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AAMC Comments on Expanding Public Access to Research Data and Findings

May 31, 2013—The AAMC May 20 submitted to the White House Office of Science and Technology Policy (OSTP) comments  on federal proposals to expand access to findings and data from publicly funded research.   In its letter, the AAMC encourages agencies to seek ways to expand such access, but notes that any release must also take into consideration quality and reliability of data, and contextual or other information needed to help the public in using or soundly interpreting data and findings. 

The letter was submitted following a meeting at the National Research Council commissioned by federal scientific research agencies to discuss the best ways to increase public access to findings from publicly funded science. 

These agencies are responding to a Feb. 22 memorandum from OSTP Director John Holdren, Ph.D., that outlines federal goals that would require all science agencies to provide access to published research findings [see Washington Highlights, March 1]. The goals in the memorandum are similar to what is already provided by National Institutes of Health (NIH) Public Access program, a database of author manuscripts posted up to one year after their publication in the peer-reviewed literature.  The goals also include providing access to data from federally sponsored research.

In its comment letter, the AAMC generally endorsed such goals, mindful of the additional responsibilities for protecting the public’s health and welfare. The letter notes, “As an organization dedicated to improving the health of all, the AAMC also acknowledges the paramount importance of providing complete and precise information to the public on issues pertaining to medicine and health.”  The letter continues that “The quality of data is as important as quantity.  Ideally, contextual and other information is provided to help the public guide and interpret health findings.”

The AAMC letter describes that while the NIH already provides a well-tested model for public access to publications, new systems for providing access to data from federal research pose many additional challenges that have been less well explored. These challenges raise questions of formatting, timing of release, and especially, as the AAMC notes, how best to safeguard the integrity of the research process and security of any sensitive information, such as individually identifiable information. 

“Access to raw data without benefit of analysis or review by a third party in the relevant field could be more harmful than beneficial and could undermine the fundamental reasoning behind the public accessibility efforts,”  AAMC states.  The association also advises that the institutional and investigator responsibilities under any proposed system for access should be clearly delineated. 

Federal agencies have until August 2013 to determine how they will implement the OSTP directives.


Heather Pierce, JD, MPH
Sr. Director, Science Policy & Regulatory Counsel
Telephone: 202-478-9926

Stephen Heinig
Director, Science Policy
Telephone: 202-828-0488


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