethesda, MD 20892-7963

Dear Dr. Zerhouni;

The American College of Physicians (ACP), representing more than 116,000 internal medicine physicians and medical students, is pleased to offer comments on the National Institutes of Health (NIH) proposal for "Enhanced Public Access to National Institutes of Health (NIH) Research Information" as described in the Federal Register on September 17, 2004 (Volume 69, Number 180, Page 56074).

As the nation's largest medical specialty society, our mission is to enhance the quality and effectiveness of health care by fostering excellence and professionalism in the practice of medicine. ACP has an official scientific journal, Annals of Internal Medicine, the most widely cited medical specialty journal in the world. ACP's other journal, ACP Journal Club, is the premier synoptic journal for internal medicine.

While ACP supports the intent of free access to the results of taxpayer-funded health related research, we disagree with the concept of accessing the manuscripts through a central repository. We are concerned that having access to a centrally deposited manuscript will create problems with version control. Often, authors and readers notify the journal of errors in articles in the published version of a manuscript, which are then published as Errata in both the print and electronic versions. Readers who access the version published on the date of print publication could miss important changes that would only be present in the publisher' corrected version or master copy. Using any version other than the master copy could cause confusion, at a minimum, and could significantly compromise the integrity of the scientific record. It should be noted that journals spend a great deal of time and money on editing and peer review in order to assure the public about the quality of the research and the reliability of the results being published.

In addition, ACP believes that the concept of access to a manuscript though a central repository could lead to missed opportunities in providing readers with access to related materials in the same issue or other issues of the journal, including editorials and related articles which may not necessarily be NIH-sponsored research. These items can often be found in the internet-based versions of journals and provide the reader with greater context. We believe that this issue, and the version control problem, could easily be resolved by providing linkage to the master copy on the publisher's website, rather than providing just the journal's published version of the manuscript on PubMed. In return for the NIH linking to the original publisher's website instead of maintaining its own copies of the manuscripts, it would be incumbent upon the journal publishers to make sure that any links from the NIH site remain functional.

Finally, ACP is concerned that the cost for developing and maintaining the online repository that NIH describes will be significant. This cost, plus increased publication costs to authors, could reduce funding available for research. We believe that further explanation of the cost to the NIH budget and the related impact on grant funding should be provided before this policy is implemented.

ACP appreciates the opportunity to comment on the NIH's proposal to "Enhanced Public Access to National Institutes of Health (NIH) Research Information." While we support the concept of open access to NIH-funded research, we oppose immediate implementation of the proposed NIH plan until the concerns in areas as described above are addressed. If you have any questions regarding our comments, please do not hesitate to contact Renee Zerehi, Associate, Health Policy and Council Activities at 202-261-4555.

Sincerely,

John Tooker, MD, MBA, FACP
Executive Vice President & CEO