In case you missed this important piece of news from NIH, here it is again: starting this spring or thereabouts, investigators who don't comply with the public access policy in progress reports could experience a delay in their noncompeting awards.
There's more to the announcement—see the November 16, 2012, Guide notice—but read on here for additional information and advice on how to avoid public access problems with your progress report so you don't run into any delays.
Compliance: the Big Picture
Under the public access policy, you must submit to PubMed Central (PMC) final peer-reviewed journal manuscripts that arise from NIH funds upon acceptance for publication.
In your progress report, you have to demonstrate compliance with the policy for all applicable papers (see Determine Applicability) by including a PubMed Central identification number (PMCID) or other identifier at the end of full citations.
You can create citations manually using the following process, but we suggest generating citations with My NCBI, a feature we talk about in a section below.
Note: submission methods refer to four ways you can submit papers to PMC. See NIH's Submission Methods.
- For published papers, include the PMCID at the end of full citations.
- For papers in press in Submission Method A or B journals, indicate “PMC Journal - In Process."
- For papers in press in Submission Method C or D journals, provide the NIH Manuscript Submission reference number (e.g., NIHMSID97531) at the end of the citation.
For more information on this, go to Include PMCID in Citations on the NIH Public Access site.
Think About Compliance Early On
We encourage you to ensure compliance well before your annual reports are due. That means 1) ensuring all publications arising from your awards are posted to PubMed Central and 2) using your My NCBI account to track compliance for publications.
Posting to PMC
Starting as early as when you plan to submit papers for publication, think about how they will reach PubMed Central. At that point, consider the following:
- How will your paper be submitted to PMC?
- What version of the paper, e.g., final published article, final peer-reviewed manuscript, will be made available on PMC?
- Who will submit the paper?
- When will it be submitted?
- Who will approve the submission?
- When can the paper be made public on PMC?
Find additional details at NIH's Submission Methods.
Familiarizing yourself with My NCBI
Whether you use the Research Performance Progress Report (RPPR) or paper PHS 2590 progress report, you'll have to use My NCBI. Start using this feature now to avoid delays in progress report submissions.
My NCBI is an easy way to track compliance and identifiers as well as ensure your citations are in the correct format. It can also help you save time.
When authors link a paper to your grant in My NCBI, it will show up as a suggestion in your My NCBI account to help you track and report the paper. This can be particularly helpful when you do not author all papers arising from your award. It also helps you monitor whether a paper was wrongly affiliated with your award, so the error can be corrected in a timely manner. You can also delegate My NCBI tasks.
For paper progress reports, NIH recently introduced a My NCBI feature that generates a PDF report of publications; see the January 10, 2013, Guide notice. As it states there, the PDF report will be mandatory later this year, so you may want to check out the new feature sooner rather than later. Since paper progress reports are often used for complex applications where there are numerous papers, start ensuring papers are in My NCBI now.
To acquaint yourself with My NCBI, see My NCBI and My Bibliography Training Materials on the Training/Communications page of NIH's Public Access site. And learn about My NCBI's role in Managing Compliance to the NIH Public Access Policy. For additional information on reporting publications in the RPPR, see Frequently Asked Questions.
Answers to Your Compliance Questions
You may find the Q&As below helpful. For others, see our Copyright and Publication for Grantees questions and answers and NIH's Frequently Asked Questions About the NIH Public Access Policy.
Can I include manuscripts submitted for publication in my progress report?
No, not in the publications section. The publications section should include only manuscripts accepted for publication or published that directly arise from the award.
Can I include manuscripts accepted for publication in my progress report?
Yes, provided that they are directly supported by the award. If you use My NCBI to complete an RPPR or to generate the publication section of your PHS 2590, you do not need to worry about public access citation formats; My NCBI will format citations for you.
If you want to report publications manually, follow the guidance at Include PMCID in Citations on NIH's Public Access site.
Is a PubMed identifier (PMID) the same as a PCMID?
No. The PMCID links to full-text papers in PubMed Central (an index of full-text papers), while the PMID links to abstracts in PubMed (an index of abstracts). PMIDs have nothing to do with the NIH public access policy.
How do I know which submission method my journal uses?
You can enter the journal's name in the box "How do I submit my paper to PMC?" that's on the right side of the NIH Public Accesssite. However, this tool provides only general details and, for example, does not ensure that a publisher will post the version you want upon acceptance for publication.
Remember that what authors are allowed to do and what the publisher will do are specified in the publication agreement between the authors and publisher. We encourage you to understand how a publication agreement will affect how you comply with the public access policy before you sign it.
Is there a way that staff in my institution's office of sponsored research can track compliance of publications?
Yes. They can use the new Public Access Compliance Monitor, which NIH unveiled last month. See the January 9, 2013, Guide notice.
If I have a paper that is out of compliance, why don’t I just leave it off my progress report?
You would be noncompliant with the terms and conditions of award and putting you and your institution at risk. Both the RPPR and PHS 2590 include statements that describe the consequences of not completely and accurately reporting information.
From the PHS 2590:
I certify that the statements herein are true, complete and accurate to the best of my knowledge, and accept the obligation to comply with Public Health Service terms and conditions if a grant is awarded as a result of this application. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties.
The RPPR includes similar language:
… Deliberate withholding, falsification, or misrepresentation of information could result in administrative actions such as withdrawal of a progress report, suspension and/or termination of an award, debarment of individuals, as well as possible criminal penalties. The grantee institution may be liable for the reimbursement of funds associated with any inappropriate or fraudulent conduct of the project activity.
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