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Federal Agency Open Access Updates: NIH

Information about Federal Funding agencies' policies and procedures for open access publication and research data sharing and deposit

Publications

Effective July 1, 2025, a new NIH Public Access Policy went into effect.

This policy now removes the 12-month embargo, requiring all Author Accepted Manuscripts accepted for publication on or after July 1, 2025 to be made immediately available in PubMed Central upon publication.

Author Accepted Manuscripts are defined by the NIH as, "the author’s final version that has been accepted for journal publication and includes all revisions resulting from the peer review process, including all associated tables, graphics, and supplemental material."

Three Critical Steps to Maintaining Compliance

1. Ensure submission of work to PubMed Central upon notice of publication

2. Ensure language about NIH funding and PubMed Central requirements are clearly defined in the work

3. All reports, proposals, etc. must include a PubMed Central Identifier (PMCID) when demonstrating compliance with NIH

More Information on Steps 1 and 3

1. You must submit your Author Accepted Manuscript to PubMed Central for public availability without embargo upon publication date. It is not sufficient for the work to be available on a journal or publisher's website; it must be submitted for immediate release to PubMed Central. With that, there are some journals that automatically deposit the work in PubMed Central. To see which journals currently have this agreement, visit this link from the NIH. Ensure that the agreement is active and check with the journal/publisher.

3. When you submit your work to PubMed Central, it will be assigned a PubMed Central Identifier (PMCID). If you have a NIH Manuscript Submission identifier (NIHMSID), that may be used instead of a PMCID for up to three months following the publication date.

This chart, created by Dana Haugh, Harvey Cushing/John Hay Whitney Medical Library, Yale, (and copied from University of Pittsburgh's HSLS LibGuide) can also help explain:

Chart that explains which articles are subject to the new NIH public access policy. If your award was closed before July 1, 2025 or your manuscript accepted before July 1, 2025, comply with the 2008 Public Access Policy.

Digital Research Data

This section summarizes key points from NIH policy as of NOT-OD-21-013. Further explanations and clarifying details are available at https://grants.nih.gov/policy-and-compliance/policy-topics/sharing-policies.

Data Management Plan

  • A formal Data Management and Sharing Plan (DMSP) is required as part of the Budget Justification section of the application.
  • For detailed instructions on writing a DMSP for NIH, visit https://grants.nih.gov/policy-and-compliance/policy-topics/sharing-policies/dms/writing-dms-plan.
  • Following agency approval of a submitted DMSP, any changes in expected data types, levels of public data sharing, or inability to meet timelines outlined in the original plan require submitting a revised DMSP to the NIH ICO for review.
  • USU Libraries provides assistance with writing DMPs. Access DMPTool or request a consultation with our Data Librarian here: https://libguides.usu.edu/data/dmp

Timeline

  • "Shared scientific data should be made accessible as soon as possible, and no later than the time of an associated publication, or the end of performance period, whichever comes first. Researchers are encouraged to consider relevant requirements and expectations (e.g., data repository policies, award record retention requirements, journal policies) as guidance for the minimum time frame that scientific data should be made available, which researchers may extend."

Required and Excluded Data

NIH defines the type of data that is covered by their sharing policy as:

The recorded factual material commonly accepted in the scientific community as of sufficient quality to validate and replicate research findings, regardless of whether the data are used to support scholarly publications. Scientific data do not include laboratory notebooks, preliminary analyses, completed case report forms, drafts of scientific papers, plans for future research, peer reviews, communications with colleagues, or physical objects, such as laboratory specimens.

Data resulting from research involving human subjects must be managed and shared appropriately to protect privacy. NIH accepts a variety of strategies for doing this when sharing data, including deidentification, redaction, or sharing via controlled-access repositories. For more details, visit https://grants.nih.gov/policy-and-compliance/policy-topics/sharing-policies/dms/privacy.

Repository & Metadata

  • Some funding opportunities specify which repositories must be used. Check your grant terms!
  • For data generated from research for which no data repository is specified by NIH, researchers are encouraged to select a data repository that is appropriate for the data generated from the research project. Be sure to consult the list of desirable characteristics and the following guidance:
    • Primary consideration should be given to data repositories that are discipline or data-type specific to support effective data discovery and reuse. For a list of NIH-supported repositories, visit Repositories for Sharing Scientific Data.
    • If no appropriate discipline or data-type specific repository is available, researchers should consider a variety of other potentially suitable data sharing options:
      • Small datasets (up to 2 GB in size) may be included as supplementary material to accompany articles submitted to PubMed Central (instructions).
      • Data repositories, including generalist repositories or institutional repositories, that make data available to the larger research community, institutions, or the broader public.
      • Large datasets may benefit from cloud-based data repositories for data access, preservation, and sharing.
  •  For help choosing a data repository, visit USU Libraries Research Data Services.

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