Skip to main content

Full Library Hours
Available Equipment
Contact Us

Federal Agency Public Access Compliance

A Research Guide summarizing the Federal public access policies resulting from the US Office of Science and Technology Policy memorandum of February 2013.

Implementation Timeline: NIH

Publications Implementation: April 2008

Data Implementation: March 2002 (NIH Intramural Policy on Large Database Sharing), February 2003 (NIH Data Sharing Policy), October 2012 (NIH Grants Policy Statement). January 2015 (Genomic Data Sharing Policy)

  • NIH has already implemented policies that meet all of the objectives of the OSTP memorandum for publications and, for the most part, the objectives for digital scientific data.
  • NIH will explore whether additional steps are needed to achieve the fullest measure of public access to results of NIH-funded research. Should any policy changes be required, OSTP has set the end of calendar year 2015 as the date by which policies to fulfill the plan should be issued.


Compliance Monitoring: NIH

Publications Compliance Monitoring:

  • NIH staff manually checks applications, proposals, or reports for compliance with the Public Access Policy. They confirm that a citation includes the appropriate reference number that indicates compliance, such as the PubMed Central Identifier (PMCID). NIH has begun to automate this reporting process by integrating the NLM’s Bibliography tool, My NCBI, with our electronic grants management system. My NCBI tracks the public access compliance status of every paper associated with an award, generates a citation with the current identifier and clearly indicates its compliance status. It also allows awardees to collaborate with their colleagues to associate publications with NIH awards.
  • In November 2012, NIH announced that it will delay processing of all non-competing continuation awards (commonly called progress reports) with a start date of July 1, 2013, and beyond that are not compliant with the Public Access Policy. To simplify reporting and tracking, awardees now use My NCBI to report public access compliance on these awards. This process is fully electronic for our Research Performance Progress Reports (RPPR). My NCBI supports paper based progress reports by generating PDF reports of the publication section of paper forms.

Data Compliance Monitoring:

  • NIH’s current expectations for data sharing are communicated to intramural and extramural researchers through numerous guidance documents and outreach activities, and these are reiterated to funded researchers through the Notice of Award or the Contract Award.
  • NIH staff is responsible for monitoring and taking steps to ensure compliance with the terms and conditions of the award.
  • Data-sharing plans that are approved and made a term and condition in the Notice of Award or the Contract Award can be enforced. Accordingly, failure to comply with the terms and conditions of the funding agreement could lead to enforcement actions, including the withholding of funding.
  • To improve monitoring of grantee and contractor compliance, program staff overseeing extramural grants and contracts will review progress reports carefully for adherence with data management plans and policies.
  • Development of procedures for enhancing the discoverability of data sets, as part of the BD2K initiative, will provide an additional mechanism for monitoring compliance with data management plans by including a citable unique identifier that can be used to verify that novel data sets are registered in accordance with applicable NIH policy.
  • Under the intramural program, IC Scientific Directors will be responsible for carrying out a prospective review of intramural researchers’ compliance with data management policies and plans.
  • The Office of Intramural Research (OIR) plans to use its annual Management Survey of Scientific Directors to monitor overall compliance with data management and data-sharing expectations and policies developed to implement this plan.

Additional Compliance Monitoring:

  • Failure to comply with statutory requirements for submitting the results of applicable clinical trials to can also result in penalties specified in section 402(j)(5) of the Public Health Service Act.


Publication and Data Repositories: NIH

Publication Repository: PubMed Central

  • The NIH Public Access Policy requires scientists to submit final peer-reviewed journal manuscripts that arise from NIH funds to the digital archive PubMed Central (PMC) upon acceptance for publication.

Data Repository: NIH data repository or appropriate, existing, publicly accessible repository

  • NIH currently supports numerous data repositories for a range of research fields and data types. Many NIH program-level data sharing policies expect deposition of data in existing repositories.
  • NIH will expect funded researchers to deposit data in appropriate, existing, publicly accessible repositories before considering other means of making data available.
  • NIH will work to ensure that NIH repositories are designed to minimize the burden of submitting data and will consider whether enhancements to existing archives are needed to accommodate the deposition of additional data.
  • To help researchers find an appropriate repository to accept their data, NIH will expand its database of existing repositories. NIH plans to develop guidance and criteria to aid researchers in identifying acceptable repositories not funded by NIH.



What is the embargo period for publications and datasets?

12 months for publications.

  •  The Policy requires that NIH supported papers are accessible to the public on PMC no later than 12 months after publication.


Where can I find the full Public Access Policy?

Does this agency require a data management plan (DMP)?

Yes. NIH will ensure that data management plans include clear plans for sharing research data. NIH is taking steps to ensure all NIH funded researchers develop data management plans whether they are funded by a grant, cooperative agreement, contract, or intramural funds, regardless of funding level. 


How do I comply with the public access policy and submit a publication?

Manuscripts resulting from funded work must be submitted directly to the NIH Manuscript Submission System (NIHMS).


Where can I find more detailed information about the NIH Public Access Policy?

The Ebling Library Research Guide on NIH Public Access Policy Compliance.