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Since the OSTP RFI on public access to the results of federally funded research has been extended until January 12, I decided to add to my first Kitchen article presenting my case for using research reports instead of journal articles to meet the mandate. I have even done some research in the interim. Plus, there has been a spirited discussion here in the Kitchen, in the comment threads of several different posts.

My basic argument is that the goal of public access to federally funded research results is best served via contract research reports, not journal articles. I first need to make clear that providing public access to research reports is not new. In fact, several science agencies have done it for a long time. DOE, DOD, EPA, NASA, and NSF all have extensive Web portals that provide searchable access to their unclassified reports.

DOE’s “Information Bridge” portal is a good example (plus, I have worked on it). It has lots of fancy features and contains about 300,000 reports. Last year, over 30 million (that’s million) were downloaded from Information Bridge alone. Thirty million downloads is a lot of public access indeed. So all I am proposing is that all the agencies do what some do already; this is not a radical change in federal practice.

Now let me make the case that the goal of public access to federally funded research results is best served via research reports, not journal articles:

  • Meeting the goal of public access to federally funded research results does not require public access to journal articles. There is growing interest in providing public access to the results of federally funded research. In particular, SEC. 103 (a) of the America COMPETES Reauthorization Act of 2010 specifies that the federal government

. . . shall establish a working group under the National Science and Technology Council with the responsibility to coordinate Federal science agency research and policies related to the dissemination and long-term stewardship of the results of unclassified research, including digital data and peer-reviewed scholarly publications, supported wholly, or in part, by funding from the Federal science agencies. [emphasis added]

A great deal of attention has been focused on the referenced “peer-reviewed scholarly publications,” or journal articles, but in the legal language they are just an example of the results of federally funded research. The term “including” signals an example. This is a common mistake, whereby an example given in a law is taken to be the general case itself. But the COMPETES Reauthorization Act clearly refers to “the results of unclassified research” not merely to peer-reviewed scholarly publications, such as journal articles. In fact, the original COMPETES Act of 2007 contains a mandate for public access to research reports, in this case reports from the National Science Foundation. Section 7010 says the following:

The Director shall ensure that all final project reports . . . are made available to the public in a timely manner and in electronic form through the Foundation’s Web site.

  • Federally funded research always produces one or more research report. These reports are central to the federal research process. These research reports are required by the Federal Acquisition Regulations, which apply to both grants and contracts. There is always a final report for every project and in many cases there are also annual interim reports. The reports summarize the research results, and they can be quite lengthy. For example, the Department of Energy estimates that its average report is around 60 pages long, far longer than the typical journal article. It is not that research reports are superior to journal articles, nor are they inferior. The two serve different purposes.
  • These research reports are the natural vehicle for providing public access to federally funded research results. The reports are produced as part of each federally funded project, and they are delivered to the government as a contract deliverable. Thus, there is a report for virtually every project. The research results being reported on are solely that which the government funded. Thus if the policy is to provide public access to federally funded research results, then these reports are the natural vehicle for doing so. The government already has them, so all it has to do is make them publicly available. No new system is required.
  • Presently some agencies provide public access to their research reports while others do not. There is presently no government-wide policy regarding public access to research reports. Some science agencies provide public access to all of their unclassified research reports; some provide access to a fraction of their reports; others do very little. Those agencies that provide comprehensive access include the following:
    • Department of Defense
    • Department of Energy
    • Environmental Protection Agency
    • National Aeronautics and Space Administration
    • National Science Foundation

In addition, various science units within the other science agencies make their research reports publicly available. Examples include the U.S. Forest Service in the Department of Agriculture and the Institute of Education Sciences in the Department of Education. The point is that providing public access to agency research reports is neither new nor unusual.

  • Journal articles, in contrast, are not part of the federal research process. To consider journal articles as the result of federally funded research is a misleading oversimplification. To begin with, these articles are often written long after the project has ended, so they are not federally funded. Unlike research reports, the government does not own these articles.

Then too, these articles have undergone extensive pre-publication filtering and editing, including journal peer review, which is also not part of the federal process. In many cases they include additional, unfunded research, in response to peer review comments. So while these articles may be derived in part from federally funded research, they are not in fact the simple result of such funding, not as the research reports are. Journal articles are not really part of the federal research process, while research reports are.

  • Moreover, applied research often does not lead to journal articles, yet it is a major component of federally funded research. A great deal of federally funded research is of an applied nature, as opposed to being basic research. For example, in the Department of Energy, applied programs account for a large fraction of the research budget. In many cases applied research results are not published as journal articles, just as project research reports. Yet this applied research is often the most suitable for technology transfer into the private sector, which is one of the major goals of public access policy. Thus a focus on journal articles misses much of the research.
  • Unavailable research reports are a wasted resource. Where are the federally funded project research reports now, the ones that are not presently publicly available? Presumably they are in the files of the contract and program offices. As it is these unavailable reports are largely wasted resources. There are probably millions of pages of such reports, representing hundreds of billions of dollars in research.
  • Providing public access to all unclassified federally funded research results via contract research reports should be simple to implement. As explained above, the government already receives detailed research reports for all federally funded research. A number of science agencies already make all of their reports publicly available, via Web portals. Moreover, there are already two portals available for government wide dissemination of research reports. These are the National Technical Information System and It should therefore be a relatively easy matter for all the science agencies to make all of their research reports publicly available. They have the reports, and they have the technology.
  • Conversely, providing government implemented public access to journal articles is complex, costly, and burdensome on the research community. The US federal government is not part of the international journal publishing system so tying the two together cannot be simple. At present NIH is the only federal agency to collect journal articles, via the PubMed Central system. The system whereby journal articles are delivered to NIH is quite complex. The flavor of this complexity can be seen in the instructions to authors at

Summary: The goal of public access to federally funded research results is best served via agency research reports, not journal articles.

