This document is a formal response from the Council on Governmental Relations (COGR), representing over 200 U.S. research universities and affiliated institutions, to the National Institutes of Health’s Request for Information regarding its plan to enhance public access to the results of NIH-supported research. COGR expresses support for the OSTP directive that increases access to federally funded research results but raises several critical considerations to ensure equitable implementation. First, COGR highlights the financial challenges posed by the transition to open access publishing, particularly due to the shift toward Article Processing Charges (APCs), which could disproportionately disadvantage early-career researchers and those at less-resourced institutions. The organization urges NIH to provide clear guidance and potentially supplemental funding to address these increased costs, emphasizing the need to revisit current modular budget caps that inadequately reflect today’s research expenses, including costs of data management and publishing.
Additionally, COGR addresses administrative burdens relating to multiple repository deposit requirements and advocates for a centralized federal repository to minimize compliance complications and costs. The letter welcomes NIH’s efforts to enhance publication accessibility, particularly through machine-readable formats, and encourages the development of processes that facilitate broader access for individuals relying on assistive technologies. Monitoring the evolving cost landscape and its differential impacts on the research community is deemed essential, and COGR recommends NIH assess and develop equitable funding models while remaining vigilant against unintended deterrents to scholarly publishing. Further, COGR calls for harmonization of public access policies across federal agencies to streamline compliance and foster equity, suggesting systems like the PASS System at Johns Hopkins as potential models. The response concludes with a call for continued engagement and dialogue to ensure that public access policies maximize both the impact and equitable dissemination of NIH-funded research.
