January 2024

On January 19, AERA submitted comments in response to the Request for Information (RFI) from the National Science Foundation (NSF) on the agency’s Public Access Plan 2.0.

NSF released the plan in June 2023 as a step in implementing the 2022 White House Office of Science and Technology Policy (OSTP) memorandum “Ensuring Free, Immediate, and Equitable Access to Federally Funded Research.” In implementing the OSTP memo, the plan provides guidance for NSF grantees in the future to make available upon release their publications and related data supported by NSF-funded research. The current requirement is that NSF grantees with grants funded after January 1, 2025, must make these products available within one year after publication.

In its RFI, NSF sought (a) input on the benefits and challenges that organizations and individual researchers may see in making NSF-funded peer-reviewed publications and the underlying data publicly available, (b) input on how NSF can engage with communities regarding public access issues, and (c) additional comments about Public Access Plan 2.0.

In the comments, AERA Executive Director Felice J. Levine noted the importance of public access to NSF-funded peer-reviewed publications and their underlying data. Levine highlighted several next steps that NSF can take to further implementation of Public Access Plan 2.0:

• Clarify the types of publications subject to NSF’s public access policy.
• Work with the scientific community to communicate expectations for NSF grantees trying to comply with the updated public access plan requirements, including through webinars.
• Provide NSF grantees with guidance on ways to adhere to the public access plan, including examples of repositories for data archiving, the use of persistent unique identifiers to identify publications and data sets, and best practices for sharing data involving human subjects under appropriate protections of privacy and confidentiality.
• Provide NSF peer reviewers guidance on the inclusion and examination of costs for publication and data archiving in NSF grant applications.
• In NSF's leadership role, promote the value of data sharing and access to publications through direct support for these activities; reimagine its own evaluation criteria for funding; and signal to higher education institutions to similarly value such practices in hiring, promotion, and tenure.

AERA has long been involved in issues related to public access to research and data from federally funded research:

• May 2020: AERA submitted comments in response to an OSTP request for information on “Public Access to Peer-Reviewed Scholarly Publications, Data and Code Resulting From Federally Funded Research.”
• December 2019: AERA joined a coalition of 60 scientific organizations on a letter urging stakeholder involvement in response to potential changes to the federal government's open access policy.
• May 2013: AERA released a “Statement on Public Access to Federally Supported R&D Publications.”
• January 2012: AERA responded to an OSTP Request for Information: “Public Access to Peer‐Reviewed Scholarly Publications Resulting from Federally Funded Research.”
• January 2012: AERA responded to OSTP Request for Information: “Public Access to Digital Data Resulting from Federally Funded Scientific Research.”

AERA will continue to engage with NSF and the broader scientific community as the agency continues to develop its guidance.