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The world of scholarly publishing seems to have an affinity for crises and existential threats, and it is likely that the next few years will see us adding a new and complex burden to our anxieties — managing the enormous number of policies and requirements being placed on authors and their papers. This problem is just starting to be recognized, and creates time and effort costs across the spectrum of publishing, including extra work for publishers, librarians, administrators and researchers. Are there ways we can lessen this burden by planning for it in advance?

Rick Anderson recently offered his thoughts on a UK study looking at the administrative costs of compliance with (primarily) the RCUK and HEFCE access policies. In reading through recent rounds of open comments on the RCUK policy, I was surprised at the amount of problems and costs that administration of the policy was causing. This study starts to put some concrete numbers behind what seems to have been an unanticipated downstream effect. Libraries are already facing significant financial problems with increased overall costs due to having to pay article charges to make UK papers free to the world while still having to pay for subscriptions to access research from outside of the UK. The administrative burden makes the policies even more expensive and difficult to enact.

It would be tempting to look at the raw numbers from this study and try to extrapolate them to an all-open access world (£9.2M for 20-30% compliance levels for the 6% of the world’s literature that comes out of the UK likely would result in a number well above $1B for worldwide administration efforts alone). But as Rick noted in his post, it’s unclear how well such efforts would scale. Perhaps more importantly, it understates the growing complexity of the compliance landscape.

One of the striking things learned when doing the initial pilot studies that led to the building of CHORUS was that very few papers had only one funding source listed. So, for each paper, it is likely that multiple, sometimes overlapping, sometimes contradictory funder policies must be followed. Research is increasingly collaborative and increasingly international. As author lists expand, this means each paper is thus more likely to fall under multiple governmental policies and multiple institutional policies. Perhaps we need to start thinking exponentially instead of just doing the simple multiplication above.

For a journal, this means tracking an enormous number of policies and constantly updating and changing terms and conditions in order to help authors remain in compliance. Librarians and administrators are under the same burden and need to carefully monitor all scholarly output from their institutions, compare these with any policies that apply, and ensure that publication happens in compliant venues. Authors will need to know not only the rules for their own funders and institutions, but for those of all of their coauthors as well. Picking a journal for submission may become a minefield of competing interests and hard to parse rules.

As an example, MIT recently updated their campus policy on publication agreements to help bring them into line with the Department of Energy’s announced public access policy. While the move was made with hopes that it will be comprehensive across all US federal funding agencies covered by the 2013 OSTP Memo, it’s unclear how well it will line up with the more than 20 individual funding agency policies that have yet to emerge from this group alone. The DOE policy offers multiple routes to compliance, and most federal policies seem set up for evolving towards more efficient routes over time, so steps taken to ensure compliance will similarly need to evolve. And that only covers the US federal funders under the OSTP policy. Different amendments may be needed for other federal government funders, not to mention public funders at different levels, funders from outside of the US, and private funding agencies.

If you run a journal, you’re going to have to read this amendment and adjust your publication agreement accordingly (or ask MIT authors to request a waiver from the policy). Multiply that by every university and every funding agency on earth, and you’re likely going to incur some serious costs in keeping up.

More time, effort and monetary costs for journals, for universities and for researchers are likely on the horizon, and that’s before we start talking about article processing charges or the cost of building and maintaining repositories. If you really want to get depressed, this only considers policies about access to research papers. Add in policies for access to data and all the complexities involved there and you’re jumping way further up that exponential scale.

Three factors will help everyone contain costs and that should be an important goal — research funds should be spent on doing research, not on policy compliance:

1) Convergence of policies on common principles:  We’re still in something of a formative phase. New policies are announced every week, and they vary widely. Ideally, over time this multitude of policies will find common ground and converge on a similar set of principles. If everybody sets the same rules, then monitoring becomes vastly less complex.

2) Implementation of standards and openly available tools:  As with any complex system, the more we can standardize and use the same toolset, the more the different components can talk to one another. If all players use commonly available tools like DOIs, ORCID IDs (that phrase still rankles, much like “ATM machine”), and CrossRef’s FundRef service for identifying the funding sources behind research, then compliance tracking becomes much more feasible.

Tagging research outputs with standard tools like these enables the creation of tracking tools (such as the CHORUS dashboards built for funding agencies or the planned SHARE notification tool). This adds efficiency, allowing multiple outputs from multiple researchers with multiple funding sources to be tracked simultaneously, rather than individually one-by-one. The use of common tools and identifiers is particularly important for linking research papers to research data as well.

3) Automation of compliance: Where policies have required extra work on behalf of researchers, compliance levels have historically been poor, particularly when efforts weren’t made to enforce those policies. For the researcher, time spent interpreting rules and hand-depositing papers in repositories is time spent away from the bench. For the funder, time spent chasing after non-compliant authors is time spent away from working toward the agency’s true goals.

