Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public...

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Transcript of Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public...

Page 1: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.
Page 2: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

• Why It’s Important to Know About the Policy– What Hospital Librarians Need to Know

• NIH Public Access Policy Overview

• Myth Busters re: NIH Policy

• Compliance Steps – including 2010 MyNCBI/My Bibliography function

• Problems and Questions Identified by the Library

Community

• Models of Library Support

• Resources and Further Reading

Contents

Page 3: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Why Know About the Policy?

• To gain knowledge for educating patrons

• To enhance the library’s role in compliance

• To understand versioning, including the difference between the final peer-reviewed manuscript and the final published article

Page 4: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Why Know About the Policy?

• To recognize the possible impact of the policy on interlibrary loan

• To understand the policy’s possible influence on collection development decisions and the need for journal subscriptions

• To improve publisher relations by understanding their perspective

Page 5: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

What Do Hospital Librarians Need to Know About NIH Public Access Policy?

• Does your hospital receive NIH funding? – Yes? Review entire slide show!

– No? Awareness essential, know four key concepts as follows: (can skip slides for compliance, problems, models)

• Understanding: Can you briefly define the policy? See “Overview” section and publicaccess.nih.gov

• Reality check: NIH Public Access ≠ Open Access. Do you know the difference? See: http://publicaccess.nih.gov/FAQ.htm#f39

• Professional practice: Can you present and discuss possible impacts/myths to a library committee? See: “Why It’s Important to Know about the Policy?” and “Myth Busters”

• Just-in-time, bookmark resources you might need: See: “Resources” Time for only one? – MLA Q&A videocast by Neil Thakur, NIH: publicaccess.nih.gov/PublicAccess_MLA_Q&A_5-09_small.wmv

Page 6: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

• Why It’s Important to Know About the Policy– What Hospital Librarians Need to Know

• NIH Public Access Policy Overview

• Myth Busters re: NIH Policy

• Compliance Steps – including 2010 MyNCBI/My Bibliography function

• Problems and Questions Identified by the Library

Community

• Models of Library Support

• Resources and Further Reading

Contents

Page 7: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

NIH Public Access Policy

• Signed into law December 2007; made permanent in FY09 Federal budget bill

• Formerly a recommendation, now a requirement • Pressure to make results of tax-payer funded research

accessible to the public

1. National Institutes of Health, Office of Extramural Research. Public Access Frequently Asked Questions. [web page] Bethesda, MD; [cited 2009 August 5]; Available from: http://publicaccess.nih.gov/FAQ.htm#a1

“To ensure that the public has access to the published results of NIH-funded research to help advance science and improve human health”1

Page 8: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

U.S. Government Initiative:NIH Public Access Policy

• All peer-reviewed articles arising from NIH funding (in whole or in part) must be submitted to PubMed Central (PMC) when they are accepted for publication, to be publicly available no later than 12 months after date of publication

• Responsibility of the grantee to ensure articles are submitted– Must include all graphics and supplemental materials– Submission is to be done upon acceptance for publication

Page 9: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Timely Submissions are Important!

• Authors need to plan for complying with the Policy early in the publication process.

• See specific questions for authors to consider at:

publicaccess.nih.gov/address_copyright.htm

Page 10: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Policy Applies toAny Final Manuscript That ….

• Is peer-reviewed• Is accepted for publication in a journal on

or after April 7, 2008, and arises from:

– Direct funding from an NIH grant or cooperative agreement active in Fiscal Year 2008, or;

– Direct funding from an NIH contract signed on or after April 7, 2008

Page 11: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Policy Does Not Apply to:

• Non-peer-reviewed materials such as letters,editorials or book chapters

• The full applicability criteria are at: http://publicaccess.nih.gov/determine_applicability.htm

NOTE: Review articles, which were excluded

in the prior voluntary policy are covered in the

current policy only if they are peer-reviewed1

1 -Thakur, Neil,Ph.D., Office of Extramural Research, National Institutions of Health, Email communication, June 30, 2009.

Page 13: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

U.S. Government Initiative:PubMed Central (PMC)

www.pubmedcentral.gov

• Digital archive of freely available biomedical & life sciences journal literature

• Developed & managed by NIH/NLM/NCBI

• Publishers or authors deposit electronic content– Content available immediately or after a specified embargo period– Voluntary participation was low

• Potential to integrate literature with other information resources such as sequence databases or public data sets

Page 14: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

PubMed vs. PubMed Central

PubMed:• Provides access to citations from biomedical literature

• Includes 19 million+ citations from MEDLINE and selected other life sciences journals

• Life science journal and biomedical journal articles and manuscripts back to 1948

