Summary of listening sessions and writen comments for USDA's 2023 

Implementa�on Plan to Increase Public Access to USDA-Funded Research 

Results 

Introduc�on 

On August 25, 2022, the White House Office of Science and Technology Policy (OSTP) issued a 

memorandum �tled "Ensuring Free, Immediate and Equitable Access to Federally Funded Research" 

promp�ng the USDA to enhance its policies, infrastructure, and outreach efforts. The goal is to make 

scien�fic data and publica�ons easily accessible and available to the public. These plans and policies apply 

to research results that are funded either par�ally or en�rely by any agency, within the USDA. 

The USDA Na�onal Agricultural Library (NAL) held two listening sessions on September 27 and October 12

of 2023 to solicit comments, recommenda�ons, and sugges�ons from public stakeholders on how they 

should respond to the new guidance from the OSTP related to the Implementa�on Plan to Increase Public 

Access to USDA-Funded Research Results (2023). There were 69 unique, non-USDA registrants for the 

public listening sessions. Addi�onally, USDA accepted writen comments via Regula�ons.gov through 

November 15, 2023. 

Comments were asked to address the following five ques�ons:

1. How can USDA best implement its plans to improve public access to USDA-funded research 

results? 

2. How can USDA update or refine its policies to improve public access to USDA-funded research 

results? 

3. How can USDA ensure equity in publica�on opportuni�es? 

4. How can USDA use partnerships to improve public access and accessibility to results of USDAfunded research? 

5. How can USDA monitor impacts on communi�es impacted by its public access policies?

Twenty-four total comments were received with 19 in the form of writen submissions (available at: 

(Regula�ons.gov) and five spoken comments during the two listening sessions (Available at YouTube.com: 

Sept 27; Oct 12). Of the five persons that gave spoken comment, four also submited writen comments 

though both forms of comments were considered for content individually. The writen comments 

composed 68 pages in total. Each comment, including transcripts of listening session comments, was read 

by at least two persons associated with the Na�onal Agricultural Library. 

Stakeholder Representa�on 

The USDA sought input from stakeholders throughout the United States including members of the public, 

principal inves�gators, research ins�tu�ons, libraries, scholarly publishers, scien�fic socie�es, agricultural 

organiza�ons and associa�ons, data scien�sts, data repositories, and other stakeholder groups. Of 

commenters, 60% were from the publishing industry including publishing associa�ons (Table 1). Not 

specifically represented among commenters were principal inves�gators, data scien�sts, and data 

repositories.
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Table 1. Organiza�ons represented by commenters.

Commenter Category Number

For-profit academic publishers 5

Non-profit society publishers 5

Publishing industry group 2

Anonymous 2

Private individuals 2

Non-profit other 1

Library associa�on 1

University 1

Agricultural tech companies 1

Total 20

Comment Analysis 

Almost all commenters expressed general support for public access though there were differing 

perspec�ves on how public access could be achieved. Disrup�ons to exis�ng business models were a major 

concern for publishers who generally advocated for recommending or requiring that researchers pay 

ar�cle processing chargers (APCs) to journals to have the version of the ar�cle published by the journal, 

the Version of Record (VOR or VoR), made openly available. This prac�ce is commonly referred to as Gold 

Open Access (OA). Current USDA policy requires either the final, peer-reviewed version of an ar�cle, also 

called the accepted manuscript (AM), or the VOR if published open access, be made publicly accessible

via the USDA publica�on repository PubAg. The AM does not have the journal’s proprietary typese�ng 

and forma�ng and is not copyrighted by the journal so can be made publicly accessible via a repository. 

This prac�ce commonly referred to as Green OA. 

Publishers men�oned the value added by the publishing process. Publishers recruit and coordinate peer 

reviewers, detect fraud, make ar�cles discoverable, update ar�cles with correc�ons and addenda, etc. This

value accrues more to Gold OA rather than Green OA according to publishers. Some commenters 

described inequity in the publishing process where well-funded researchers could publish Gold OA while 

less well-funded researchers could not. Commenters suggested USDA create specific funding mechanisms 

to cover APCs and to provide training to researchers about se�ng aside research funding to pay for these 

charges. Also men�oned were disconnects between grant periods and publishing which o�en occurs a�er 

a grant closeout. This poten�ally leads to grant funds not being able to be used for publishing costs. 

