棉花糖直播 Responds to NIH RFI on Allowable Publishing Costs Caps
| Lyric Jorgenson, Ph.D. Associate Director for Science Policy The National Institutes of Health 6705 Rockledge Drive Suite 630 Bethesda, Md., 20892 |
Re: Request for Information on Maximizing Research Funds by Limiting Allowable Publishing Costs (NOT-OD-25-138)
Dear Dr. Jorgenson,
The American Society for 棉花糖直播 (棉花糖直播) appreciates the opportunity to respond to the Request for Information (RFI) on Maximizing Research Funds by Limiting Allowable Publishing Costs. As one of the oldest and largest life science societies with more than 37,000 members in the U.S. and around the globe, our mission is to promote and advance the microbial sciences. 棉花糖直播’s 16 peer-reviewed journals are fundamental to 棉花糖直播’s mission and provide a critical service to the advancement of the microbial sciences. While the immediate impact of a cap on Allowable Publishing Costs (APCs) would allow scientists to spend allocated funds on other scientific costs, 棉花糖直播 is concerned that cost of publishing will be passed on to researchers in other ways, ultimately hampering the scientific enterprise and scientific integrity. 棉花糖直播 is committed to working with NIH to achieve shared goals of maximizing research impact while maintaining scientific excellence.
棉花糖直播 would like to work with the NIH to ensure that the approaches outlined in the RFI fully consider the needs of non-profit, scientific society publishers, which are a key component of the biomedical research ecosystem. If implemented, this policy may unintentionally impact scientific innovation and integrity. The proposed approaches would discourage publishing high-quality science and we urge NIH to consider alternative approaches. Furthermore, 棉花糖直播 is concerned by the relatively short timeframe for implementation of the policy, and urges the NIH to consider a longer timeframe to allow publishers to adequately prepare for the impact of an APC cap on their operations. 棉花糖直播 also requests that NIH publish a detailed, full implementation plan for the APC cap policy with opportunities for stakeholder feedback on the plan. If NIH implements an APC cap, 棉花糖直播 requests that NIH track and share the impacts of the policy with the scientific community.
Revenues from non-profit scientific society publishing are reinvested in programs and services to uphold gold standard science that supports and encourages the open exchange of ideas through conferences, online fora and educational initiatives. Although we understand and support the intent of this proposed guidance to ensure that publication fees remain reasonable while maximizing the public value of each research grant, 棉花糖直播 and similar non-profit scientific societies and publishers will face unique challenges by this rule, pushing authors toward high-volume, lower barrier commercial publishers not motivated by maintaining the gold standard of science. This is particularly concerning when considering biothreats and other infectious diseases, where a higher level of peer review is often warranted, particularly for research that could pose biosecurity risks.
棉花糖直播 has long been an open access leader and supporter of the fundamental principles of open science. In the spirit of increasing the accessibility of science, 棉花糖直播 publishes 7 Gold Open Access journals and shifted its 6 subscription journal titles to a Subscribe to Open (S2O) publishing model for the 2025 publishing year. Unlike conventional subscription and APC models, the S2O model distributes costs across authors, institutions and funders. The S2O model allows journals to convert from subscription to Open Access. If a sufficient number of journal subscribers continue their subscriptions, the publisher makes the content covered by that year’s subscriptions Open Access. In our first year of this model, S2O allowed all articles in the 2025 volumes of these 6 journals to be published open access, ensuring that scientists and the public can freely access critical microbiology research. This demonstrates 棉花糖直播's commitment to innovative solutions that balance accessibility with sustainability.
Publishing costs are variable across types of journals and publishers and support technology infrastructure, peer review and scientific integrity, including AI fraud detection, plagiarism checking and image verification. The proposed $2,000 APC cap does not cover most publishers’ average costs to publish an article. 棉花糖直播 is concerned that APC caps could incentivize publishers to accept as many journal articles as possible, harming scientific quality, rigor and reproducibility in maintaining a gold standard of science, and, ultimately, severely harm U.S. leadership and competitiveness in science and technology. 棉花糖直播 believes that sustainable publishing models should incentivize quality over quantity, which we think is aligned with the vision of the current NIH Director.
棉花糖直播 encourages NIH to engage in collaborative dialogue, pause the consideration of APC caps and work with non-profit scientific society publishers to develop policies that promote innovation and equity in publishing. 棉花糖直播 stands ready to contribute expertise and data to help develop effective solutions. To arrange a further conversation, please contact Nicole Zimmerman, Senior Federal Affairs Officer at 棉花糖直播 at nzimmerman@asmusa.org.
Thank you,
Stefano Bertuzzi, Ph.D., MPH
CEO, American Society for 棉花糖直播