• Links to full text articles and other scientific resources

• Each citation indexed with a PMID

Page 15: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

PubMed vs. PubMed Central

PubMed Central (PMC):• Digital archive of full-text, peer-reviewed journal articles and author

manuscripts

• Each paper indexed with a PMCID

– Series of numbers preceded by “PMC”

– Content is publicly accessible and integrated with other databases

• A PubMed citation exists for each PMC article, with a link from the PubMed record to the full text of the article in PMC. See below:

Page 16: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

• Why It’s Important to Know About the Policy– What Hospital Librarians Need to Know

• NIH Public Access Policy Overview

• Myth Busters re: NIH Policy

• Compliance Steps – including 2010 MyNCBI/My Bibliography function

• Problems and Questions Identified by the Library

Community

• Models of Library Support

• Resources and Further Reading

Contents

Page 17: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Myth Busters RE: NIH Policy

• Roughly 10% of PubMed content from recent years is NIH funded and therefore could link to free full text manuscripts1,2

• Overall policy compliance is close to 70% (see next slide for statistics)

• Most journal embargo periods are 12 months, meaning that a subscription is still required to gain access to the most current year of content.

1. Steinbrook R. “Public access to NIH-funded research.” N Engl J Med. 2005 Apr 28;352(17):1739-41.

2. Thakur, N., National Institutes of Health, Office of Extramural Research, Email communication, July 24, 2009.

Page 18: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

National Institutes of Health. NIH Manuscript Submission System – NIHMS Statistics. [web page] Bethesda, MD; [cited 2010 Aug. 20]; Available from: http://www.nihms.nih.gov/stats/index.shtml.

NIHMS Statistics through March 2010

Page 19: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

• Why It’s Important to Know About the Policy– What Hospital Librarians Need to Know

• NIH Public Access Policy Overview

• Myth Busters re: NIH Policy

• Compliance Steps – including 2010 MyNCBI/My Bibliography

function

• Problems and Questions Identified by the Library

Community

• Models of Library Support

• Resources and Further Reading

Contents

Page 20: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Compliance Step 1:Publication Agreement

• Authors own the original copyright to their articles• Publishers ask authors to transfer some or all of their rights• DO NOT sign any copyright transfer or publication agreement that

does not allow the article to be submitted to PMC in accordance with the NIH Policy

• Librarians and investigators should consult with institutional officials or legal counsel to develop particular copyright agreement terms. Sample language to insert:

“Journal acknowledges that Author retains the right to provide a copy of the final manuscript to the NIH upon acceptance for Journal publication, for public archiving in PubMed Central as soon as possible but no later than 12 months after publication by Journal”1

1. National Institutes of Health, Office of Extramural Research. Public Access Frequently Asked Questions. [web page] Bethesda, MD; [cited 2009 Aug. 4]; Available from: http://publicaccess.nih.gov/FAQ.htm#c16

Page 21: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Compliance Step 2:Submit Paper to PMC- Submission Methods Overview

• Method A - Journal deposits final published articles in PubMed Central without author involvement

• Method B - Author asks publisher to deposit specific final published article in PMC

• Method C - Author deposits final peer-reviewed manuscript in PMC via the NIHMS

• Method D – Publisher deposits manuscript; author approves and completes the process

Page 22: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Method A:• Publish in a journal that deposits all NIH-funded

final published articles in PMC without author involvement

• View NIH-approved list of journals

Compliance Step 2: Submit Paper to PMC

Page 23: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Compliance Step 2: Submit Paper to PMC

Method B: • Make arrangements to have a publisher deposit a

specific final published article in PubMed Central

• View NIH-approved list of publisher programs

This is generally an “Open Choice” – author-pay model-which costs $$$

Page 24: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Method C: Deposit your own manuscript• Three steps:

1. Deposit manuscript files to NIH Manuscript Submission System and link to NIH funding

• Can be done by author, publishers, or someone in the author’s organization – such as the librarian

2. Authorize NIH to process the manuscript (via email from NIH) • Can be done only by authors who log into NIHMS with an eRA

Commons Account or NIH Account.

3. Approve the PMC-formatted manuscript for public display• NIHMS converts deposited files to PMC format, and emails author

to approve its release

• After the specified delay period, NIHMS will automatically send the article to PMC for public posting

Compliance Step 2: Submit Paper to PMC

Page 25: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Method C: Deposit your own manuscriptSee: www.nihms.nih.gov/ for help, FAQs, news, statistics, and a grant lookup tool

www.nihms.nih.gov

Compliance Step 2: Submit Paper to PMC

Page 26: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Method D: Complete the submission process for a final peer-reviewed manuscript that the publisher has deposited in the NIHMS. 

