Science Policy News ASPET Provides Comments to NIH Open

Access Plan

ASPET submitted comments to the National Institutes of Health (NIH) on its Plan to Enhance Public Access to the Results of NIH-Supported Research (Plan). The Plan outlines how NIH will be implementing the Office of Science and Technology Policy’s (OSTP) open access plan which was released in August 2022. The OSTP provided guidance for agencies to update their public access policies as soon as possible to make publications and research funded by taxpayers publicly accessible, without an embargo or cost. All agencies will fully implement updated policies, including ending the optional 12-month embargo, no later than December 31, 2025.

ASPET is generally supportive of the Plan; however, as noted in its comments has concerns about the implementation of the open access plan and its effects on scholarly publications. ASPET encouraged NIH to include supplemental information covering all allowable paths for charging publishing costs, including from indirect costs and other university general or restricted funds. ASPET also encouraged NIH to include in this guidance coverage for all costs, such as open access fees, page charges, and submission fees among other costs. ASPET encourages NIH to permit CC BY-NC license options that allow for the free reuse of content by the public (in line with the goals of NIH) but not for commercial purposes.

ASPET recommended that NIH not monitor publication fees, which could lead to a system that favors quantity over quality. Any “one-size fits all” pricing structure which is the logical result of this type of monitoring does not enhance the publication’s quality; it just streamlines the bookkeeping. Ultimately, NIH should allow the marketplace and competition between publishers to determine the reasonable publication costs.

ASPET commended NIH for engaging to improve the plan for public access and to develop a policy that allows researchers to comply more readily.

ASPET Responds to NIH Requests for Information

ASPET spent the spring responding to several requests for information (RFI) from NIH that would improve research grant applications and the postdoc training experience.

Proposed Simplified Review Framework for NIH Research Project Grant Applications

In the RFI, Proposed Simplified Review Framework for NIH Research Project Grant Applications, NIH proposed streamlining the factors for reviewers for NIH grant applications into three main areas: Importance of the Research, Rigor and Flexibility, and Expertise and Resources.

ASPET commended NIH on its proposal and goal to reduce implicit bias and minimize workload within the grant review process. While maintaining the necessary rigor that NIH holds its grantees to, the transition from nine areas of review to three main areas with additional areas shows a willingness to streamline the review process.

ASPET highlighted that any change to the grant application, review, and award process will take time to become commonplace. During this time of change, ASPET strongly encouraged NIH to work with its stakeholders to prepare the community for this change. NIH is encouraged to provide detailed timelines for not only alerting the community of the change, but also when the change is going to occur. NIH should work with stakeholders on educational materials to train all members of the grant application process so that when the changes are implemented, there is little to no disruption.

Re-envisioning of U.S. Postdoc Training within Biomedical Research Enterprise

In the RFI, Re-envisioning of U.S. Postdoc Training within Biomedical Research Enterprise, the NIH sought information regarding the current state of postdoctoral research training and career progression within the biomedical research enterprise. NIH is particularly interested in understanding the perspective and experience of recent and current postdoctoral trainees, postdoctoral office leaders, as well as graduate students considering becoming postdoctoral trainees within the academic sector.

ASPET shared its belief that an academic postdoc position should be an established and temporary period that has defined goals for the advancement and enhancement of professional skills needed to pursue his or her chosen path whether it is in academia, industry, government, or another area.

ASPET highlighted that the current system needs close oversight that will assist in mitigating some of the concerns outlined below. Along with oversight, better surveying on the following areas will allow NIH to observe trends and take proactive measures before any pertaining issues escalate. Inequities in postdoc pay create significant financial barriers that can lead to physical and mental health difficulties. Currently, accurate guidance on how postdocs can be paid is lacking from the NIH, which enables institutions to treat postdocs not as employees but independent contractors depriving them of standardized pay, benefits, and employment protection. This creates a barrier, such that only those that have the means to become a postdoc without suffering financial hardships pursue that career path.

ASPET shared that without clear guidance from the NIH on standardized benefits for postdocs, inequities in benefits have emerged within institutions and across institutions that create discrepancies in terms of quality of life. To sustain and enhance quality of life, more and more early career scientists are looking at careers outside of academia for a healthier work/life balance and a better paycheck that they believe they deserve.

ASPET commented that the treatment as a “trainee” is degrading and disingenuous as much of the workforce looks at new PhDs as top candidates and employees and far from a “trainee.” These issues in a work environment manifest as prolonged work hours impacting work/life balance, strained menteementor relationships, with bullying and harassment that can deter and drive postdocs to careers outside of academia. New PhDs would need to be recognized for their professional strengths and skills, rewarded with competitive salaries, enabling work/life balance.