Comment from Jeremy Wolfe

I am writing to raise a concern about section 200.461 which state “OMB is revising the section to make publication costs unallowable unless such costs are expressly required by statute or approved in advance by the Federal agency on a case-by-case basis.” This is, at best, ambiguous. NIH requires that grant-supported publications be available without embargo. This more-or-less requires publishing in open access journals. The open access journals with serious peer-review have APC costs for publication. This rule would make it harder to publish quality research in quality outlets, thus undermining gold-standard science goals. The rule does point at a serious problem. Productive labs are now faced with thousands of dollars of publication expenses each year. At present, those costs fall on the researchers. In the earlier model, the costs fell primarily on libraries who were paying high subscription costs. Clearly, there is a problem and clearly part of that problem is with the business model of publishers. However, making it impossible or very difficult to publish the results of grant-supported research is not a good answer. thank-you Jeremy M Wolfe, PhD Professor of Ophthalmology & Radiology, Harvard Medical School Visual Attention Lab Department of Surgery Brigham & Women's Hospital 900 Commonwealth Ave 3rd Floor Boston, 02215 Phone: 617-851-1166 Fax: 617-768-8816 Best email: jwolfe@bwh.harvard.edu [ ] URL: search.bwh.harvard.edu