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57 Thoughts on "My Argument for Public Access to Research Reports"

Interesting post, thanks! There are many cases where you’d want research to go through peer review and have a bit of context before the general public see it, though, right? Like about patient advocacy groups or worried parents reading outside their area of expertise.

I like the idea of opening up the reports – like you say, such a waste otherwise. I do suspect the quality and comprehensiveness of reports may be lacking in some cases (as a scientist you assume your journal articles will be read and subjected to critical review; you assume any mandated reports will go into a big federal filing cabinet and never be seen ever again). Do you know if that’s typically the case? If so you’d need a period of adjustment during which you convince scientists they need to spend longer on reports for the public *on top of* continuing to write papers for their peers which may or may not fly.

Ultimately I think articles vs reports a false dichotomy – authors and readers have expressed no interest in picking one over the other, it’s something driven entirely by the interests of intermediaries which is a warning sign that it’s not a good idea.

The dichotomy is very real; it is between a simple, efficient federal reports system and one that requires extensive federal intrusion into the scientific publishing system. Worried parents who know enough medicine to read journal articles may be a special case, and it is already met by the NIH system. It is hard to see this case extending into astronomy, geology, particle physics, polar research, etc. DOE estimates that its final reports are around 60 pages long, so they provide a lot of information, more than enough to satisfy the public mandate.

It is appealing to think that since information is good, the more the better. Such thinking ignores the question of the cost, impact and burden of the proposed system. Depriving publishers of their product is not a free good.

I think your arguments are compelling, except for the last bullet, “Conversely, providing government implemented public access to journal articles is complex, costly, and burdensome on the research community.” – which seems like pandering. The link shows complexity only in that it offers a bunch of different ways to do it. The act of submission of an article seems to be no more inherently complicated than uploading a video to you-tube.

Why are you pandering? I think it’s because the elephant in the room is that scholarly journals are, in part, charging for value-add that they do not create. Their enormous subscriptions reflect the input that they get for free – both the research and the peer-review.

Dave, once upon a time I was an expert on the design of regulatory systems, although now I mostly study science as a system. See At this time I helped design the burden budget system for the US federal government, which requires burden estimates for every proposed regulation. I did a lot of burden estimating and there is a lot of complexity and burden in the NIH system. Just figuring out how to do it the first time is a bear, and most researchers only publish one paper. For example, in many cases the author is responsible for monitoring the publisher’s submission. One wonders what the NIH burden estimate is?

As for your claim that journals add no value, I think it is groundless. Journals do collecting, sorting, ranking, editing, and publishing, all of which are valuable. Adding a federal system to further collect and sort journal articles, by agency or research project, is a needless major burden.

I didn’t say that journals add no value. I said that part of their price is value they didn’t add. The most important part of an article about research is the research that is describes, and the second most important part of a peer-reviewed article is the peer reviews. Neither of these are paid for by the journal. It’s hard to judge the value of collecting, sorting, ranking, editing, and publishing, unless the same per-reviewed information is available without those actions.

Sorry for the confusion. It is true that journal publishers do not pay for the articles, nor for the peer review. Presumably the journals would cost a lot more if they did. I happen to think that importance ranking is the biggest value that the journal system adds. But I don’t see how this applies to the issue at hand, which is how best to satisfy the perceived mandate that the public should have free access to the results of federally funded R&D. The issue is quite narrow, a matter of regulation design and engineering if you like. OSTP is asking for advice on designing a federal public access mechanism. I am proposing a design.

Yes! I think this is the approach NIH should have adopted, but I suspect there will be strong librarian opposition to this proposal because their objective is to get journal articles without having to pay for journal subscriptions. Federal funding does not require peer-review, it requires progress reports of federally funded research and these reports (annual progress reports and final reports) should be available to all.

The NIH Public Access Policy is a fiasco, requiring authors who do not have federal funding (just because they are the corresponding author of a journal article) to deposit peer-reviewed manuscripts into PubMed Central if NIH funding is acknowledged in the article, regardless of the fact that the corresponding author may be in Australia or Austria, Brasil or Bavaria. All investigators do not have an ERA Commons account, only federally funded authors.. Requiring open access to research reports opens up the results of research funding with the responsibility clearly being placed on the funded investigator.

Thanks Danny. Actually federal funding does require peer review, of the funding proposal not the final report. My view is that if the research is worth funding then the report is worth publishing. Conversely, the kind of importance ranking and filtering the journals do is not a federal function.

If the reports are good enough to meet the mandate – why bother with the journal articles?

I should clarify the above – I don’t mean why bother with the journal articles for the mandate, but rather why bother with the journal articles at all. This would save lots of people lots of time and money!

Heather, you are basically asking what value journals provide, beyond simple communication? This basic question has been a topic of extensive discussion here in the Kitchen for a long time, but it is not directly relevant to my narrow proposal. It might be relevant in the sense that making more reports available might hurt subscriptions. In those areas where reports have long been available this does not seem to have happened, although there are no studies of this possible effect that I know of. This suggests that journals play an important role beyond the raw communication of results. That is they process these results in important value adding ways (as in a kitchen!).

A study published this week in BMJ suggests that the results of fewer than 50% of clinical trials funded by NIH appear in the peer-reviewed literature within 30 months of the completion of the trial. doi: 10.1136/bmj.d7292

However successful the drive to make free access to the peer reviewed literature may turn out to be, it will never achieve the goal of providing public access to all the results of federally funded research. Something along the lines of David’s proposal would.

Interesting point, T. Scott. What would be even better would be an open research approach. Funded scientists could be required to post all of their work online as they go along, including all versions of the work, except of course for the final version with its pretty lay out, which can be left to the publisher to sell.

This is assuming, of course, that we all can agree that peer review is probably nowhere near as important as people think it is, as this idea from the scholarly publishing community that we can all rely on non-peer-reviewed results suggests.