Several commenters urged USDA to allow authors flexibility in where to publish.

Commenters men�oned the importance of making it easier for researchers to comply with public access 

requirements. Commenters requested user-centered USDA submission portals, clear policy guidelines that 

are communicated consistently, and leveraging digital persistent iden�fiers, e.g., DOI, ORCID, ROR, etc., to 

automate compliance processes. Digital persistent iden�fiers were further iden�fied as preexis�ng tools

that could be used for monitoring the impacts of research. Commenters suggested improved 

communica�on and training for researchers, par�cularly on data management and sharing best prac�ces. 

They noted that researchers are o�en not trained or incen�vized to use best prac�ce data principles such 

as FAIR (Findability, Accessibility, Interoperability, and Reuse). Training was also recommended on 

naviga�ng publishing including what costs might be associated with publishing and what USDA funds could 

be used for such costs. Several commenters men�oned that the USDA should provide more informa�on 

for USDA-supported researchers on USDA websites related to compliance. 
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Regarding accessibility, commenters suggested alloca�ng staff resources to ensure ar�cles and data are 

accessible and compliant with Sec�on 508, including text descrip�ons that accompany visuals (i.e., charts, 

figures, tables, and etc.) found within scholarly outputs. Also suggested was that crea�ng plain language 

summaries or plain language versions of scholarly publica�ons would make USDA-funded scholarly 

publica�ons more accessible to the public. 

A few commenters addressed the broader impacts of public access. One comment, from a technology 

start-up, men�oned that making research and data available would help companies save �me and money. 

Another commenter men�oned that public access to research results would benefit transparency and 

accountability of taxpayer funded projects. One comment men�oned the importance of data from USDAfunded school meal programs and had specific data requests related to this. This comment was forwarded 

to the USDA Food and Nutri�on Service. Finally, commenters supported con�nued USDA engagement with 

external communi�es including to solicit feedback for evalua�on of the effec�veness of exis�ng public 

access policies.

The following six themes emerged from the 43 dis�nct comments: 

Coopera�on - Calls for the USDA to work more closely with other government agencies, libraries,

organiza�ons, professional and scholarly associa�ons, and with the publishing industry. 

Using exis�ng best prac�ces and infrastructures - Using digital persistent iden�fiers, using principles like 

FAIR, and relying on the publishing industry’s infrastructures. 

Training and communica�on - Clarity around funding for publica�ons, how to use best FAIR data principles, 

and making public access-related informa�on available on the USDA website. 

Funding mechanisms - Alloca�ng USDA funds for ar�cle processing charges and making sure funds are 

available for publica�on costs post-grant closeout. 

Accessibility - Alloca�ng resources to make sure USDA-funded scien�fic publica�ons meet exis�ng 

accessibility laws and using plain language summaries. 

Monitoring and evalua�on - Reviewing publica�on trends, cita�on rates of different publica�on methods

and formats, cost monitoring, using feedback from expert panels, listening sessions, and roundtables. 

Commenter Recommenda�ons 

The USDA asked the public five ques�ons. Below are the five ques�ons asked along with recommenda�ons 

from the public related to each of those ques�ons.

Ques�on 1: How can USDA best implement its plans to improve public access to USDA-funded research 

results? 

1. Provide integrated links, drop-down lists, and APIs to other websites to support the capture of 

relevant research and researcher metadata in grant workflows.

2. Develop flexible, clear frameworks in close coordina�on with other agencies to reduce confusion.
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3. Provide incen�ves and develop training resources, par�cularly on data management and sharing.

4. Leverage exis�ng infrastructures to avoid diver�ng resources from cri�cal research ac�vi�es.

5. Engage con�nually with the research community.

6. Minimize the administra�ve and financial burden on researchers and ins�tu�ons for compliance.

7. Specify allowable and unallowable costs for data management and sharing ac�vi�es. 

8. Develop a mechanism to ensure that funds are available post-closeout for publica�on and 

research data storage and/or sharing expenses. 

9. Collaborate with scholarly socie�es, researchers, and libraries to define a public-access deposit 

package that is inclusive of policy requirements.