Steps for author:• NIHMS emails corresponding author

– Author approves manuscript

– Author receives NIHMS number

• NIHMS emails corresponding author again– Author approves PMC-formatted version for public display

• Once process is complete, NIHMS emails the citation and PMCID to all authors

Compliance Step 2: Submit Paper to PMC

Page 27: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Compliance Step 3:Citing Your Papers

In all grant applications, renewals, progress reports or biosketches:• List the PubMed Central reference number (PMCID) at end of journal citation

• If a PMCID number is not yet available, include the NIH Manuscript Submission system reference number (NIHMS ID) instead, but there is a limit on how long this temporary number can be used (See next slide).

• In submission Method A or B, use "PMC Journal in Process" for any citation that does not yet have a PMCID

Example:• Varmus H, Klausner R, Zerhouni E, Acharya T, Daar A, Singer P. 2003.

PUBLIC HEALTH: Grand Challenges in Global Health. Science 302(5644): 398–399. PMCID: PMC243493

• See “Citation Methods” web page at publicaccess.nih.gov/citation_methods.htm

Page 28: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Compliance Step 3:Citing Your Papers – Policy Change

re: Use of NIHMSID1

• NIHMSID can only be used to show compliance for up to 3 months after a paper is published.

• After that, a PMCID must be used to demonstrate compliance.

• An NIHMSID will no longer be accepted for use if an applicable paper was published 3 or more months prior to an NIH application

1. National Institutes of Health, Office of Extramural Research. Clarification on the Use of an NIHMSID to Indicate Compliance with the NIH Public Access Policy. [web page] Bethesda, MD; [cited 2009 August 17]; Available from: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-136.html

Page 29: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

My NCBI / My Bibliography Function

• New feature in My Bibliography facilitates management of publication compliance

• Introduced January, 2010• From the new Awards View, eRA Commons users,

extramural principal investigators, grantees or applicants can see whether their publications are compliant with the Policy, start the manuscript submission process, associate their NIH extramural awards with their publications, and designate delegates to manage their bibliography via My NCBI.

Page 30: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

My Bibliography- For more information:

• NLM Technical Bulletin article: “My NCBI: Managing Compliance with the NIH Public Access Policy Using My Bibliography”which walks you through the process.

See: http://www.nlm.nih.gov/pubs/techbull/jf10/jf10_myncbi_redesign.html

Page 31: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Find PMCIDs in PubMed’sAbstract View

31

Page 33: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

• Why It’s Important to Know About the Policy– What Hospital Librarians Need to Know

• NIH Public Access Policy Overview

• Myth Busters re: NIH Policy

• Compliance Steps – including 2010 MyNCBI/My Bibliography function

• Problems and Questions Identified by the Library

Community

• Models of Library Support

• Resources and Further Reading

Contents

Page 34: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Problems/Questions: What if I don’t comply?

• Compliance is a “term & condition of award”

• Generally, NIH will offer grantee opportunity to correct the deficiency

• Even if a grantee is taking corrective action, NIH may take proactive action to protect the Federal government’s interests, including:

– Placing special conditions on awards, or – Precluding the grantee from obtaining future awards for a specified

period,

• NIH may take action designed to prevent future non-compliance, such as closer monitoring.

Page 35: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Problems/Questions:Which version should be submitted?

• Final peer-reviewed manuscript: The investigator's final manuscript of a peer-reviewed paper accepted for journal publication, including all modifications from the peer review process. Methods C (author submits) and D (publisher submits/author approves)

• Final published article: The journal’s authoritative copy of the paper, including all modifications from the publishing peer review process, copyediting and stylistic edits, and formatting changes.1

Methods A and B (publisher submits and completes the process for both methods)

1. National Institutes of Health, Office of Extramural Research. Public Access Frequently Asked Questions. [web page] Bethesda, MD; [cited 2009 August 4]; Available from: http://publicaccess.nih.gov/FAQ.htm#c18

Page 36: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Problems/Questions:Where is my manuscript’s NIHMSID?

Three sources of information:• Ask the corresponding author• Ask the publisher• Ask the NIHMS Help Desk via one of two contact links

on this page: http://www.nihms.nih.gov/ but you need to be logged in to NIHMS to link to the correct help page.

NOTE: Do not write “PMC – Journal in Process” to indicate compliance except in Methods A or B submissions– See http://publicaccess.nih.gov/submit_process.htm

Page 37: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Problems/Questions:Where is my manuscript’s PMCID?

• Try locating the PMCID in the abstract version of the PubMed record or in PMC

• Use the PMID to PMCID Converter here: http://www.ncbi.nlm.nih.gov/sites/pmctopmid

• Use the NIHMSID instead, with the caveat:NIHMSIDs will become invalid three months after a paper is published. The validity of an NIHMSID will be evident in:

– The NIHMS, under Manuscript List, which is the first screen a user will see once logged on to the NIHMS.