Requiring researchers to post all of their work online as they go along would be very burdensome, not to mention intrusive. I don’t see how the value added, if any, could possibly justify this burden. )”Burden” here is a technical term in regulatory systems design. It basically means the labor hours that are due to the rules). As a researcher I cannot imagine writing up every step I take for publication, as I go along. That sort of documentation is done in certain high risk areas, such a drug development, but it is very time consuming.

The instructions for complying to the NIH Public Access Policy can be found here:

1. The policy only applies to manuscripts that arise from direct NIH funding, i.e. costs that can be specifically identified with a particular project or activity.

2. Many journals submit the manuscript for the research so there is essentially no burden.

3. Even if all else fails and an author has to deposit the manuscript them self, it looks easier than, for example submitting an article to a journal using ScholarOne. They also provide a well done video that walks you though the process. Take a look at the instructions.

Could you explain how this is such a burden?

I’ve completed a number of Health Resources and Services Administration (HRSA) grant final reports and the process was a horrible burden that made me want to tear my hair out and much of the required information was totally useless. We did conduct and publish research off the grants and though the results were mentioned they in no way provided the type of information found in a peer reviewed published research report. This point has been highlighted in several posts on this blog.

David, it is burden not a burden, the hours expended. The burden of doing a final report is irrelevant, because they must be done. We are talking about the added burden of also collecting journal articles related to the research. People often greatly underestimate the burden of a paperwork system because they do not se all the players and tasks involved. As I mentioned, just learning the rules looks significant under th NIH system. And labor on the publisher’s or agencies part is part of the burden.

David, I do not quite understand what you mean. My point was the NIH goes out of their way to make it as easy as possible for grantees to submit their manuscripts to PubMed Central. I don’t see it as much of a burden for them.

To my knowledge there is no evidence that the NIH mandate has cost publishers subscription income or placed other significant financial burdens on them. If there is, that that would be an important point to bring up in the public comment. But where is the evidence?

I think your argument is a reasonable one if grantees were required to submit an adequate description of the research methodology, results and the implications of the results of research conducted in their final reports; and if granting agencies made the final reports freely available with standardized metadata on par with is available in PubMed Central. The fatal flaw in my view is that is just not happening.

As it stands PMC provides a permanent archive for NIH research that is easily accessible and in a consistent format with metadata that facilitates researchers in doing a whole other level of meta research looking for relationships across large numbers of studies. It provides this a small fraction of the overall cost of what the federal government spends on biomedical research. In my view the cost is well worth the expense and it does not place a significant burden on either grantees or publishers.

David, you sound just like a typical regulator. Your system won’t be much of a burden and will do great good. Note that we are not talking about NIH, but about a government wide program, spanning perhaps multiple science agencies.

First of all there is a lot of burden, no matter how you do it. Burden estimating is basically workflow systems analysis. In the NIH case watching the video is part of the burden, and so is finding out that there is a video in the first place. Having done a lot of these analyses I can say that the NIH system is not simple, especially for first timers. Talking to the publisher is burden on both sides, plus the publishers who do submissions have significant burden. My wild guess is 20 to 40 hours per paper. If there are 100,000 papers a year, another guess, that is a total burden of two to four million hours a years. That is a lot of burden, the benefits of which are completely undemonstrated vis a vis simply publishing the existing reports.

You seem to be suggesting that the benefits lie in the metadata and meta analysis capabilities. That these benefits are important is speculative. Government-wide the disciplines are very different, from agriculture to astronomy, so I don’t see much opportunity. But (one of my projects) has some of this capability and can easily have a lot more, for the reports.

As for the reports being good enough, I think you will find they are in those cases where they are already made public. Note that this already covers most of the physical, space and computer science research. If some agencies are not getting good reports I suspect that will change when they are made public.

Maybe you have a point government wide but I think you are over estimating the burden. The NIH video is I believe 11 minutes if you need it the first time. The NIH estimates it usually takes 10 minutes to submit a manuscript. (

As for it taking 20-40 hours for a publisher submitting the XML directly, (again this is voluntary) I did it for my own small journal by contracting it out. It cost approximately $50 an article and that included creating fully typeset and formatted HTML and PDF versions of the article for publication as well as creating the XML and uploading it to PMC and PubMed for indexing. For a publisher that does this on a large scale, I suspect it would be somewhat less.

As I said if the final reports are easily accessible, searchable and adequately describe the research, I agree there is no need for the mandate. I searched around and found a NSF final report on a science education project that the researchers posted on their own web site. They included sevreal draft manuscripts and even a dissertation based on the research. If the reports are like that, I agree it would be unnecessary to require submitting manuscripts to a separate archive.

This is a proposal that very clearly shows which interests are behind it. Toll-access publishing interests, not citizen interests.

As a citizen and tax-payer, I have interest in deriving the FULL benefit from the research I finance with my tax. Therefore I have no interest in getting a reasonable deal on parts of my investment and a bad deal on other parts.

Exempting journal articles from the open access mandate would be accepting the unnecessarily poor deal that traditional Toll-access publishing is. It would be accepting that taxpayers finance the research and the peer review, and then allowing Toll-access publishers to lock away the results and charge our tax-financed libraries monopoly-rents to look at the research that we financed in the first place.

There is no reason we should accept that proposal.

You’re from Norway. You haven’t paid any US taxes. Therefore, you should not be able to access US-funded research in any way, shape, or form, taking your arguments to the extreme — not via open access, not through NIH portals, and not through subscription journals (after all, you didn’t pay for the research, so why should we subsidize your access by only making you pay for access instead of also having had to pay taxes).

You are a citizen and taxpayer in Norway. You have no rights as a US taxpayer, and taking your arguments to their logical conclusions, we would balkanize research if borders and tax statuses determined access rights.

Enjoy your Norwegian research. According to your logic, that’s all you have rights to.

And in turn, we in the USA should not be allowed access to Norwegian funded research? It seems like a little reciprocity makes sense, particularly when there is no additional costs involved.

Exactly. You see how ridiculous this “taxpayer access” thing could get. Let’s take the worldwide science community and shackle it to nationalistic tax policies? Genius.

