NIH Public Access Comments
National Institutes of Health
Office of Extramural Research
6705 Rockledge Drive, Room 350
Bethesda, MD 20892

To Whom It May Concern:

The Heart Rhythm Society (HRS) appreciates the opportunity to submit comments on the National Institutes of Health (NIH) Draft Proposal for Enhanced Public Access to NIH Research Information. The Heart Rhythm Society is the international leader in science, education and advocacy for cardiac arrhythmia professionals and patients, and the primary information resource on heart rhythm disorders. Its mission is to improve the care of patients by promoting research, education and optimal health care policies and standards.

The National Institutes of Health (NIH) has proposed that all medical/scientific publications supported by NIH funding be freely available to the public via PubMed Central, no longer than six months after their appearance in a journal as per the Federal Register Notice. The Heart Rhythm Society welcomes the opportunity to provide input to the NIH as it considers implementing this policy. The Heart Rhythm Society also publishes Heart Rhythm, the Official Journal of the Society. The journal provides rapid online and print publication of the most important basic and clinical scientific developments devoted to arrhythmias, devices, and cardiovascular electrophysiology.

The Heart Rhythm Society recognizes the right of the federal government to mandate the public availability of biomedical research supported by taxpayer dollars within a six-month time frame, however we also recognize the right of medical publishers to protect the commercial copyright that is necessary if medical/scientific journals are to remain in the business of providing medical information to the public and to publish the results of medical and scientific research to the public.

Heart Rhythm Society Recommendations:

1) Commercial Access:
The Heart Rhythm Society supports the concept that an individual should have access to see the results of publicly funded NIH research. However, there must be safeguards to ensure the availability of a critical mass of journals to the scientific community. For example, we strongly recommend that the Journal retain commercial distribution/copyright protection from mass distribution of journal articles. Availability of information on a public site should not permit individuals or organizations to download and distribute this information for personal gain or profit.

2) Six Month Timeframe:
Although the Heart Rhythm Society supports a six-month time frame, we would not support a proposal that would mandate access before that six-month timeframe. Mandating immediacy would confront journals with several problems; for example, revenues from reprints and conceivably advertising dollars and page charges might be lost to a point where the journals could no longer be published. The Heart Rhythm Society also recommends that the NIH specify exactly when the six-month window begins and ends. The Heart Rhythm Society recommends the public gain access to journal materials six-months after a Journal publishes a ‘hard copy’ of the journal and not from six months after on-line access.

Thank you very much for your consideration. Please contact Amy Melnick, Vice President, Health Policy at amelnick@HRSonline.org or 202-327-5430 if you have any specific questions or would like to discuss this issue in greater detail.

Sincerely,

Stephen Hammill, MD
President, Heart Rhythm Society