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Access to Government Information

MLA Comments to Dr. Zerhouni on NIH Draft Policy,
Enhanced Public Access to NIH Research Information


October 12, 2004

The Honorable Elias Zerhouni
Director
National Institutes of Health
9000 Rockville Pike
Bethesda, MD 20892

Dear Dr. Zerhouni:

Thank you for giving us an opportunity to comment on the NIH draft policy, Enhanced Public Access to NIH Research Information. We are submitting these comments on behalf of the Medical Library Association (MLA). The Medical Library Association (MLA), a nonprofit, educational organization, is a leading advocate for health sciences information professionals with more than 4,700 members worldwide. Through its programs and services, MLA provides lifelong educational opportunities, supports a knowledge base of health information research, and works with a global network of partners to promote the importance of quality information for improved health to the health care community and the public.

Comments on the NIH Public Access Policy

The Medical Library Association strongly supports the NIH proposal to provide freely available online access to NIH-funded manuscripts via PubMed Central not later than six months after publication in a peer-reviewed journal. MLA has moved to an open access model for its own journal, Journal of the Medical Library Association (JMLA), so that while we understand the economic concerns of publishers, we have decided to support more open and immediate access and try to cover the loss of revenue in other ways. We believe that the public has a right to information resulting from research funded by their tax dollars. The proposed initiative will vastly expand and improve public access to much needed medical literature. Timely access to the results of NIH-funded research is critical to maintaining the vitality of our Nation's investment in research and education, and also is critically important to taxpayers seeking needed information.

An average of 500 million Internet searches are performed annually on NLM's MEDLINE database, which provides access to the world's most up-to-date health care information. MEDLINEplus, NLM's extensive electronic information resource for the general public, is viewed approximately 200 million times a year. This activity dwarfs previous usage of NLM's bibliographic services, whether electronic or print. Such usage demonstrates the need that currently exists and indicates that access by health professionals and the public will continue to grow in the future. Today, optimum health requires a partnership between a knowledgeable physician and an informed patient.

We believe that the NIH proposal balances the public interest in having enhanced access to federally-funded NIH research while allowing publishers sufficient market protections and time to implement new economic publishing models. In addition, this initiative is consonant with the market models that many publishers have adopted that place short-term embargoes on access to scientific literature. Further, MLA supports the efforts of several journals that provide authors with the opportunity to publish their articles online immediately, rather than waiting six months. For this reason, we support the recommendation of the Council of the National Academy of Sciences that NIH would enable authors to take advantage of this option by authorizing the use of grant funds for this service.

An informal study of 2003 MEDLINE citations to find NIH funding support found that less than 11 percent of the articles published in scientific journals would be impacted by the NIH proposal. Another study reports that the 60,000 plus articles published each year as a result of NIH funding reflect only one third of all published biomedical literature. It is highly unlikely that libraries will cancel journal subscriptions as a result of the NIH proposal, since health professionals need access to all current information as soon as it is published and not just a relatively small percentage of it. In fact, the Council of the National Academy of Sciences pointed out that a good number of leading journals already follow the practice of making their articles available on PubMed Central six months after publications so the NIH proposal is hardly a radical one.

MLA believes it is critical to preserve the processes of peer review, editing and scientific quality control in the publication of journal articles because of the crucial role that scientific and medical research play in the delivery of healthcare. We further support the importance of maintaining only one final version of the manuscript for publication, for deposit in the PubMed Central repository, and for permanent archival access. MLA believes it is imperative that the NIH call for the archiving of all the literature in perpetuity. Research lays the foundation for future scientific discovery and information contained in earlier studies is often critical as demonstrated by the John's Hopkins incident involving the death of a research subject.

We support the intention of the NIH to continue its dialogue with publishers, investigators, and representatives from scientific associations and the public to ensure the success of this initiative. We are pleased to submit these comments and express our interest in continuing to dialogue and work with all the stakeholders in this initiative.

Sincerely,

Joanne Gard Marshall, AHIP, FMLA
MLA President

Carla J. Funk, CAE
MLA Executive Director

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