I’m from Denmark – close to Norway. However, Denmark hasn’t passed a sensible Open Access mandate – so here Toll Access publishers are making the same arguments why we shouldn’t and why we should exempt their favorite cash cows.

So the argument I made is the argument I make in Denmark – it just happens to be equally relevant to the US.

You are wrong however about balkanization. Sensible Open Access definitions like the US one or the Berlin Declaration, do not make restrictions based on territory.

And neither would it be in taxpayers interest to do so – reciprocity is one reason, maximizing impact and usefullness of the research is another.

Sorry, Denmark. My mistake. I had Norway on my mind for other reasons.

OK, let’s take this one at a time. I can’t help it if the OA declarations to-date have failed to realize a direct consequence of the “taxpayer access” argument, so the fact that statements fail to acknowledge it isn’t persuasive. It’s just proof of the authors’ limited understanding of what they’re arguing and its implications. And calling them “sensible” doesn’t make them sensible.

Restrictions based on nationality are implicit in tax laws. Making the taxpayer access argument is making a nationalistic argument.

And it would be in taxpayers’ interests to limit access, because taxpayers don’t want to give freeloaders access to things they themselves have paid for. If there is a higher calling aspect to this, then appeal to that. But the taxpayer access argument is based on selfishness and nationalism, so you have to expect at some point those inherent aspects will reveal themselves. The argument is, “I paid for it, so I should have access to it.” The direct corollary is, “You didn’t pay for it, so you shouldn’t have access to it.”

(The point of this post was that there is another “it” that is more persuasively in the purview of taxpayer funded research than a scholarly article.)

As for “maximizing impact,” the impact enhancement argument around OA has been debunked for a while now. As for usefulness, that’s another weak argument — it takes specialized knowledge, access to complex machines and data, and special skills to make use of most scientific research. Unless you have magic in Denmark that can make anyone a PhD with grant funding and a well-stocked lab and temporally condensed research, simply by reading an article of their choosing, there’s no real usefulness to a cardiologist having access to a free high-energy physics article. The barriers to usefulness aren’t access to information — the barriers are much more profound, real, and difficult to surmount, things like education, funding, know-how, and persistence.

Ah, I see the problem. You seem to have missed the essence of the argument.

Tax isn’t the focus – “who pays” is the focus. “Taxpayer access” isn’t about tax – it’s about “payers”. Because the people who pay get to make the decisions. So mentioning “taxpayer access” is just a tool to remind people, that they get to decide – the Toll Access publishers just have to bid their services to the market.

Curiously, in Norway some research may not even be paid for by taxes, but by the national oil-fund. But it is still the payers who get to decide the terms of the research they fund – eg. that the results must be Open Access.

And no, it is not in the payers interest to limit access, because access has positive externalities and no cost and reciprocity is a reasonable expectation. Actually limiting access, has administrative costs, however.

And maximising impact is a simple “all other things being equal” calculation. Restricting access means strictly fewer readers, therefore not restricting access must be the situation with maximum impact.

I’ve missed the essence of the argument?!

Researchers receiving some portion funding via government grants are often required to file reports as part of the grants. The government can and often does make those reports freely available. That circle of information quid pro quo (this for that) is what David is proposing should be sufficient — research paid for, report filed, done. After that, it’s over-reach. Why should private publishers be required to make free a separate report written for different reasons and perhaps including more or less data? Where does this end? Nobody gets paid for anything except government funding? Why are researchers paying those OA fees? Why are they being charged even? How do you defend charging authors a fee to publish government-funded research when their free report is available online?

There’s a huge value publishers provide which you hint at in your response — there’s significant risk when payers get to decide the terms of the research they fund. This has been the downfall of many a researcher who lets the payer decide a) which data to include, b) which conclusion to emphasize, c) which confounding variable to downplay, and/or d) where and when to publish. A thriving, independent publishing community brings a prism of powerful and independent skepticism to research, sorting it, improving it, and removing intellectual and commercial bias from it. If you really believe that payers should be allowed to determine so much, where does this stop? Who will be there to stop it? Don’t forget, 58% of US biomedical research was funded by industry in 2010, only 33% by the US federal government. Do you disagree with requirements that pharmaceutical companies disclose studies into a government database? They used to hide studies that put patients at risk because they were, you know, acting like payers. You would applaud secrecy if you believed that payers get to determine the terms of their research reports.

As for statements like “access has positive externalities and no cost and reciprocity is a reasonable expectation,” the first has not been proven, the second is patently false, and reciprocity is unlikely when the stakes are high.

I’m increasingly convinced that many OA advocates don’t have enough experience with high-stakes research that can cost lives, and therefore view this all as a little game of jacks we’re all playing. Sorry to disappoint, but high-stakes research is a contact sport for most, and a blood sport for some. Rules like “play nice” don’t cut it in that world. And having a layer of robust, independent, and well-funded publishers — no matter their business model — is vital to clean play.

“If there is a higher calling aspect to this, then appeal to that. But the taxpayer access argument is based on selfishness and nationalism, so you have to expect at some point those inherent aspects will reveal themselves. The argument is, “I paid for it, so I should have access to it.” The direct corollary is, “You didn’t pay for it, so you shouldn’t have access to it.””

That statement might make a shred of sense if knowledge was a tangible substance that only one person could have at a time. That of course is not the case.

The REAL argument that those of us who support open access is that knowledge developed through publicly funded research should not be given away solely to a publishing company to control and sell at whatever price and under whatever conditions they decide. The written reports of the results should be made freely available in the final written form produced using grant funds. Whether this is best done through a final report or a NIH style mandate is a debatable question.

The federal funding agencies I have dealt with specifically require dissemination as an objective of the grant. Even paying the article processing fees to publish the results in an open access journal. is a legitimate grant expense. The NIH mandate itself, passed by Congress clearly shows an intent is to disseminate the results of NIH research freely to anyone in the USA or the rest of the world who wants to access it. You can argue how best to do that, but the intent is clear.

