Strengthening the Foundations for Trustworthy, Open Research: Annual Report 2025

Federal Policy Engagement

In 2025, COS deepened its engagement in U.S. federal science policy, focusing on how public investment in research is communicated, evaluated, and preserved. COS policy leadership submitted formal comments in response to a National Institutes of Health (NIH) Request for Information on limiting allowable publishing costs. The submission, authored by Maryam Zaringhalam, Senior Director of Policy, and David Mellor, Senior Policy Analyst, outlined evidence-based recommendations to better align research assessment, incentives, and investments with actions that can better promote the openness and trustworthiness of NIH-funded research.

“NIH has an opportunity to drive a paradigm shift away from publications as the primary unit of currency for research communications and toward a more holistic ecosystem for knowledge dissemination and evaluation that promotes the transparency, rigor, and trustworthiness of research results. In doing so, NIH can promote more cost-effective opportunities for researchers to continue sharing their work while maximizing NIH’s investments in research.”
Maryam ZaringhalamMaryam Zaringhalam
Senior Director of Policy
Center for Open Science
David MellorDavid Mellor
Senior Policy Analyst
Center for Open Science

Following the RFI, congressional appropriators encouraged NIH to increase support for replication research and directed the agency to brief committees on potential caps to article processing charges, reflecting the broader policy issues organizations like COS highlighted in its submission. COS also submitted a formal comment to the White House Office of Science and Technology Policy on actions to accelerate the American scientific enterprise, building on our response to NIH. Our recommendations centered on strengthening implementation efforts for open science policymaking and increasing the capacity of the research community to meaningfully comply with public access mandates to increase the openness and trustworthiness of federal research, while increasing the return on investment of federal research dollars.

Complementing this focus on how research outputs are funded and shared, COS was awarded a grant from the Robert Wood Johnson Foundation to lead a collaborative and community-led strategic planning effort focused on preserving and safeguarding publicly funded scientific data. This work aims to identify risks, align and coordinate stakeholders, and develop practical approaches for ensuring that federally-funded research data remain accessible, usable, and responsibly stewarded over time—particularly amid funding uncertainty and a shifting policy landscape.

COS also issued a statement in response to the “Restoring Gold Standard Science” Executive Order, explaining why framing reform around a rigid “gold standard” could undermine the decentralized, evidence-based processes that support credible research. The statement reaffirmed that the research community must continue to advocate for meaningful, principled efforts to promote openness and earn trust. COS has since worked with aligned organizations to monitor Gold Standard Science implementation efforts and their potential impacts.