FASEB Responds to NSF’s Public Access Plan 2.0

By: Darla P. Henderson, PhD
Wednesday, December 20, 2023
On December 10, FASEB submitted written comments to the National Science Foundation (NSF) regarding the NSF Public Access Plan 2.0 outlining steps the agency will take for increasing public access to results of NSF-funded research. With phase 1 of the NSF’s plan scheduled for implementation in January 2025, 11 months earlier than required by a White House Office of Science and Technology Policy memorandum, FASEB notes that the shorter timeframe further amplifies the importance of continual engagement with the broad research community. FASEB welcomes the opportunities NSF provided through listening sessions earlier this year and by issuing an RFI for written community comments. 
 
Alongside federal agencies, FASEB appreciates the opportunities public access can bring to further scientific understanding and improve human health. To achieve this goal and the shared desired outcome of research being responsibly conducted, rigorous, and reproducible, FASEB emphasizes the importance of public access plans always being accompanied with a focus on scientific integrity. 
 
In response to NSF’s specific questions on potential barriers to implementation, FASEB highlights three issues: 
 

1. Community and stakeholder confusion. FASEB advances the idea that NSF could create a Publication and Data Cost table in the Proposal and Award Policies and Procedures Guide (PAPPG) and requested the agency further clarify the specific manuscript types included in the agency’s policy.
2. Resource needs and the significant impact of public access changes on scholarly societies. Recognizing that there is already in place a diversity of business models across the system, and this system is unlikely to change by 2025, FASEB encourages NSF to be flexible with how researchers may meet the new policy requirement. FASEB focuses also on the notable vulnerability of scholarly societies in the U.S. who most often have modest revenues, and who rely heavily on the revenues from publications to support not only publication and data, but also to support other efforts that advance the sciences and are a central part of the broader scientific ecosystem, including conferences, education, career development, recognition, policy development, and more. In consideration of this environment, FASEB suggests NSF look at the implementation of their plan in two phases— supporting and accommodating a transition via a variety of models that support peer-reviewed research findings and, later, refining implementation and guidance with knowledge gleaned from more extended stakeholder feedback and environmental changes.
3. Inconsistent use and support for existing infrastructure. FASEB applauds NSF’s commitment to work with the existing infrastructures, including generalist repositories and PIDs such as digital object identifiers. At the same time, FASEB appreciates that NSF recognized that preservation of digital content will require added support and resources.  

 FASEB next addressed NSF’s question of how to best engage with affected communities on public access issues, notably marginalized or underrepresented groups. First, FASEB recognizes that we can reasonably anticipate researchers from underserved populations being disproportionately impacted by public access requirements. New costs, added time, and administrative burdens are expected consequences. FASEB encourages NSF to recognize this disparity as a first step to better understanding and exploring paths for supporting the impacted populations. Further, FASEB encourages NSF to explore accessibility challenges broadly, to actively consult with English language learners, researchers with disabilities, and the broader public to ensure agency resources are inclusive of their concerns, questions, and needs. 
 
FASEB reiterates its commitment to supporting the academic freedom of researchers, including keeping the choice of where to publish research findings and under license terms that they choose. Overall, FASEB notes the particularly unique position of scholarly societies as domain experts who can promote culture change and serve as potential partners for federal agencies, including NSF, as they look to advance public access policies.