The argument that only highly trained scientists have ability to use research results is really chauvinistic. For example here are some comments I pulled about six years ago off an excellent site that has for years been a conduit for accessing OA medical journal articles. ( Unfortunately they stopped posting comments but these are just a few of the dozens of similar comments, especially from health professionals in developing countries.

Thank you for offering this excellent resource. I have CML, and although I can find a great deal of information about my disease, the most current publications are generally inaccessible to me. This list of free publications will be a wonderful source of knowledge for myself and thousands of others.

Erick J Swearengin, Payson, UT – USA

The great difficulty in developing countries like Pakistan is access to literature, even not so current. We just cannot afford enough subscriptions. This site is good and I am forwarding it on to some of my colleagues. As a maxillofacial surgeon I was hoping there would be more available on the
head and neck area.

Mervyn X Hosein, Karachi – Pakistan

As it can cost a small fortune to attempt to keep up to date with latest advances and information, this site is a boon to us working in countries without access to academic libraries.

Gloria Ann Christie, Phnom Penh – Cambodia

As a US taxpayer I do not consider the people above to be “freeloaders”. What I think is selfish and mean spirited is to not give them access to knowledge that might help or even save someone’s life when it costs us nothing.

OK, a few things here. If publicly funded research is all that you’re talking about, then make that the focus. You’ll get 25-35% of all research that way, and a lower percentage of the really cutting-edge stuff. But again, which public funded it? Why should people in one country have access to things paid for by taxpayers in another? What justice is there in that? And what risk? If we’re moving into an information economy, are we going to start raising tariffs on our research archives? Why not? If you haven’t seen the trend of governments learning how to manage their Internet nodes these past few years, you haven’t been paying attention. And how much science funded by governments is classified? In the US. the Defense Department, the Department of Health and Human Services, and the National Science Foundation account for most of the closed-door meetings in the US government. I think once you acknowledge the risks of government control, centralization, and nationalism, you’ll be closer to reality. Publishers charge money for access, period — either access to editorial services (OA) or access to information (subscription). Do you prefer unpredictable political agendas to that? I disagree with your risk assessment. Strongly.

The argument about specialists was about “utility,” not emotions. Your quotes prove this. Someone with CML can’t prescribe drugs, research new drugs, and their ability to process the information is unproven — therefore, the utility of access strikes me as low. The Pakistani’s evaluation of the value of access proves that access to parts of the literature he’s not a specialist in is of little to no value to him. And I can’t evaluate any utility from the Cambodian comment. It seems emotionally satisfying, but that’s not the argument being made was about utility. Just because someone says a tall man is tall and a short man is short doesn’t make him a chauvinist — it makes him observant.

David’s proposal was about providing free access to the US-funded research reports filed with the US government. Why isn’t that sufficient for you? It seems to me that your agenda is excessive if you disagree with that solution.

Publicly funded research was all I was talking about. I thought that was pretty clear.

Your assertion that there is no utility for people with serious illnesses such as chronic myelogenous leukemia to become knowledgeable and actively involved in their care is nonsense. I’ve taught in medical schools for 25 years and helping patients understand their illness, the benefits and risks of treatment options and participate in key treatment decisions is the standard of care.There is also good evidence it improves the quality of care and patient outcomes. If they are motivated and want to read the primary literature on their disease why shouldn’t they?

I disagree the solution above because in my experience these reports do not adequately describe the research. As i said in an earlier post, if they include an adequate description of the research, are accessible and are easily searchable that would be an acceptable solution to me.

I’m all for patients understanding their illnesses, but access to cutting-edge research papers written for other researchers and chock full of statistics, comorbidities, qualifications, references, and so forth isn’t the best path to this engagement or understanding. I’m sure access to the paper entitled, “Lapatinib induces autophagy, apoptosis and megakaryocytic differentiation in chronic myelogenous leukemia k562 cells” is the answer to patient education needs all by itself, even though it’s an in vitro study and far from reality.

If your goal is to educate patients, giving them access to a complicated, subtle, and relatively opaque literature is a lazy man’s answer.

If payers aren’t able to get scientists to write clear research reports, and journals are, then clearly journals add value in that way alone.

Ken, when you say, ” If payers aren’t able to get scientists to write clear research reports, and journals are, then clearly journals add value in that way alone.”

What you are saying is that patients should read the author’s final peer-reviewed manuscript, not the research report, right?

My goal is to allow people who want to read the primary medical literature about their disease or condition do so. Throwing up a esoteric basic research article that probably has very little direct clinical relevance is a red herring. I read the medical literature all the time for a variety of reasons including understanding my own medical conditions and I am not a physician. It takes some effort including looking up words and concepts you don’t understand but it is certainly possible for an educated and highly motivated person.

My point is there are many people with serious illnesses like Erick Swearengin that DO want to read the primary literature about their illnesses and have difficulty getting to that literature. They don’t have access to academic libraries and don’t want or can’t afford to pay the ~$35 and article typical subscription medical journals charge. PubMed Central gives them access to NIH funded research. It also gives access to health professionals in other countries who also have difficulty accessing the literature. Sure, those health professionals didn’t pay for it but so what? it doesn’t cost us anything to make it available to them and it is certainly not endangering our national security or lowering our competitive edge against other countries.

Anders, my proposal is based primarily on issues of efficiency. That is, what is the simplest, least intrusive way to provide public access to federally funded research results. You apparently have something against publishing per se. That is a different issue.

No, your prosal is based primarily on disturbing the least possible the legacy publishing models of Toll-Access publishers in the face of public interest in getting value for their money.

I have nothing against modern publishing like Open Access publishing. With OA publishing publishers and editors are free to offer their services without locking away the results of publically funded research and peer review.

Disturbing the publishers and researchers as little as possible is indeed one of my goals. It should be the goal of every regulator to minimize intrusion and burden, while getting the job done. I construe the job narrowly, in this case providing public access to federally funded research results. Restructuring the existing publishing industry is not the goal of this effort. There is nothing to suggest such a goal in the RFI.

