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Complying with the new �NIH Public Access Policy

June 27, 2025

Tyler Nix, Merle Rosenzweig, Sara Samuel

Taubman Health Sciences Library

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Housekeeping

Session recording and slides will be shared after the session.�
Everyone will remain muted throughout the presentation, and cameras will remain off. �
Use the Q&A feature to submit questions and upvote questions of interest for discussion at the end of the session.

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Session outline

Policy refresher
Policy change July 1
Compliance
Author's rights and copyright
Citing papers in grant renewals
FAQ
Questions
Resources

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NIH Public Access Policy refresher

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NIH Public Access Policy

https://sharing.nih.gov/public-access-policy

“To advance science and improve human health, NIH makes the peer-reviewed articles it funds publicly available on PubMed Central. ”

Making NIH-funded research publicly available
Applies to manuscripts only - not data or other scientific output

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Timeline

September 2004: Voluntary NIH Public Access Policy (PAP) implemented

April 2008: Mandatory NIH PAP enacted

August 2022: Office of Science & Technology Policy (OSTP) (Nelson) memo

December 2024: Draft 2024 NIH PAP released with December 31, 2025 implementation date

April 2025: 2024 NIH PAP accelerated to July 1, 2025 implementation date

July 2025: New NIH PAP goes into effect

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This policy has evolved over time so here are some key dates in the policy’s history.

In September 2004: a Voluntary NIH Public Access Policy (PAP) implemented. So researchers weren’t required to deposit their works into PubMed Central, but were asked to.
Then in April 2008: Mandatory NIH PAP enacted where researchers were then required to submit their work into PubMed Central.
In August 2022: the Office of Science & Technology Policy (OSTP) (Nelson) memo was released, asking all federal agencies to make a plan for how they would make publicly funded research available without an embargo. So the NIH responded to that in
December 2024 with the Draft 2024 NIH PAP, and that policy had listed the date of December 31, 2025 as the implementation date. Then unexpectedly, in
April 2025, the implementation date of the new NIH PAP was changed or accelerated to July 1 instead of December 31. So now, we are preparing for
July 1, 2025: when the New NIH PAP goes into effect.

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Important terms

Author Accepted Manuscript - authors' copy of the final peer-reviewed manuscript, not the publisher's Final Published Article. Referred to as "final peer-reviewed manuscript" in prior policy language.

Final Published Article - the journal's authoritative copy of an article, even prior to the compilation of a volume or issue or the assignment of associated metadata. May be referred to as the ”version of record."

PubMed Central - NIH's archival repository. PubMed Central accepts submissions of NIH-funded manuscripts from both authors (Author Accepted Manuscript) and journals (Final Published Article).

NIH Manuscript Submission System - supports the deposit of manuscripts into PubMed Central

Government Use License - a license that provides agencies with non-exclusive rights to articles resulting from federally-funded research.

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2024 NIH Public Access Policy. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-047.html

Before we go into more details about the policy itself, we’re going to cover some important definitions. Some of these are actually new in the 2024 policy. The 2008 version of the policy and other related communications since then have used the word 'manuscript' or 'final peer-reviewed manuscript' and some other terms that the 2024 policy now clarifies, so it's worth taking a moment to go over these new definitions.

Author Accepted Manuscript - authors' copy of the final peer-reviewed manuscript, not the publisher's Final Published Article. Referred to as "final peer-reviewed manuscript" in prior policy language. So it’s now called the Author Accepted Manuscript.
Final Published Article - this the journal's authoritative copy of an article, even prior to the compilation of a volume or issue or the assignment of associated metadata. May be referred to as the “version of record."
PubMed Central - NIH's archival repository. PubMed Central accepts submissions of NIH-funded manuscripts from both the author (Author Accepted Manuscript) and journals (Final Published Article). PubMed Central is different from the PubMed database which indexes a broad range of biomedical literature, including MEDLINE.
NIH Manuscript Submission System - the system supports the deposit of manuscripts into PubMed Central
Government Use License - a license provides agencies with non-exclusive rights to articles resulting from federally funded research.

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National Institutes of Health (NIH)�Public Access Policy Requirements

Submission of an electronic version of the Author Accepted Manuscript to PubMed Central upon its acceptance for publication for public availability without embargo upon the Official Date of Publication;
An acknowledgment in the Author Accepted Manuscript and Final Published Article that satisfies the requirements in the NIH Grants Policy Statement (GPS) regarding communicating and acknowledging federal funding (GPS 4.2.1 and GPS 8.2.1)...;
When an Author Accepted Manuscript is submitted to NIH, agreeing to a standard license … explicitly granting NIH the right to make the Author Accepted Manuscript publicly available through PubMed Central without embargo upon the Official Date of Publication.

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2024 NIH Public Access Policy. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-047.html

The new Policy requires that

An electronic version of the Author Accepted Manuscript be submitted to PubMed Central upon its acceptance for publication for public availability without embargo upon the Official Date of Publication;
There should also be an acknowledgment in the Author Accepted Manuscript and Final Published Article that satisfies the requirements in the NIH Grants Policy Statement (GPS) regarding communicating and acknowledging federal funding;
And when an Author Accepted Manuscript is submitted to NIH, researchers agree to a standard license … explicitly granting NIH the right to make the Author Accepted Manuscript publicly available through PubMed Central without embargo upon the Official Date of Publication.