PubMed Central (PMC) works really well because publishers deposit papers automatically on behalf of funded authors. Kent Anderson’s posts about PMC indicated that around 80% of what gets archived there comes from publishers. This level of automation, where compliance becomes part of the standard publication process, is key to both reducing efforts and ensuring high levels of compliance.

Automation of compliance was a key principle in the design of CHORUS. Given that publishers are increasingly concerned with the clear competition offered by PMC, it is unlikely we’ll see another such industry-wide effort to automatically post papers in third party repositories. If funders and institutions can accept access coming via journals, particularly with the guarantees of perpetual public access that CHORUS requires, then this offers a path to cost and effort reduction.

Unlike many of the “crises” facing scholarly publishing, compliance is one we can clearly see coming. Rather than waiting for things to get desperate, we can implement plans that minimize the burdens that will need to be endured. This will require awareness on behalf of all stakeholders, along with flexibility and a willingness to collaborate on shared policies and shared solutions.

With careful planning and cooperation, we can turn this hurricane into a drizzle.





David Crotty

David Crotty

David Crotty is the Editorial Director, Journals Policy for Oxford University Press. He serves on the Board of Directors for the STM Association, the Society for Scholarly Publishing and CHOR, Inc. David received his PhD in Genetics from Columbia University and did developmental neuroscience research at Caltech before moving from the bench to publishing.

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25 Thoughts on "Compliance: The Coming Storm"

Very few papers had only one funding source listed. So, for each paper, it is likely that multiple, sometimes overlapping, sometimes contradictory funder policies must be followed.

I can easily see how there could be overlapping funder policies, but I can’t offhand think of how they could be contradictory — could there really be one funder that insists on open access and another that insists on a paywall?!

Do you remember any cases of outright contradiction?

For a journal, this means tracking an enormous number of policies and constantly updating and changing terms and conditions in order to help authors remain in compliance.

Really? Are there any funder policies, or any possible combination of policies, that would not be satisfied by a simple CC By licence? If, as I suspect, that satisfies all funders, then isn’t the work of journals like PLOS ONE and PeerJ already done?

Hi Mike,

I combined your two comments into one because I think they both approach the same question, basically that if you take the most extreme position, you may be better able to satisfy funder/institutional requirements across the board by going beyond what’s asked of you in most cases. If an author is DOE funded, they don’t need any particular licensing terms, but if a coauthor is Wellcome funded, they want a CC BY license. If author 1 wants to publish in Nature, they’re in conflict with author 2 who can’t publish there.

Nature then needs to look at these two very different policies and decide what it wants to do. The needs of authors for these funders must be weighed against business concerns and sustainability issues. We know that authors favor more restrictive licenses and we know that there are many unfunded authors and entire fields that can’t afford article processing charges. By taking an extreme position, you may be able to save effort in tracking different policies, but you may also be at a competitive disadvantage. CC BY results in the loss of secondary rights revenue, meaning higher prices for authors and subscribers (a high APC might harm you with authors who have the option of publishing in similar journals at no charge and still meeting the needs of their funders).

Most policies allow for waivers, so a blanket policy of requiring all authors request waivers might be equally effective.

Also note that US government employed authors are required to release works into the public domain and CC BY is not adequate for this.

Thanks, David, very helpful. On the last point: interesting that publishers have coped for many years with federal employees’ work being in the public domain. I suppose that edge-case was the first shot fired in the policy battle you describe.

Burden is indeed an issue. Regarding the OSTP agencies under the US Public Access program, most will probably have to go through rulemaking in order to implement their public access plans. (DOE is an exception.) Each rulemaking will require a detailed burden estimate, part of what is called the Information Collection Request (ICR) that goes to OMB for approval and is issued separately for public comment. The burden is supposed to be minimized so people might want to comment on how to do that, along the lines outlined in this post.

I think what you’re talking about here is what Kyle Grayson in 2013 described as “managerialism.”

He explains managerialism in a blog post called “Why UK Open Access Threatens Academic Freedom,” available here:

Gold open-access introduces even more bureaucracy to higher education and is making it harder for authors to communicate their research findings.

Under the subscription model, all an author needs is a good manuscript.

Under gold open-access, a scholarly author needs funding, connections, administrative approval, forms, red tape, deadlines, compliance managers, and the like.

Good point Jeffrey. Note too that all this burden on the authors is not included in the British burden estimate study that David C. cites. That study just looked at the burden on the university. When the US agencies do their burden estimates they will have to include author burden and that should be very interesting. However, the US Public Access program is delayed green not gold so the burden associated with gold will not be included. In either case burden is a big deal.

“Under the subscription model, all an author needs is a good manuscript.”