You “construe the job narrowly”, and this is how one can tell that your proposal is for the benefit of toll-access publishing interests, not citizen interests.

And you are right that “Restructuring the existing publishing industry is not the goal of this effort”. The goal is getting value to citizens for their money. And that goal is not attained by selecting only a narrow slice of the output of the publically funded research to get get full access value in. The goal is to get full value for the full investment. And it is of course worth mentioning that nothing prevents toll-access publishers from giving the public a better offer by going Open-Access.

IF Toll-Access publishers choose to offer inferior access, they chose themselves to not offer a product that delivers adequate value to the citizens that fund research. It is their choice. What is not their choice is what products citizens should select to get maximum value for their money.

You say: “A great deal of attention has been focused on the referenced ‘peer-reviewed scholarly publications,’ or journal articles, but in the legal language they are just an example of the results of federally funded research. The term “including” signals an example. This is a common mistake, whereby an example given in a law is taken to be the general case itself.”

Actually, the term “including” signals an instance of a part in relation to its whole, not merely an example. As you say, the “whole” that Congress has directed federal agencies to keep in mind is “the dissemination and long-term stewardship of the results of unclassified research.” However, in specifically identifying two particular “parts” of that “whole”, the statute emphasizes that in pursuing that main goal these two things–“digital data and peer-reviewed scholarly publications”–are to be specifically included. The fact that the COMPETES Act of 2007 discusses the dissemination of “final project reports and citations of published research documents resulting from research funded, in whole or in part” by the government only serves to strengthen this point. In updating the statute, Congress felt it important to expand its focus from just research reports and citations to a broader set of “results of unclassified research, including digital data and peer-reviewed scholarly publications” (emphasis mine).

It seems clear that Congress wants research reports and peer-reviewed publications and digital data made publicly available. Starting with the research reports is a good idea, given that it should be relatively easy for agencies to do. But it doesn’t follow that disseminating other kinds of research results can’t be pursued in tandem with that goal.

Jeremy, I agree with your analysis but not your conclusion. If “including” refers to parts, then my point is that these parts have become the whole, which is a mistaken interpretation by OSTP. Only these parts are being considered. Regarding your conclusion, the COMPETES Act amendments do not say that Congress wants anything made publicly available. They merely mandate a study of public access policies, which the OSTP RFI is responding to.

My point is simply that making research reports publicly available is an option that should be included in the study, but the Task Force scope has been defined solely to focus on the peer reviewed literature. That is the mistake I am pointing out.

According to section 103(a), Congress is mandating the creation of a working group “to coordinate Federal science agency research and policies,” which doesn’t sound to me like only requesting a study of policies. The OSTP RFI is fulfilling the charge in 103(b)(6) to “solicit input and recommendations from, and collaborate with, non-Federal stakeholders.” I don’t think you can read the statute as reducing the whole charge of this working group to simply getting feedback and studying the issue. It’s broader than that.

I agree with you that making research reports publicly available is an option that should be included. Seems like a very sensible one to me. However, when you say that you are “presenting my case for using research reports instead of journal articles to meet the mandate,” it seems to me like you are committing the same mistake that you criticize the OSTP of making–substituting one part for the greater whole.

The proposal makes the assumption that final research reports are equivalent to (peer-reviewed) research articles.

All things being equal, the argument could be defensible. However it is my experience and understanding that final reports ARE NOT research publications, in more than one aspect.

First of all, If and when these reports are required, data is not necessarily articulated into an cogent argument. In clear, final reports often are quite raw and a good part of the researchers work –ie data interpretation– is missing or incomplete. Contrariwise, research papers are the quintessential intellectual elaboration of research data.

Secondly, peer review, however criticized and flawed, remains a touchstone in scientific research. Placing non-peer-reviewed reports in par with peer-reviewed publications equates to removing a critical check and balance in the system. Not that researchers wouldn’t be held accountable to their work anyway, but the proposal would leave the public trustees with only a very partial, skewed or incomplete view (and overview) of publicly funded research. Mind you, the overview is over research, not only the raw data.

Moreover, researchers put the most effort into obtaining grants and much less into closing projects. I acknowledge this is an oversimplification, but it is meant to underline a critical point: scientists, like good entrepreneurs, try to maximize their ROI (return on investment). Thus, if the research paper can help secure funding or a grant, so will the efforts go. On the other hand, final reports not only are rarely used to request new grants, but more often than not require the researchers to indicate the publications the grant generated, and *that* is used in the next cycle of evaluation for new grants. So, to get new grants good publications–and not (only?) good scientific results (reported)–are required.

Thus, to me it seems that the argument for equivalence between reports vs. papers is far from being matter of fact. I would go one step further: scientific reports are even less accessible to the non-specialist than scientific papers are. Final reports seldom have a non-specialist in mind.

And then comes a sticky point that is often omitted from the arguments: many public research grants include publication costs as part of the financed activities. In a way, publicly funded research not only is paying for the main resource of the publishing industry (ie the research AND the peer review), it openly subsidises publishers via the same grants.

Now, the efficiency argument would make sense to me if: a/ researchers and publishers had to go far out of their way to accomplish what is requested (ie register a revised copy of the manuscript online) or b/ that publishers or researchers had a one in a lifetime complicated process to complete. But neither argument seem convincing, since (as mentioned in other replies) the registry process is not particularly cumbersome, and that publishers quite rapidly incorporate and streamline the whole process, whereas individual researchers absorb the shock of this and more intricate and arcane requirements and shape-shifting rules routinely, with different funding agencies, different research partners, interacting faculties or industrial partners, etc.

The OP further mentions that most researchers publish only once, making the process all the more cumbersome on the individual; though that maybe true, individual researchers are, more often than not, part of articulate institutions, so many of these tasks are integrated into the routine administrative staff functions. So the “one off” cumulative effect should not be, in the whole, all that burdensome.

