°®¶¹´«Ã½

Lyric Jorgenson, Ph.D. Associate Director for Science Policy The National Institutes of Health 6705 Rockledge Drive, Suite 630 Bethesda, Md. 20892

Re: Request for Information: National Institutes of Health Draft Public Access Policy 

Dear Dr. Jorgenson, 

°®¶¹´«Ã½ (ASM) appreciates the opportunity to respond to the Request for Information on the National Institutes of Health Draft Public Access Policy. As one of the oldest and largest life science societies with more than 32,000 members in the U.S. and around the globe, our mission is to promote and advance the microbial sciences.  

ASM has been an open access (OA) leader and advocate for many years and supports the fundamental principles of open science. ASM has a long-standing commitment to equity in science and recognizes that making research more widely accessible is a step in that direction. The dissemination of research findings without paywalls is essential for advancing scientific knowledge and public health. Open access ensures that researchers, policymakers and the public can freely access and build upon the latest discoveries. This is crucial for addressing urgent health threats and fostering innovation. 

ASM’s 15 peer-reviewed journals are fundamental to ASM’s mission and provide a critical service to our members and the advancement of the microbial sciences globally. In the spirit of open science and open access, ASM has embarked on a journey to transform our publication business model to allow this important transition to happen. In July 2023, ASM announced that it will shift its 6 subscription journal titles to a Subscribe to Open (S2O) publishing model by the 2025 subscription year.  

ASM has reviewed the NIH’s draft public access policy, and we believe that ASM journals will be fully compliant with the policy as written by the proposed Oct.1, 2025, effective date. ASM stands ready to assist NIH-funded authors in complying with the policy. Under our current operating procedures, ASM uploads final, formatted manuscripts to Pub Med Central. Current NIH infrastructure does not allow publishers like ASM to upload accepted manuscripts to Pub Med Central. ASM urges NIH to develop a mechanism for publishers to do this, bringing authors into compliance with the public access policy and saving authors time and effort. 

ASM encourages NIH to consider requiring broadly adopted persistent identifiers (PID), such as Open Researcher and Contributor IDs (ORCiD), and engage in stakeholder efforts around PID strategies, including the National Information Standards Organization and the Open Research Funders Group. Using PIDs will enhance the discoverability of research and allow the agency to more easily connect grants and research outputs. 

ASM continues to be concerned about the unintended consequences of enacting federal policies that might shift costs to researchers, or otherwise result in significant additional costs related to publication, repositories, data management and staffing. There remains a cost to publishing good science. Peer reviewers are not paid, and maintaining the peer review system, which is integral to upholding scientific integrity and rigor, demands human time and adoption of innovative technologies. These standards and the integrity and rigor they uphold in science should not be compromised in the pursuit of public access. 

As the costs of publishing increase, the costs are increasingly falling on individual researchers and institutions. We believe that if researchers are forced to make up for lost subscription revenue, a new kind of inequity will result. For example, author processing charges (APCs), which have evolved as an open access alternative revenue model to page charges and library subscriptions, have become increasingly expensive and create financial barriers for researchers from underserved populations, including early career researchers, those from historically excluded backgrounds, those at less research-intensive institutions and with limited resources and those living in the global south. We know that the scientific community does not want to disadvantage our colleagues in these institutions and countries by this approach. 

It is critical that NIH policies support alternative means for funding public access. ASM encourages NIH to prioritize funding for open access publication avenues for publicly funded research and to work with Congress and the research community to identify appropriate financial support to address these unequal additional burdens in future spending bills and through other strategies. ASM appreciates that the draft public access policy allows researchers to use federal funds to cover reasonable publication costs and encourages NIH to allocate funds specifically for covering reasonable publication fees in open-access journals and by encouraging grantees to publish in open-access venues. Explicit support for open access aligns with the broader goals of transparency, equity and the democratization of scientific knowledge. 

ASM and its members look forward to continuing to work with you through the implementation process. For more information, please contact Nicole Zimmerman, Senior Specialist, Federal Affairs, at nzimmerman@asmusa.org. 

Thank you,



Amalia Corby 
Director of Federal Affairs 
American Society for °®¶¹´«Ã½