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NIH Invites Recommendations on How to Implement and Monitor Compliance
with Its OA Self-Archiving Mandate
SUMMARY: NIH is now calling for a round of public recommendations on
the best way to implement and monitor compliance with its OA Self-
Archiving mandate. My own recommendation below is designed to make the
NIH mandate efficient and successful for NIH and its fundees and to
ensure that it reinforces and converges with the growing number of
complementary university self-archiving mandates (such as Harvard's).
The gist is that (1) NIH's preferred locus of direct deposit for the
postprint should be the fundee's Institutional Repository (IR) (from
which it can then be downloaded to NIH) and that (2) the fulfillment
conditions on the NIH grant should stipulate that the fundee
institution monitors that the deposit has been made. Please make your
own recommendations here.

In a very responsible and timely way, NIH has now called for a round
of publicrecommendations on the best way to implement and monitor
compliance withNIH's Green OA Self-Archiving mandate.

If you feel (as I do) that it is important to implement the NIH
mandate in a way maximize its efficiency and likelihood of success, as
well as making it an optimal model for all research funder mandates
worldwide to follow, I urge you to make your recommendations here.

I append my own recommendation below. It is extremely simple, and
designed not only to make the NIH mandate efficient and successful for
both NIH and its fundees, but also to ensure that it reinforces and
converges with the growing number of complementary university self-
archiving mandates (such asHarvard's) rather than diverging, competing
or complicating.

The gist is that (1) NIH's preferred locus of direct deposit for the
postprint should be the fundee's Institutional Repository (IR) (from
which it can then be downloaded to NIH) and that (2) the fulfillment
conditions on the NIH grant should stipulate that the fundee
institution monitors that the deposit has been made.

(There is also a Question 3 for you to recommend ways to improve NIH
instructions to fundees, and a Question 4 where you can -- and I hope
will -- reaffirm support for the NIH policy itself.)

Here are my own recommendations for 1 and 2, and my expression of
support for 4:
Question 1:  Do you have recommendations for alternative
implementation approaches to those already reflected in the NIH Public
Access Policy?
Yes. Modify the procedure for fulfilling the deposit requirement of
the NIH self-archiving mandate in order to make it compatible with,
and to reinforce, university self-archiving mandates (such as
Harvard's):

In the NIH interface, at the point of deposit, add a feature that
allows the full-text deposit to be downloaded from the URL where the
full-text has already been deposited in the fundee's institution's
Institutional Repository (IR).

And stipulate in the overall instructions that the preferred way to
fulfill NIH's self-archiving mandate is to deposit the full-text
directly in the fundee's IR and then download it to the NIH deposit
site.
Question 2:   In light of the change in law that makes NIH’s public
access policy mandatory, do you have recommendations for monitoring
and ensuring compliance with the NIH Public Access Policy?
Yes. The optimal way to monitor and ensure compliance is by making it
part of the grant fulfillment conditions for the fundee's institution
that it must monitor and ensure that the deposit is made.

The best and easiest way that an institution can monitor and ensure
deposit -- and at the same time encourage or mandate the self-
archiving of all the rest of its own institutional research output in
all disciplines (not just NIH-funded research) -- is to require direct
deposit in the institution's own IR.

See: "How To Integrate University and Funder Open Access Mandates."

Do not rely on direct deposit by publishers! It will only make the
monitoring of compliance more divergent and difficult. Direct deposit
should be convergent on the fundee's IR, to create a synergy with
institutional mandates.
Question 3:   In addition to the information already posted at http://publicaccess.nih.gov/communications.htm
, what additional information, training or communications related to
the NIH Public Access Policy would be helpful to you?
[See Public Access Communications and Training and suggest what would
make it clearer and easier for you. The principal thing is that the
deposit itself should b in your own university's IR. The deposit can
then be downloaded to NIH.]
Question 4:  Do you have other comments related to the NIH Public
Access Policy?
The NIH Green OA Self-Archiving policy is splendid, timely, historic.
But it can be made orders of magnitude more successful, effective, and
worthy of emulation worldwide if the one small implementational detail
recommended above is adopted. It will create a synergy between funder
OA self-archiving mandates like NIH's and institutional OA self-
archiving mandates like Harvard's, with one convergent point of direct
deposit (the institution) and both the institution and NIH jointly
monitoring and ensuring compliance. It will also maximize the
contribution of the NIH OA mandate to the growth and success of OA
mandates, and OA, in all fields, worldwide.

Stevan Harnad
American Scientist Open Access Forum