10. Adopt the Implemen�ng Effec�ve Data Prac�ces report recommenda�ons from higher educa�on 

associa�ons.

11. Require Digital Object Iden�fiers (DOIs) for each publica�on and research output (data, code, 

so�ware)

12. Use Open Researcher and Contributor iden�fiers (ORCiD IDs) to uniquely iden�fy authors.

13. Use Research Organiza�on Registry (ROR) IDs to link authors with known organiza�ons, including 

Funder IDs

14. Share up to date and revised �meline online (NAL website) for Public Access.

15. Require that the Version of Record (VoR) be used in repositories.

16. Make sure data/publica�ons are machine readable.

17. Create a fund for ar�cle processing charges (fund Gold OA).

Ques�on 2: How can USDA update or refine its policies to improve public access to USDA-funded 

research results? 

18. Keep research summaries in plain, easy-to-read language. Research summaries should translate 

scholarly research findings and implica�ons for a wide audience.

19. Ensure PubAg and other websites that support USDA-funded research results (such as PubMed) 

and data are compliant with federal accessibility laws and standards. 

20. Publish USDA data in a �mely and standardized way that includes clarity around the level of 

aggrega�on of the data.

21. Provide more researcher training and database support for ensuring FAIR principles.

22. Create a “Publica�on Costs” table outlining different publica�on approaches.

23. Leverage Transforma�ve Agreements (TAs) between ins�tu�ons and publishers.

24. Create guides encouraging the use of alterna�ve text for visual or print-impaired individuals. 

25. Appoint staff resources to support USDA Accessibility requirements. 

Ques�on 3: How can USDA ensure equity in publica�on opportuni�es? 

26. Work with research ins�tu�ons, their libraries, and their professional and scholarly associa�ons 

on coordinated educa�on to inves�gators on their op�ons for no-fee manuscript deposit.

27. Explore preprint services to accelerate the sharing of research findings and consider the poten�al 

of recognizing peer-reviewed preprints as substan�ally similar to AMs for compliance with the 

policy.

28. Ensure final publisher PDF versions are accessible. This is cri�cal to enable equitable delivery of 

federally funded research results. 

29. Provide rights-reten�on language (for inves�gators to use upon submission of manuscripts to 

journals) that encourages authors to retain their copyrights and assign a Crea�ve Commons 

Atribu�on (CC BY) or similar license to their work to enable full reuse rights.

30. Adopt an evolving ethical framework.
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Ques�on 4: How can USDA use partnerships to improve public access and accessibility to results of 

USDA-funded research?

31. Develop an organized network or community of prac�ce from across the research ecosystem to 

gain a beter understanding of the impact of policies and share research results more widely. 

32. Partner with organiza�ons that are u�lizing plain language summaries for accessibility. 

33. Collaborate with publishers to develop more tailored research use-focused findings and output –

to maximize the poten�al for research to reach its target audience/s. 

34. Explore ways to support funded inves�gators and their ins�tu�ons in maximizing the uptake of 

open access and the impact of their research, e.g., partner with ins�tu�ons and libraries when 

possible so that ar�cle processing charges (APCs) are covered under TAs or open access accounts 

with publishers.

Ques�on 5: How can USDA monitor impacts on communi�es impacted by its public access policies?

35. Maintain a consistent dialogue with researchers and the public to monitor impact. 

36. Provide training materials for authors and grant managers to collaborate on finding the best route 

to publish.

37. Work with research ins�tu�ons to monitor costs and expenses for public-access policies by 

tracking not just expenses included in the grant, but across the ins�tu�on (from campus IT, 

research library, and research office) through a grant close-out report or commissioned study. 

38. Monitor publica�on trends across publica�on formats, including journal ar�cles, book chapters, 

and other peer-reviewed publica�ons.

39. Review the publica�on costs of journal �tles that USDA-supported researchers most commonly 

publish. 

40. Track data cita�ons for USDA-funded datasets over �me to best understand dataset use and reuse, 

and the impact of data reuse on advancing science. 

41. Compare impact factor of Gold OA to Green OA.

42. Use advisory panels, listening sessions, and roundtables.

43. Use exis�ng repor�ng infrastructure.