ASM Submits Comments on Public Access to USDA Research

Nov. 13, 2023

Dr. Simon Y. Liu
Administrator, Agricultural Research Service
1400 Independence Ave
Washington, D.C. 20250

Written Stakeholder Comment: Increasing Public Access to the Results of USDA-funded Research (Docket: NAL-2023-0001-0001)

Dear Dr. Liu,

The American Society for Microbiology (ASM) appreciates the opportunity to respond to the USDA on the agency’s plan to enhance public access to results of USDA-funded research. As one of the oldest and largest life science societies with more than 36,000 members in the United States and around the globe, our mission is to promote and advance the microbial sciences. Many ASM members’ projects are supported by USDA research programs, including the Agriculture and Food Research Initiative and Agricultural Research Service. ASM has a long-standing commitment to equity in science and recognizes that making research more widely accessible is a step in that direction. ASM has been an open access (OA) leader and advocate for many years and supports the fundamental principles of open science.  

ASM’s 15 peer-reviewed journals are fundamental to ASM’s mission and provide a critical service not only to our members, but also to the advancement of the microbial sciences globally. As you consider input on this public access plan, we stand ready to work with you to ensure a thoughtful, balanced approach. In the spirit of open science and open access, we have embarked on a journey to transform our publication business model to allow this important transition to happen. In July 2023, ASM announced that it will shift its 6 subscription journal titles to a Subscribe to Open publishing model by the 2025 subscription year, which complies with the White House Office of Science and Technology Policy Memorandum on Ensuring Free, Immediate and Equitable Access to Federally Funded Research.

ASM appreciates the USDA’s commitment to engaging with publishers and USDA-funded researchers while developing and implementing public access policies. ASM is ready to work with you to facilitate stakeholder engagement on this topic, and we provide input on some of your specific questions below: 

How can USDA best implement its plans to improve public access to USDA-funded research results?

To best implement public access plans, information about when and how to comply with the USDA’s public access policy should be clearly and repeatedly articulated to USDA extramural researchers and collaborators. Examples could include regular communication between USDA program officers and grantees regarding this policy, as well as a website that provides clear information to grantees about compliance.

The USDA can also leverage existing partnerships with scientific societies to implement these policies. For example, the USDA could hold forums at scientific societies meetings or host online forums with scientific societies to share information about compliance with public access policies with journal authors and editors.

How can USDA ensure equity in publication opportunities?

ASM commends the USDA for its commitment to equity and its work to achieve equitable access to publishing and to research in setting forth this plan. ASM continues to be concerned about the unintended consequences of enacting federal policies that might shift costs to researchers, or otherwise result in significant additional costs related to publication, repositories, data management and staffing. There remains a cost to publishing good science. Peer reviewers are not paid, and maintaining the peer review system, which is integral to upholding scientific integrity and rigor, demands human time and adoption of innovative technologies. These standards and the integrity and rigor they uphold in science should not be compromised in the pursuit of public access.

As the costs of publishing increase, the costs are increasingly falling on individual researchers and institutions. We believe that if researchers are forced to make up for lost subscription revenue, a new kind of inequity will result. For example, author processing charges (APCs), which have evolved as an open access alternative revenue model to page charges and library subscriptions, have become increasingly expensive and created financial barriers for researchers from underserved populations, including early career researchers, those from historically excluded backgrounds, those at less research-intensive institutions and with limited resources and those living in the global south. We know that the scientific community does not want to disadvantage our colleagues in these institutions and countries by this approach. 

It is critical that USDA policies support alternatives means for funding public access. We urge you to work with Congress and the research community to identify appropriate financial support to address these unequal additional burdens in future spending bills and through other strategies. Investing in infrastructure and services that are directly aligned with the research mission will be critical to laying the foundation for a more open and equitable system. We are pleased to see the USDA’s commitment to convening the community throughout the process to work through these challenges and share ideas, and we look forward to participating in these discussions.

How can USDA monitor impacts on communities impacted by its public access policies?

We thank the USDA and the White House Office of Science and Technology Policy for taking the approach of establishing a public access policy and not a publishing policy. When it comes to scientific publishing, one size does not fit all, and it is imperative that federal policies respect the business of publishing and allow for each organization to take an approach that works for its members and customers.

ASM has committed to implementing a novel publication business model called “Subscribe to Open,” starting in 2025. In this model, ASM will open content if a sufficient number of current journal subscribers continue their subscriptions. This model is more equitable than traditional open access models because it does not shift all of the costs of publishing to authors. We envision this model will include incentives for our customers to invest in ASM as a publisher and a partner in curating and disseminating science in accordance with open access policies.

While the USDA implementation plan does not mention monitoring costs associated with complying with public access, ASM encourages the USDA to evaluate the overall costs of public access polices while monitoring costs. For example, ASM is concerned that the shift from a subscription model to an article processing charge model could result in a system that favors quantity over quality. There should remain bright lines between public access policies and publisher business models.


The American Society for Microbiology thanks the USDA for the opportunity to provide input on this important issue, and we encourage you to continue to engage stakeholders as you move work to implement open access policies. Through open communication and by working together, ASM is confident that we can move boldly toward a world of open science, while also preserving the critical organizational infrastructure, including the financial health of nonprofit scientific societies, that has been foundational to publishing research in this country. 

ASM and its members look forward to continuing to work with you through the implementation process. For more information, please contact Allen Segal, ASM Chief Advocacy Officer, at

Stefano Bertuzzi, Ph.D.
ASM Chief Executive Officer

Author: ASM Advocacy

ASM Advocacy
ASM Advocacy is making it easy and providing opportunities for members to advocate for evidence-based scientific policy.