– The PI’s  eRA Commons Profile. See especially the new Awards View in My NCBI/ My Bibliography (Slide #’s 30 and 31)

See Clarification on the Use of an NIHMSID to Indicate Compliance with the NIH Public Access Policy for details.1

1-National Institutes of Health, Office of Extramural Research. Clarification on the Use of an NIHMSID to Indicate Compliance with the NIH Public Access Policy. [web page] Bethesda, MD; [cited 2009 August 17]; Available from: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-136.html

Page 38: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Problems/Questions:How do I demonstrate compliance with papers that don’t fall under the policy?

Explanations to use for lack of required #’s

• Paper was accepted prior to April 7, 2008*

• Paper was not peer-reviewed1

• No NIH funding was used

1. “Reminder Concerning Grantee Compliance with Public Access Policy and Related NIH Monitoring Activities Notice Number: NOT-OD-08-119,” September 23, 2008, http://grants.nih.gov/grants/guide/notice-files/NOT-OD-08-119.html

Page 39: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

• Why It’s Important to Know About the Policy– What Hospital Librarians Need to Know

• NIH Public Access Policy Overview

• Myth Busters re: NIH Policy

• Compliance Steps – including 2010 MyNCBI/My Bibliography function

• Problems and Questions Identified by the Library

Community

• Models of Library Support

• Resources and Further Reading

Contents

Page 40: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Models of Library Support:Collaborative Approach

• To achieve optimal compliance, libraries should work with other departments involved in the sponsored research management process.

• Consult with Offices of Sponsored Research or Research Administration to develop a plan

• For suggested approaches, see:

http://publicaccess.nih.gov/sponsored.htm

Page 41: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Models of Library Support:Library Services for Authors

• Add compliance information to library website

• Consult with authors

• Write newsletter articles on the Policy

• Offer lectures/classes on Policy compliance

Page 42: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Models of Library Support:Deposits to PubMed Central

• Assist authors with deposits

• Perform actual manuscript submissions on behalf of authors; compliance may be a shared responsibility between the library and office of research or grants.

• Assist in interpreting publisher agreements and author rights

• Assist in understanding embargo periods and authors’ rights

Page 43: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Models of Library Support:Related Services

• Host an institutional repository

• Provide citation management software & support

• Participate in monitoring compliance

Page 44: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Sample Library Support Web Pagebecker.wustl.edu/services/scholarly/nihpolicy.html

Page 45: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Sample Library Support Pagewww.fhcrc.org/science/shared_resources/library/services/authors/index.html

Page 46: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

• Why It’s Important to Know About the Policy– What Hospital Librarians Need to Know

• NIH Public Access Policy Overview

• Myth Busters re: NIH Policy

• Compliance Steps – including 2010 MyNCBI/My Bibliography function

• Problems and Questions Identified by the Library

Community

• Models of Library Support

• Resources and Further Reading

Contents

Page 47: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

• Question and Answer Videocast for Medical Library Association Annual Meeting (by Neil Thakur, PhD- 19 min., May, 2009) publicaccess.nih.gov/PublicAccess_MLA_Q&A_5-09_small.wmv

• NIH Public Access webpage: publicaccess.nih.gov

• NIH Public Access and Manuscript Submission – Resources and Tools www.nlm.nih.gov/bsd/public_access/resources.html

• NIH Public Access and Manuscript Submission System Help page: www.nihms.nih.gov/help/

• MLANET NIH Public Access Policy webpage www.mlanet.org/resources/publish/sc_nih-policy.html

• Association of Research Libraries (ARL)- Guide for Research Librarieswww.arl.org/sc/models/models-resources/nih-pa/nih-guide/index.shtml

Resources and Further Reading

Page 48: Why Its Important to Know About the Policy – –What Hospital Librarians Need to Know NIH Public Access Policy Overview Myth Busters re: NIH Policy Compliance.

Resources and Further Reading

• AAHSL Public Access Toolkit:   

http://www.usc.edu/hsc/nml/aahsl/open_access_toolkit.html

• Scholarly Publishing & Academic Resources Coalition (SPARC) Resources for Authors : www.arl.org/sparc/author/

• SHERPA/ROMEO: www.sherpa.ac.uk/romeo.php– Copyright and archiving policies of individual publishers and

journals– NOTE: Authors are bound by the copyright agreements they signed;

not necessarily what SHERPA/ROMEO indicates

• Washington University- Becker Medical Library --Compliance Flowchart: becker.wustl.edu/pdf/Demonstrate-NIHCompliance.pdf