By nature science is a shared resource, a commons of sorts. It knows no boundaries and recognizes no nationality. Gravitational law, Natural Selection, or the Principles of Thermodynamics apply everywhere, whether discovered by Chinese, German, English or French. Publishers run a risky business in resisting open access to science and the free flow of information, as many of the means for self-publication become increasingly available. As specialist societies published their own journals in the past, such publications might readily re-flourish.

I do consider that publishers have an important role to play in the communication of science. However in this digital era, services the industry offers have to evolve and adapt. Publishers should be heralds not gatekeepers because, at the end of the day, information, as Diderot said:
«passeront entre leurs jambes ou sauteront par-dessus leurs têtes, et nous parviendront.» (Lettre sur le commerce de la librairie)
(will pass between their legs or over their heads, and they will reach us).

I most certainly do not assume that research reports are equivalent to journal articles. In fact I point out that journal articles include a lot of value added, including peer review based sorting (this is not for us), ranking (this is not good enough for us), editing (this this unclear) and even more research (do this differently). In subscription journals none of this work is paid for by the federal government, which is one of the reasons that seizing the resulting articles is intrusive. The government is taking something it does not own.

My point is simply that publishing the research reports, which the government actually owns, is sufficient to meet the mandate of public access to research results, because they are the research results. As for quality, the ones I have seen are fine. I have three in the system, two at DOE and one at DOD, and they are (self praise to follow) very good. Research reports are not the same as journal articles, but they do the job.

My impression from your writing is that you simply think journal articles should be free. That is a different issue, a much broader issue, than public access to research results.

I understand your position, and we must agree to disagree. In particular, our appreciation of the added value of journal articles differs fundamentally. I consider the writing process (including the peer-review) to be research at its best. And that that part of this process is in part paid for by the granting institutions is also a point in which we differ. As for ranking, editing and marketing, these are indeed out of the research field: services offered by the publishers.

The funding agencies sensu latu (be them public or private) pay not only for data, but for the whole process of research. As I stated previously, some funding agencies clearly specify that part of the grant is to be used to pay for writing (including contracting professional copy-editing services, but often is mainly translations) and publishing of the said research. (I do not want to open a can of worms, but there is also the issue of publicly funded research leading to patents. Something to keep in mind. Full disclosure of raw research results, and even research reports could ultimately undermine technological drive.)

As for the said reports, I do not question their quality. As in many things I can expect there are good ones, and also bad ones. In my opinion they do not have the proverbial “layman” in mind. Thus, limiting open access to these reports alone would accomplish disclosure, not openness.

My position does not imply that journal articles should be free. In a nutshell:

1/ Knowledge (not journal articles) should be freely accessible. It is upon free exchange of knowledge and ideas that science is ultimately built.

2/ Publicly funded *research*, and not only the results, ultimately belongs to the public.

3/ Publishers have a right to sell their product. Its the product that needs redefining, and some beefing up.

The NIH approach on this matter seems to me quite even-handed, since journals have a year long embargo on their articles. Half-life of most publications is beneath that threshold, specially in highly competitive research fields. Besides, as Kent Anderson points out, this concerns publicly financed research (eg only 33% of biomedical research in the USA.)

The NIH does not require final proofs to be placed in the repository, only manuscripts reviewed and accepted for publication (out goes the editing). Neither does it require that the journals own electronic copy be made public: PubMed Central has its own hosting facilities (no undue burden on the publishers internet bandwidth or repositories). An argument could be made about PMC “stealing” ranking, but even that argument goes out the door: PMC is not a peer reviewed journal, it is neutral vis-à-vis singular journal branding and reputation and does not have any effect manuscript submissions to journals. It is up to the publishers to convince the users to use their website and buy their other products (ranking, marketing, networking, business intelligence, etc.)

There is a business-model shift ongoing, but this change is not a produce of this particular USA mandate. It is a product of the internet, and its inexorable transforming force remodelling in how we communicate and relate to each other.

In the internet epoch, wide and instantaneous distribution is already achieved. Diffusion is not enough. Scientific journals must brand their authors, convince their colleagues that a particular journal is “the place to be seen”. As to how the journals earn a living, various business models are available that are not incompatible with open and free access to journal articles.

Journals, in this era of social networks, should seek to lead in the means to achieve the ultimate goal of scientific publication: to guarantee authorship relevance, reputation and enduring notoriety. However, reputation and notoriety go both ways, and so long as NIH (or other publicly funded research) is of quality, publishers cannot do without this important resource.

A note about relevance: citations of papers are a direct and well established method by which scientists recognize the relevance of each others work. And citations are the ultimate currency in scholarly publications: they give journals their impact factor, they give authors their h-rank. An increasing body of evidence points to the fact that readily accessible information significantly increases the chances of any given research to be cited (know as the Open Access Citation Advantage – OACA).

Whether confirmed or not, it is good to keep in mind that knowledge not shared ultimately withers and dies.

P.S. BTW, I do retain the particular practice of full concession of copyrights to the publishers a questionable practice, but that is way off topic.

An interesting and obviously controversial piece.

In a far-flung aside, I want to point out that download statistics, particularly from publicly available sites are highly suspect. You say that, “Last year, over 30 million (that’s million) were downloaded from Information Bridge alone,” but I have to wonder how many of these are robots and other automated (i.e. not generated by human/reader interest) activities.

We used to see the same thing in journalism about 10 years ago where an newspaper editorial would frequently begin, “One of the most important issues of our time is (for example) ocean acidification. A Google search for “ocean acidification” yields over 10 million hits.” The latter was included to justify the importance or prominence of the subject being discussed. But most contemporary journalists have dropped this tactic since even the most obscure of topics will show millions of hits on a standard web search.

I think the same thing is true of download statistics.

Again, a very well-thought out piece on which substance I will not offer comment. I only want to suggest that the utility or popularity of freely available documents on the web can’t truly be measured by the number of downloads.

