ASM Responds to RFI on National Science Foundation Public Access Plan 2.0

Jan. 19, 2024

Attn. Martin Halbert
National Science Foundation
2415 Eisenhower Ave. 
Alexandria, Va. 22314

Dear Dr. Halbert:

The American Society for Microbiology (ASM) appreciates the opportunity to respond to the Request for Information (RFI) regarding implementation of the NSF Public Access Plan 2.0: Ensuring Open, Immediate, and Equitable Access to National Science Foundation 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. ASM has been an open access (OA) leader and advocate for many years and supports the fundamental principles of open science. 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’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. In the spirit of open science and open access, ASM has 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 (S2O) 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. 

As you consider input on this public access plan, we stand ready to work with you to ensure a thoughtful, balanced approach. We would like to share the following feedback on selected issues raised in the RFI.  

Supporting the Transition to Open Data

A pervasive challenge to open data requirements is a lack of common formats and standardization for data and metadata. Uploading data to a repository is only useful if other researchers know how to interpret and use that data. ASM supports efforts to ensure that NSF coordinates with the stakeholder community in developing trusted open data repositories, accounting for discipline-specific needs and with necessary protections for sensitive information. One example is the National Microbiome Data Collective at the Department of Energy, which champions FAIR (findable, accessible, interoperable and reusable) data standards with a focus on environmental microbiome data.

To that end, ASM appreciates NSF’s work to foster further development of broad guidelines and disciplinary-specific norms to shape communities of practice around data description and management and encourages further investments in this work across disciplines.

Identifying Potential Open Access Implementation Challenges for Researchers, Publishers and Institutions

Our community has identified a lack of clarity for authors on funder requirements as a key impediment to implementing open access policies. To best implement public access plans, information about when and how to comply with NSF’s public access policy should be clearly and repeatedly articulated to NSF funded researchers and collaborators. Examples could include regular communication between NSF program officers and grantees regarding this policy, as well as a website that provides clear information to grantees about compliance. NSF can also leverage existing partnerships with scientific societies to implement these policies. For example, NSF could hold forums at scientific meetings or host webinars with scientific societies to share information about compliance with public access policies with journal authors and editors.

ASM continues to be concerned about the unintended consequences of new 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 burden increasingly falls 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 those with limited resources and/or living in the global south. The scientific community does not want to disadvantage our colleagues in these institutions and countries by this approach. 

Finally, ASM appreciates NSF’s commitment to work with existing infrastructure and persistent identifiers (PIDs), such as DOIs. ASM encourages NSF to consider other broadly adopted PIDs, such as ORCID, and engage in stakeholder efforts around PID strategies, including the National Information Standards Organization (NISO) and the Open Research Funders Group (ORFG).

Ensuring Equity in Publication Opportunities for NSF-Supported Investigators

Continued engagement with the research community will be integral to the success of NSF’s implementation of the plan. As noted above, we encourage partnering with scientific societies like ASM to maximize their networking capabilities, in particular with historically underrepresented groups, and ensure future guidance and resources address the full breadth of stakeholders. ASM recognizes that researchers from underserved populations, including early career researchers, those from historically excluded backgrounds and those at less research-intensive institutions could be disproportionately impacted by the new public access requirements in the form of additional time, costs and increased administrative burden. 

Furthermore, specific attention to accessibility challenges associated with public access implementation is warranted. We encourage NSF to actively consult with English language learners and scientists with disabilities to ensure agency resources are inclusive of their concerns, questions and needs.

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 Strategy and Public Affairs 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.