So in simpler terms: the manuscript needs to be put into PubMed Central, the manuscript needs to include a funding acknowledgment, and NIH should be granted the ability to host and share out the manuscript.

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What has changed?

The new policy eliminates the publisher's optional 12-month embargo period.

Manuscripts are now required to be made publicly available �in PubMed Central at the time of publication.

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Implementation timeline

Applies to Author Accepted Manuscripts accepted on/after July 1, 2025
“When determining the release of an Author Accepted Manuscript for public availability, the definition of Official Date of Publication is applicable. NIH has revised the definition of Official Date of Publication to be “the date on which the Final Published Article is first made available in final, edited form, whether in print or electronic (i.e., online) format.”

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2024 NIH Public Access Policy. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-047.html

The new Policy replaces the 2008 Policy and applies to manuscripts accepted for publication on or after July 1, 2025. The Policy applies to Author Accepted Manuscripts accepted for publication on or after July 1, regardless of when the award was made that resulted in the Author Accepted Manuscript.

So if you have an article already in the publication process, this date is important. If your article has been officially accepted already, or will be in the next 3 days, you do not need to follow the new policy. If you have an article already in the publication process and it has not yet been accepted, if you receive notice of acceptance on or after July 1, you now need to follow this new policy.

So how does NIH determine when an Author Accepted Manuscript needs to be publicly available? The Official Date of Publication is submitted along with the manuscript into the NIH manuscript system and that is the date used.

https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-047.html

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What does lack of embargo mean for grantees and administrators?

Publishers and journals are actively changing publication options in this new environment:

Assume that familiar publication routines & costs may be changing
Communicate early and often with editors and confirm compliance options in writing
Plan to budget for potential publication fees in NIH grant applications

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Policy compliance

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Option 1 �Grantees post their Author Accepted Manuscript to PubMed Central manually using the NIH Manuscript Submission System (NIHMS). ��Option 2�Publisher posts Final Published Article to PubMed Central on author's behalf.

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Option 1

Grantees post their Author Accepted Manuscript to PubMed Central manually using the NIH Manuscript Submission System (NIHMS).

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2024 NIH Public Access Policy. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-047.html

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Reuse of Author Approved Manuscripts

Posting your Author Approved Manuscript to PubMed Central is a cost-free option granted by NIH that authors have the right to exercise.

The Policy requires that grantees provide NIH rights to the Author Approved Manuscript that are equivalent to the Government Use License, e.g.:

“A royalty-free, nonexclusive and irrevocable right to reproduce, publish, or otherwise use the work for federal purposes, and to authorize others to do so.”

This right does not extend to the publisher's Final Published Article.

2024 NIH Public Access Policy. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-047.html

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Exercising compliance with author agreement addendums

If a publisher does not offer a route to compliance, you can request to modify the author agreement so that you, the author, retain the right to share and post your Author Approved Manuscript in PubMed Central
Addendum templates are available from the Library Copyright Office: https://www.lib.umich.edu/research-and-scholarship/copyright-services/forms/authors-addenda

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NIH Manuscript Submission System (NIHMS)

https://www.nihms.nih.gov/

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If you are submitting your Author Approved Manuscript to PubMed Central manually, you or a delegate will use the NIH Manuscript Submission System to submit your final draft manuscript and all tables, figures, and supplemental materials. The NIHMS system walks you through a six step process that includes file submission, conversion, and two stages of approval. Submitting your manuscripts in NIHMS requires that you have access to the original manuscript drafts, so it's important to stay organized and maintain access to all of your files during the writing process.

The process typically takes several weeks to complete and results in the Author Accepted Manuscript being available in PubMed Central and assigned a PMCID number. We don't have time to go in depth into the NIHMS submission and approval process today, but we do link to a NIHMS FAQ document and other resources at the end of the slides.

Note: in number 6, there will no longer be an embargo period.

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Option 2

The publisher posts their Final Published Article to PubMed Central behind the scenes, on the author's behalf.��

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Which journals have formal agreements with NIH to post Final Articles to PubMed Central? ��Which journals still have a 12 month embargo?

Check with your journal / publisher!

*New* PMC Journal List - see the “Agreement status” and “Agreement to deposit” fields�https://pmc.ncbi.nlm.nih.gov/journals/

JISC Open Policy Finder�https://openpolicyfinder.jisc.ac.uk/

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Public Access and Open Access publishing

Public Access compliance does not require an Open Access (OA) publishing agreement�
However, many authors do achieve compliance by publishing Open Access

NIH will accept submission of the Final Published Article to PubMed Central from journals or publishers with formal agreements with NLM if the article is made publicly available without embargo upon the Official Date of Publication

2024 NIH Public Access Policy. https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-047.html

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Publication costs

The NIH allows reasonable Open Access / Author Processing Charge (APC) fees to be covered by grant funds�
Publishing fees besides APC fees, e.g. for the sole purpose of submitting the Author Accepted Manuscript to PubMed Central, are not allowable costs

