National Institutes of Health Public Access Policy and the University of Michigan Libraries' Role in Assisting with Depositing to PubMed Central
Rosenzweig, Merle, Schnitzer, Anna Ercoli, Song, Jean, Martin, Scott, Ottaviani, Jim, Journal of the Medical Library Association
On April 7, 2008, the National Institutes of Health (NIH) instituted the NIH public access policy implementing division G, title II, section 218 of Public Law 110-161 (Consolidated Appropriations Act, 2008) and affecting all peer-reviewed research funded through its grants [I]. Researchers receiving such funding are required to place "an electronic version of their final peer-reviewed manuscripts upon acceptance for publication, to be made publicly available no later than 12 months after the official date of publication" into "the digital archive PubMed Central," thus making them freely available .
IMPACT OF THE POLICY ON THE UNIVERSITY OF MICHIGAN RESEARCH COMMUNITY
The policy had numerous implications for the NIH grant process. Some of the specific details of the new NIH grant application guidelines are laid out in the following notification:
Information that May Be Included in the Application
Published manuscripts and /or abstracts that are publicly available in a free, online format may be referenced in the application. These publications may not be included in the appendix. [Uniform resourse locators (URLs)] or NIH PubMed Central (PMC) submission identification numbers may be included along with the full reference in the Bibliography and References Cited section (SF 424RR)/Literature Cited (PHS 398) section, the Progress Report Publication List section and/or the Biographical Sketch section. While there is no limit to the number of URLs or PMC submission identification numbers that can be cited, applicants should be both judicious and concise. 
In addition, new instructions relating to the NIH Biosketch, which is a mandatory biography required for all key personnel listed on an NIH grant proposal, raised many questions. The NIH Biosketch instructions call for a selected bibliography of peerreviewed journal articles with PubMed Central submission identification numbers (PMCIDs) attached to relevant citations. A problem with complying is evident in an email sent by a new faculty member to the UM Libraries: "Transfer of my two NIH grants from my previous institution to UM is being held up by my Biosketch lacking appropriate PMCID numbers."
Progress reports that researchers are required to submit to NIH on an annual basis are also impacted by the policy. The message from the NIH Group explains:
To be in compliance the publications shown in your Progress Reports (eSNAP or paper submission) must provide the PMCID after each paper listed. Please note that the PMCID (the PubMed Central reference number, with a "PMC" prefix) is not the same as the PMID (the PubMed number). If the paper has been published more than three months ago, only a PMCID can be used as evidence of compliance with the Policy. To obtain a PMCID, please review the submission instructions at http://publicaccess .nih.gov/submit^process.htm. If the paper does not fall under the Policy, please provide a brief explanation of why the manuscript is not covered by the Policy. Compliance with the NIH Public Access Policy is a legal requirement and a term and condition of all NIH awards. NIH awardees are responsible for ensuring that all steps of the [NIH Manuscript Submission (NIHMS) system] process are complete within three months of publication, and that evidence of compliance is included in all NIH applications, proposals and reports.
In addition to the individual researchers who receive funding from NIH, institutional training grants must also comply. For example, a principal investigator of one of the UM's training grants received this message:
NIH Grant 5T32########
Some citations listed in your recent progress report do not appear to be in compliance with the NIH Public Access Policy, and need to be addressed. Peer-reviewed manuscripts accepted after April 7, 2008 that are listed on pages 24,26,29,33,38....
SUPPORTING UNIVERSITY OF MICHIGAN RESEARCHERS IN COMPLYING WITH THE POLICY
Members of the UM research community were not clear as to exactly what the policy was, what its implications for their publishing efforts were, and what they were required to do to comply with it. …