APS Comment ltr 11-16-04

The American Physiological Society 9650 Rockville Pike Bethesda, MD 20814-3991 November 16, 2004 NIH Public Access Comments National Institutes of Health Transmitted via email to PublicAccess@nih.gov RE: NIH Notice on Enhanced Public Access to NIH Research Information NOT-OD-04-64 (September 3, 2004) Notice for Comment, 69 Fed. Reg. 56074 (September 17, 2004) To the National Institutes of Health: These comments are submitted on behalf of the American Physiological Society (APS). In addition to its views on the policy implications of the NIH proposal, the APS is submitting a legal analysis jointly commissioned by the APS and the American Association of Immunologists (AAI). This legal analysis may be found as Attachment A and is incorporated by reference herein. The APS also wishes to associate itself with the comments offered by the AAI. Summary of recommendations The APS supports the principle of public access to science but believes that the NIH plan is not the right approach. This proposal will do little to enhance public access to biomedical research while causing disproportionate harm to not-for-profit societies that publish high-quality journals containing a significant amount of NIH-funded research. This includes many publishers who already provide some form of free public access. The APS believes that a better approach would be to enhance the existing MedLine/PubMed web site so that it is possible to search the full text ...