Alvin, I am not an expert on this but my understanding is that robots seldom do downloads, because you have to take the actual document, not merely index it. An exception might be when they are duplicating a collection for someone else to use. Web page hits are a notorious problem, because of search engine robots. In that regard I think DOE got over 250 million hits last year. That is why I use downloads to measure what is likely to be mostly human activity. Google search hits are a different matter entirely. They are occurrences of at least one search term on any of the billions of web pages that Google has indexed, which is why the numbers are usually absurdly high.

Others here may know more about this usage issue and I would be interesting in hearing it.

Anders, to reply to your comment above (I ran out of nesting) the value to citizens is supposed to lie in the research itself, and the progress it brings, not in giving away articles. This is a well established system. If you want to give away the results you can give away the research reports. Or we can switch the industry to author pays OA and do that much less research.

David, I agree that a significant part of the value in supporting research lies in the research itself, and the education of researchers it enables etc. But that is simply no excuse for Toll-Access publishers to claim that the public should forfeit the value of access to the published results of their supported research. The public should get full value on the full investment.

And that that author-pays-OA leads to less research is a tired lie – easily exposed by anyone who looks at the public expenses allocated to Toll-Access fees in libraries.

Here is a good introduction:

Anders, you are now using rhetoric and name calling instead of reasoning. Terms like “Toll-Access”, “forfeit”, “full value”, “full investment” and “lie” add nothing to our discussion. You are merely reiterating your original claim, that access should be free, in louder language. You offer no reasons.

As for author funded OA, I assume that these charges will be paid by those who fund the authors, that is out of research budgets. It is possible that library money will be shifted somewhat, but the US federal funding of libraries is as nothing compared to its funding of research. (Your link does not address this issue by the way. Plus its numbers are off.)

The question you do not address is who will pay for publication?

David, you claimed that “the value to citizens is supposed to lie in the research itself, and the progress it brings, not in giving away articles”.

I disagree. Why exclude the articles from the value-calculation? I see you offering no argument as to why articles are not part of “full value”.

So “full-value” is a technical term describing all contributors from funded research to citizens – and I believe that “forfeit” is an appropriate word for your (unargued) opinion that citizens should not get the value embodied in full access to the communicated results of the research they funded.

As for “Toll-access” you are free to offer a more descriptive word, I don’t know any.

You claimed or repeated other peoples claim (implausably and without evidence) that author-pays OA results in less research. I presented evidence to the contrary.

And your remark now that “US federal funding of libraries is as nothing compared to its funding of research” is undoubtedly true – but you fail to explain how it is relevant. Do you claim that all research costs will relate to publication charges? Do you claim that the majority of the cost will? If not, why did you make that remark, and not qualify it?

The question you did not address is: Who already pays for publication through Toll-Access charges to publically funded research libraries? Can you present any evidence that (total revenue per article etc.) that shows that the public pays less in total with Toll-access publishers than with Open access publishers?

David I agree with everything you say except that last statement. that we would do much less research if we moved more to an OA model.

The cost of publication is the same assuming digital publication with both subscription and open access publishing. The only difference is how publication is funded. It would create some cost shifting depending who covers the article processing charges, (APCs) but why would we do less research with open access publishing?

I suppose you can argue that funding agencies paying APCs, which at least the Public Health Service already does, drains research funds. John Willinsky showed that even using an generous estimate of $3,000 for an APC, far higher than most APCs charged, that would only be 5% of the estimated $60,000 NIH spends on funding the research to generate each each published manuscript coming from an NIH grant.

Subscription fees are currently being funded largely by university libraries. Librarians, at least the ones I have spoken with would be happy to spend that money on publication fees rather than subscription fees. By in large, they see the value of open access publishing. They just can’t free up money for APCs when they are forced to pay subscription fees to keep journals faculty want or programs need to keep to maintain accreditation. Libraries are locked into the subscription model, in my view a legacy model, that since the development of the World Wide Web is not in our best interest. I am not saying open access funded through APCs doesn’t have problems. It does, serious ones, but so does the subscription model.

Why I prefer the OA model is it solves the core purpose of scholarly publication which is dissemination. The subscription model has an inherent contradiction that I see no way around. It funds dissemination by limiting it. It is possible to mitigate this contradiction but there is no way to solve it. It just makes more sense to me to work on improving the payment system of a model that facilitates the intended purpose of scholarly publishing which is dissemination and redirect the same money that is already being spent to pay for it. That would still lead to cost shifting but it would largely be between academic institutions that are research intensive and academic institutions that do mainly teaching.

David, I share your concern about dissemination, in fact I have done computer modeling of it using a disease model. This brings up an advantage of research reports that has not been discussed, which is speed. The typical journal article on the NIH plan only becomes available perhaps 2 years after the research is done, but the report is due in 90 days.

There is an over reaction to this bill. This bill is protecting the rights of publishers to avoid having their copyrighted articles distributed for free by federal law which overwrites their rights. That is, it is a correct bill.

It does not prevent open access articles from being freely distributed. That is, if you want your articles to be freely available, publish them in open access journals, not in subscription journals. This law in no way forbids open access articles from being freely distributed.

My suggestion, if this bill passes, if for the public granting institutions to enact rules that publicly funded research must be published in open access journals (or pay the open access fee to Elsevier). That is, forbid publishing (and thereby transferring copyright) to “regular” journals. This will enhance the quality and reputation of open access journals, therefore it’s a beneficial situation for the future of open access publication.

Conclusion, this bill will end up helping open access publication by shifting publication of publicly funded research from subscription journals to open access journals.

RMS, I have no idea what pending bill you are referring to but if there is one perhaps you can enlighten us and we can look at it. As for requiring publication in OA journals, it is my understanding that one of the UK Councils does this, but it would face serious free speech obstacles in the USA. The government does not own journal articles that are written after the research contract expires, which I think is most of them. So it really cannot tell us researchers where, and where not, we can submit our articles. It will be a fun fight if they try.

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