Thursday, March 28, 2013

NIH Public Access Policy Changes: Compliance


CHANGES TO PUBLIC ACCESS POLICY COMPLIANCE EFFORTS

All NIH Awards with Anticipated Start Dates on or after 1 July 2013

Reasons for Change

To facilitate better public access reporting:
using electronic RPPRs
using paper-based progress reports (PHS 2590)

How?
by improving grantee compliance
by improving workflow and communication between PD/PIs & non-PD/PI authors using My NCBI – e.g. by tracking compliance of papers arising from their awards (even if they do not author those papers)

NIH expects the provision of this advance notice provides institutions and PD/PIs sufficient time to ensure all their NIH-supported papers are posted to PubMed Central as required

NIH advises PD/PIs to use their "My NCBI" account to track compliance for their publications now, and to ensure all publications arising from their awards are posted to PubMed Central

New Requirements
There are TWO points to consider relating to submissions for non-competing continuation grant awards. These points come into effect for all applications on or after July 1, 2013:
1) NIH awards will not be processed until recipients have demonstrated that arising publications are in compliance with NIH public access policy
2) Investigators need to use My NCBI to enter papers onto their progress reports. Papers can be linked using by the following methods:
(a) electronically using Research Performance Progress Reports (RPPRs); or
(b) by inclusion in the PHS 2590 application using a My NCBI-generated PDF report
How to Comply
(a) Electronic ‘Research Performance Progress Reports’ (RPPRs)
The RPPR requires grantees to:
1) Report all publications using a Commons-linked My NCBI account
2) When using the account, the RPPR ‘Publications’ section (C.1) is pre-populated with the PD/PI’s publications from My NCBI. The PD/PI simply ticks the box next to each relevant publication to associate it with the progress report
Non-compliance
3) Submitting an RPPR with a non-compliant publication will generate an automated email notifying the grantee that the progress report includes citations that do not comply with NIH public access policy
4) The automated email will request a response by a specified due date two weeks prior to the next budget start date
5) Awards will be delayed until a reply to the e-notification is received from the grantee with evidence of compliance or a satisfactory explanation (e.g. the sole author has passed away before they were able to process the manuscript for posting to PubMed Central)
6) Grantees can respond to this e-notification via the Progress Report Additional Materials (PRAM) link or by email
7) The PRAM link provides a ‘text box’ in which the grantee can respond through the eRA Commons. Grantees can view all PRAM submissions in the grant folder
8) Grantees responding via email must write to both the Grants Management Specialist and the Program Officer

(b) Paper Progress Reports (PHS 2590)
1) All grantees submitting paper PHS 2590 progress reports will be required to provide an additional My NCBI-generated PDF list of publications
2) These PDF reports are required from July 1, 2013. (Grantees have been able to submit them voluntarily since December 2012)
3) These new My NCBI PDF reports will carry out the following function: as ‘Section 2.2.6, Section E, Publications’ of the PHS 2590
4) By clearly indicating the applicability of the public access policy and compliance status of each reported paper, these PDF reports will: standardize reporting of publications to NIH; facilitate grantee reporting by providing a computer-generated publication list; and enhance compliance
Non-compliance
5) If a publication is not compliant with the public access policy, NIH staff will email the PD/PI and business official to inform them that the award will be delayed until a reply to the email is received with evidence of compliance or a satisfactory explanation

Reminders RE: Completeness & Accuracy
1) PD/PIs submitting an application/proposal/report to the NIH are required to include the PMC reference number (PMCID) or appropriate substitute every time a paper that falls under the public access policy is cited that they authored or that arose from their NIH-funded research
Listing one of these publications anywhere in a progress report without an appropriate identifier is not consistent with the requirements of the public access policy. Using My NCBI to report publications guarantees that the correct identifier is reported accurately, and the public access compliance status is clearly conveyed
2) Grantees are reminded to only report publications in the relevant section of the progress report (Section C.1 of the RPPR and Section 2.2.6 Section E of the PHS 2590). Publications listed in other sections of the report will not be recorded as productivity arising from the award in NIH systems (e.g. RePORT)
3) Grantees must report all publications arising from their award during the reporting period, regardless of the public access status of the publication

USEFUL LINKS
My NCBI: http://publicaccess.nih.gov/communications.htm 
My NCBI-generated PDF Reports for PHS 2590: http://www.nlm.nih.gov/pubs/techbull/nd12/nd12_myncbi_pdf.html