This is a rather drastic oversimplification, speaking from my experience as an author who has published in various open access and subscription journals. Even in a subscription-based journal (I am thinking of examples published by Elsevier and Taylor & Francis within my field), I may have to get funding for page charges, color figures, or other publication necessities (or at the very least, spend time back and forth with the editor and publisher on negotiating a waiver). It is not entirely unusual for some institutions (especially those outside of North America) to require administrative approval, or at least administrative notification, before their staff can submit a paper. Also, some institutions effectively have lists of “approved” journals (e.g., exceeding a given impact factor), and authors have to be in compliance with those. If the paper is published, and I am publishing on fossil specimens from US public lands (speaking for my field of paleontology), I have to make sure the relevant agency is appropriately credited in the paper and that the agency receives a copy of the paper after publication. In fact, this applies to just about anything housed in a museum collection (i.e., the museum probably needs a copy as part of their record-keeping, even for non-federal specimens). Funding agencies will want a copy and a report too (this applies to both public and private monies).

In the subscription and OA-models alike, the journal will probably require me to massage references into a given format (and even with a reference manager I have to sink some time into this), ensure that the figures are sized within the appropriate 0.1 mm of figure width and use the required font, etc. I’ll also have to suggest a list of reviewers, and probably do the data entry into the journal’s manuscript submission portal. And let’s be honest–having connections to the editorial board (even when editors and authors are acting completely within the bounds of ethical behavior) doesn’t hurt (if that’s what is meant by “connections”).

So the summary of all of the above is that, no, under the subscription model, a good manuscript is not sufficient.

‘Under the subscription model, all an author needs is a good manuscript”

As well as a subscription base that isn’t being quickly eroded by flat or declining library acquisition budgets.

If an author wants to communicate their research findings (adequately) under the current subscription model it depends almost entirely on the willingness of libraries to purchase a subscription to a given journal.

I am curious. Is there a line item in a grant application for APC and if not. Why not?

I can only foresee APC increasing exponentially because of all this nonsense about making something free that has a miniscule audience!

I can only foresee APC increasing

You don’t see the emergence of a functional market driving prices down?

Isn’t a functional market in scholarly publishing about as likely as a functional market in health care? There are a lot of factors that go into the decision that have nothing to do with price, and also factors that the purchaser does not have a say in.

Amanda, we surely will not get an ideal market. Nevertheless, an APC-based scholarly publishing market is one where authors can use whatever provider they think provides the best balance of services and price, whereas in a subscription-based market, librarians who want to have Cretaceous research can only get it from one place. Monopolies never make for good markets, and the fact that each journal is only available from a single source is surely a big part of a reason for the skyrocketing prices of subscriptions.

Harvey, it would be difficult to have an up front budget item on APC’s because you do not know how many papers will be written, or where published at what cost, if any. In the US Federal case there also could not be a charge for papers written after the research is done, which many are, because there is no way to hold money after the grant contract ends. All left over money is returned on contract closeout. So all in all it is a difficult legal issue.

Angela, to my knowledge none of the issues you raise in that TSK post have even been addressed, much less resolved. The DOE guidance is silent or vague on them. Perhaps if we finally get some Public Access rulemakings we can get some answers. Agencies are supposed to respond to the comments made on their proposed rules, when they publish the final rules. Feel free to ask away.

Actually, David C., right now anyone can ask DOE these sorts of compliance questions with reference to their PAGES system. Just email the questions to which is the PAGES email hotline. They need not answer and the answers will not be official but it is certainly a place to start. They have been very nice about answering my questions.

David, Can we ride your coattails here to promote upcoming learning opportunities?

Looking to SSP 15, there will be at least one rich session on Compliance in the meeting program, I believe led by one David Crotty. Not to be missed!

The SSP Education Committee is also developing a Pre-Conference Session on Standards that will have some overlap with and expand on David’s point 2 above especially.

“2) Implementation of standards and openly available tools: … the more we can standardize and use the same toolset, the more the different components can talk to one another. If all players use commonly available tools like DOIs, ORCID IDs … and CrossRef’s FundRef service for identifying the funding sources behind research, then compliance tracking becomes much more feasible.”

Paraphrasing the environs of pt. 2 from there: such Standards will enhance efficiency, automation, and convergence of Compliance. “Leveraging” these emerging trends sooner will allow publishers’ to weather the storm best to enjoy what follows to the fullest: after the storm, flowers bloom.

The Pre-Conference Session should also dovetail with points 1 and 3, as Standards and Compliance are interrelated. Stay tuned for more!

Great piece, David–and timely delivered (looking ahead for all to benefit)!

For government authors, journals already operate in a gray area of purchasing, where the author essentially makes a noncompetitive choice of a vendor for publishing services. I spent my career in a government science agency, and I can’t think of any other type of purchase where this is allowed. With APCs becoming a more significant part of the research budget, how much longer will it be before the “bean counters” start asking awkward questions about APCs and, say, Impact Factor or circulation? Will journals have to get onto a purchasing schedule? Will they have to compete?

I’d seen it, and hopefully a good sign, but I’ve learned to keep my expectations low when it comes to the policy front, particularly when any sort of cooperation is required…

Indeed, the stark contrast between British and US government policies is an example. They are almost polar opposites.

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