ASAPbio (https://asapbio.org/about/) is a non-profit, researcher-led organization that advocates for timely, open, and rigorous research communication. We work to create a life sciences communication ecosystem where all research papers and other outputs are shared rapidly and without restrictions on access or reuse, and open and constructive exchanges take place on research products at all stages.
We write from the perspective of life science researchers and open science infrastructure providers (like preprint servers), our primary constituencies. Although ASAPbio objects to many aspects of the proposed rulemaking, as it would have a wholly negative impact on federally-funded research and American scientific progress, we focus our comment on two specific parts of the proposed rule: 200.461 and 200.454.
§ 200.461 – Publication and printing costs
OMB proposes to make publication costs, including article processing charges (APCs), unallowable for Federal awards, a reversal of current practice. In principle, we support efforts to spend as much federal support as possible on research costs. However, it’s critical to move away from APCs in a measured fashion, so that the ecosystem has time to adapt. If this transition is implemented too rapidly, key parts of the research communication ecosystem (such as small, non-profit or academic society publishers) will be forced out of business, leaving researchers with few options for journal-based publishing. We therefore urge a slower transition to stopping APC payments, allowing the research ecosystem time to develop alternative sustainable approaches to research communication in an orderly transition.
One alternative would be to limit the total allowable amount of spending on publishing costs while supporting alternatives to APCs. For example, there are other ways that the U.S. government can support open and rapid public dissemination of research. Preprints – author versions of scientific papers shared publicly without delay as soon as researchers are ready – are a cost effective way to achieve public access. The preprint ecosystem is already well-positioned to deliver public access at scale, and it is growing rapidly. bioRxiv, for instance, regularly adds over 4,000 new papers each month, while medRxiv adds over 1,300 per month (cumulatively publishing over 564,000 papers since their foundings in 2013 and 2019, respectively). arxiv hosts over three million papers, with monthly submissions recently topping 30,000.
Importantly, although these services make it possible to read and post papers for free, they are not free to run. Re-routing funds that would have otherwise gone to APCs to support open scholarly infrastructure like preprint servers is a smart investment that serves the public good. Furthermore, allowing preprints to serve as a method for public access policy compliance would simplify researchers’ experience, lower burden on the public, and make more taxpayer funded research available earlier. Federally supported life sciences preprints, posted under the federal purpose license, could be ingested automatically into PubMed (or other Federal agency designated repositories) rather than researchers having to navigate confusing publisher requirements or post their accepted papers manually.
§ 200.454 – Memberships, subscriptions, and professional activity costs
OMB proposes in 200.454 Part D to make the cost of membership in organizations whose primary purpose is lobbying or issue advocacy unallowable. The category of organizations that lobby or advocate for issues is very broad, and it includes many scientific organizations that advocate for their particular professional communities (e.g., biologists, biomedical professionals). This change will negatively impact researchers who need to engage with their professional societies to be able to effectively do their jobs. Additionally, open source infrastructure (like preprint servers) often use membership funding models to cover their costs. Any such infrastructure that is hosted by an advocacy organization (like a scientific society) would likely be unable to survive that loss of funding. We urge OMB to reconsider this change, or minimally to clarify that the rule applies narrowly to membership in political advocacy organizations.
Conclusion
As proposed, the changes in § 200.461 and § 200.454 would have a chilling effect on American researchers’ ability to engage in the scientific process. Supporting ways for researchers to communicate with each other and with the public is fundamental to maintaining a research community that stands ready to deliver research that serves the public good. By supporting and growing preprints infrastructure, and continuing to allow federal funding to be used for memberships, the federal government fosters the conditions that are needed for research to flourish.
ASAPbio (https://asapbio.org/about/) is a non-profit, researcher-led organization that advocates for timely, open, and rigorous research communication. We work to create a life sciences communication ecosystem where all research papers and other outputs are shared rapidly and without restrictions on access or reuse, and open and constructive exchanges take place on research products at all stages.
We write from the perspective of life science researchers and open science infrastructure providers (like preprint servers), our primary constituencies. Although ASAPbio objects to many aspects of the proposed rulemaking, as it would have a wholly negative impact on federally-funded research and American scientific progress, we focus our comment on two specific parts of the proposed rule: 200.461 and 200.454.
§ 200.461 – Publication and printing costs
OMB proposes to make publication costs, including article processing charges (APCs), unallowable for Federal awards, a reversal of current practice. In principle, we support efforts to spend as much federal support as possible on research costs. However, it’s critical to move away from APCs in a measured fashion, so that the ecosystem has time to adapt. If this transition is implemented too rapidly, key parts of the research communication ecosystem (such as small, non-profit or academic society publishers) will be forced out of business, leaving researchers with few options for journal-based publishing. We therefore urge a slower transition to stopping APC payments, allowing the research ecosystem time to develop alternative sustainable approaches to research communication in an orderly transition.
One alternative would be to limit the total allowable amount of spending on publishing costs while supporting alternatives to APCs. For example, there are other ways that the U.S. government can support open and rapid public dissemination of research. Preprints – author versions of scientific papers shared publicly without delay as soon as researchers are ready – are a cost effective way to achieve public access. The preprint ecosystem is already well-positioned to deliver public access at scale, and it is growing rapidly. bioRxiv, for instance, regularly adds over 4,000 new papers each month, while medRxiv adds over 1,300 per month (cumulatively publishing over 564,000 papers since their foundings in 2013 and 2019, respectively). arxiv hosts over three million papers, with monthly submissions recently topping 30,000.
Importantly, although these services make it possible to read and post papers for free, they are not free to run. Re-routing funds that would have otherwise gone to APCs to support open scholarly infrastructure like preprint servers is a smart investment that serves the public good. Furthermore, allowing preprints to serve as a method for public access policy compliance would simplify researchers’ experience, lower burden on the public, and make more taxpayer funded research available earlier. Federally supported life sciences preprints, posted under the federal purpose license, could be ingested automatically into PubMed (or other Federal agency designated repositories) rather than researchers having to navigate confusing publisher requirements or post their accepted papers manually.
§ 200.454 – Memberships, subscriptions, and professional activity costs
OMB proposes in 200.454 Part D to make the cost of membership in organizations whose primary purpose is lobbying or issue advocacy unallowable. The category of organizations that lobby or advocate for issues is very broad, and it includes many scientific organizations that advocate for their particular professional communities (e.g., biologists, biomedical professionals). This change will negatively impact researchers who need to engage with their professional societies to be able to effectively do their jobs. Additionally, open source infrastructure (like preprint servers) often use membership funding models to cover their costs. Any such infrastructure that is hosted by an advocacy organization (like a scientific society) would likely be unable to survive that loss of funding. We urge OMB to reconsider this change, or minimally to clarify that the rule applies narrowly to membership in political advocacy organizations.
Conclusion
As proposed, the changes in § 200.461 and § 200.454 would have a chilling effect on American researchers’ ability to engage in the scientific process. Supporting ways for researchers to communicate with each other and with the public is fundamental to maintaining a research community that stands ready to deliver research that serves the public good. By supporting and growing preprints infrastructure, and continuing to allow federal funding to be used for memberships, the federal government fosters the conditions that are needed for research to flourish.