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2024 NIH Public Access Policy and Supplemental Guidance. https://www.federalregister.gov/documents/2024/12/18/2024-29929/the-national-institutes-of-health-public-access-policy

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U-M Open Access discounts

The U-M Library has agreements with a variety of publishers which provide either free or discounted fees for publishing open access. Examples include:

Association of Computing Machinery (ACM)
Cambridge University Press
Elsevier
Royal Society of Chemistry (RSC)

A full list is available at: https://guides.lib.umich.edu/scholarlypublishing/discounts-funding

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Compliance recap

New policy does away with the 12 month embargo period
Publishers will likely be changing their compliance-ready publication offerings in the coming weeks and months based on the deletion of the 12 month embargo period. There is uncertainty around what the new options will be.
The two existing compliance pathways will continue under the new policy, namely:

Grantees submit their Author Accepted Manuscripts manually; or
Journals submit the Final Published Article, likely through an OA publishing agreement �(though not necessarily)

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Recommendations

Investigate or contact journals to explore Public Access compliance options
Read your author agreement closely and confirm in writing all compliance options with journal editors in advance of signing the agreement

Use the author addendum to retain your reuse rights if possible

Confirm whether the journal will submit Final Published Article to PubMed Central on your behalf
Plan to use grant funds to pursue Open Access publishing when possible
If not, use the NIH Manuscript Submission System to manually submit your Author Approved Manuscript to PubMed Central when your paper is accepted for publication

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Managing publications

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Linking MyBibliography to eRA commons

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Detailed instructions: https://www.era.nih.gov/eraHelp/Commons/Commons/myncbi.htm?TocPath=_____24

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Confirming compliance status

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Managing publications: http://www.ncbi.nlm.nih.gov/books/NBK53595/#mybibliography.Managing_Compliance_to_th

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Frequently Asked Questions

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Q: Can I go ahead and submit my final manuscript to the NIH Manuscript Submission System (NIHMS) to be sure that it's deposited?

A: It depends. If you are publishing in a journal that submits your Final Article to PubMed Central, the NIHMS now prevents you from uploading a duplicate. Otherwise, be sure to confirm your submission plan in writing with your publisher before uploading your Author Approved Manuscript to avoid violating publisher terms.

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Q: Will all journals be removing their 12-month embargo requirements? If not, are there resources that clarify which journals will still enforce embargos and which will not?

A: We don't know how all publishers will be responding to this. If you have questions about a particular journal, we encourage you to reach out directly to the journal/publisher to ask. The Directory of Open Access Journals or JISC Open could be helpful tools for finding open access journals.

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Q: Should I assume that journals imposing a 12-month embargo will start requiring me to pay open access fees? What happens if I’d like to publish in a journal that doesn’t have an open access option?

A: It’s important to understand your publishing options prior to submitting an article to a journal. We encourage you to use the author addendum to retain your rights as an author, or consider publishing in one of the open access journals that the library agreements cover.

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Q: Who is ultimately responsible for compliance?

A: Institutions and PIs are ultimately responsible for policy compliance, even for articles for which PIs are not authors (e.g. a graduate student-written article that was funded by the PI’s grant). Non compliant articles may put funding renewals at risk for non-competing continuation awards.

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NOT-OD-12-160: Upcoming Changes to Public Access Policy Reporting Requirements and Related NIH Efforts to Enhance Compliance

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Q: How do I ensure that a manuscript deposited upon acceptance is made publicly available exactly on the official date of publication?

A: NIHMS will likely ask for the date of publication when manually submitting an article. If the article is being submitted by a publisher on the author's behalf, NIHMS will use publication date metadata from the publisher to coordinate posting of the manuscript on the publication date.

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Q: Can I post my Author Accepted Manuscript in bioRxiv, Deep Blue Documents, or another repository to achieve compliance?

A: The NIH policy does not prevent authors from posting Author Accepted Manuscripts to other repositories. However, to achieve compliance, the policy requires the Author Accepted Manuscript (or Final Published Article, if coming from the publisher) to be deposited into PubMed Central.

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Q: Is the American Chemical Society’s article development charge (ADC) an allowable cost?

A: Our interpretation so far is that the ADC will not end up being an allowable cost according to the NIH. For the time being, we advise you to explore alternatives to paying for the ADC, and we can follow up with you offline with some options if you have additional questions.

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Audience-submitted questions

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Let us know what you thought of the session today!

https://umich.qualtrics.com/jfe/form/SV_ctKLf49aDgqONwO

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Resources

2024 NIH Public Access Policy
2024 NIH Public Access Policy and Supplemental Guidance from the Federal Register
Taubman Health Sciences Library NIH PAP guide

Includes Canvas-based compliance tutorial

NIH PAP Frequently Asked Questions
NIHMS Frequently Asked Questions
Author’s Alliance FAQ about the NIH PAP
SPARC handout: Deadline for Compliance with NIH’s Public Access Policy Accelerated
eRA Commons: Manage Publications

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Contact us!

nihms-library-support@umich.edu

National Institutes of Health Public Access Policy - Research Guide

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