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Federal Public Access Policies: NIH Policy

An overview of the current and future landscape of US Public Access Policies.

Current NIH Public Access Policy

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  • All peer-reviewed publications that are the result of an NIH grant must be made publicly available in PubMed Central. Current policy allows for a 12-month embargo on publications.
    • For more information about NIH Public Access Compliance for publications, please visit our LibGuide. 
  • All grants awarded after January 25, 2023 are required to have a Data Management and Sharing Plan to help increase the availability of NIH-funded data, as appropriate. 
    • For more information about the 2023 NIH Data Management and Sharing Policy, please visit our LibGuide. 

Updates to NIH Policy in Response to the Nelson Memo

As a consequence of the 2008 NIH Public Access Policy, all peer-reviewed scholarly publications that are the Icon of a sheet of paper with horizontal lines representing text, depicted in black and white.result of NIH awards are required to be made publicly-available in PubMed Central. The major change to this policy that will go into effect for publications accepted on or after December 31, 2025 is that these publications can no longer be embargoed for up to a year after publication. These publications are required to be made available immediately on the official date of publication, which is newly-defined as "the date that the final published article is first made available [emphasis mine] in the final, edited form, whether in print or electronic (i.e., online) format" 2024 NIH Public Access Policy. 

As a result of the 2023 NIH Data Management and Sharing (DMS) Policy, scientific data that are the result Black-and-white icon of a magnifying glass with a horizonal line with two peaks within the magnifying glass view.of NIH funds are to be made publicly-available (as appropriate) either at the time of publication or by the end of the grant performance period, whichever comes first. For the most part, the NIH has not needed to modify or update their 2023 DMS Policy in response to the 2022 Nelson Memo. Their policy meets the requirements for the public access of data established in the Memo. 

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Publications: When a publication is deposited into PubMed Central, the National Library of Medicine (NLM) already has a system in place to collect metadata and assign a persistent identifier (PID) to each article. 

  • According to the December 2024 "Plan to Increase Findability and Transparency of Research Results...", the NIH plans to require senior or key personnel to use ORCID iDs when depositing manuscripts into PubMed Central for Public Access Compliance (p. 4). As of April 2025, we are still waiting for additional information about implementation of this requirement into NIHMS. 

Scientific Data: As part of the 2023 NIH Data Management and Sharing Policy, researchers are required to follow specific guidelines when depositing their scientific data into repositories to ensure that they are findable through reliable persistent identifiers like a DOI. 

  • According to the December 2024 "Plan to Increase Findability and Transparency of Research Results...", researchers are encouraged to follow best practices for providing metadata when submitting data into repositories. The NIH will also expect that researchers will include ORCID iDs, names, and affiliations for key and senior personnel and the funding sources when depositing NIH-funded data into repositories (p. 5). 

Researcher Digital Persistent Identifier: In 2019, the NIH began requiring all researchers supported by federal funds to obtain an ORCID, which is a researcher digital persistent identifier. 

PIDs for Grants & Awards: The NIH currently assigns a unique identifying number to all grants and awards. However, the agency recognizes in the 2023 Request for Information in response to the Nelson Memo that "they are not registered or indexed to ensure uniqueness beyond NIH and they are not retrievable using a standardized communications protocol that would allow for interoperability". In other words, the current system for identifying grant numbers within the NIH does not meet the standards to persistently identify grants. Consequently, the NIH is exploring assigning a digital object identifier (DOI) system to grants and awards to address this issue.