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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: VA

Publications Implementation: December 2015

  • No later than December 31, 2015, the VA will require that all publications based on VA-funded research be made available to the public through the NLM PMC open public access web site within one year of the date of publication.

Data Implementation: December 2015

  • No later than December 31, 2015, the VA will require that all VA investigators include in their research proposals, a data management plan that describes how, where, and the extent to which they will make the data and results of their research available to the public and specifying what data will be available in machine readable formats.


Compliance Monitoring: VA

Compliance Oversight and Enforcement:

  • The VHA Office of Research Oversight (ORO) will be responsible for conducting compliance oversight and enforcement of VA’s policies for public access to scientific publications and digital research data resulting from VA-funded research.
  • Compliance oversight and enforcement of requirements for data access plans, access to publications from VA-funded research, and access to digital data from VA-funded research will be exercised under ORO’s independent statutory authority at 38 USC 7303 to monitor, review, and investigate matters of regulatory compliance in VA research, halt VA research where warranted, and require corrective actions to ensure compliance with all applicable requirements related to the conduct of VA research.
  • ORO will incorporate the VA’s research public access requirements into its existing compliance oversight inspection and enforcement programs.
  • As soon as they become effective on December 31, 2015, the requirements for data management plans (regardless of funding source) and access to publications and digital data from VA-funded research will be incorporated into ORO’s proactive onsite compliance reviews.
  • ORO’s annual Facility Director Certification of Research Oversight process, as well as ORO’s remote compliance reviews, compliance oversight tools, and technical assistance materials, will also be modified to ensure compliance with these requirements by VA investigators.
  • Facility Research Compliance Officer (RCO) annual and triennial audit requirements (whose findings must be reported to ORO) will be modified to include annual audits to confirm existence of the required data management plans and triennial audits to ensure investigator compliance with those plans.
  • ORO monitoring and compliance oversight programs will ensure that all identified noncompliance is documented, appropriate remedial action plans are developed, and remedial actions are implemented in a timely fashion to ensure compliance with VA data management and data access requirements.
  • Noncompliance with VA’s data management and data access requirements may result in loss of the investigator’s current and/or future research funding.

Additional compliance monitoring:

  • ORO will develop, annually compile, and track performance metrics for compliance with VA’s data management and data access requirements. ORO will monitor these metrics at the investigator, facility, network, and systems levels to identify trends and, where warranted, the need for interventions to ensure compliance. Findings will be made available to the public annually.


Publication and Data Repositories: VA

Publication Repository: PubMed Central

  • VA has established an agreement with HHS to make the results of ORD-funded research accessible to the public through the National Library of Medicine (NLM) PubMed Central (PMC) archive, a firmly established public-private partnership that currently provides access to publications of research supported by NIH. 

Data Repository: To be determined by December 31, 2015.



What is the embargo period for publications and datasets?

For publications, 12 months after publication in a journal.


Where can I find the full Public Access Policy?

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

Yes. All VA investigators conducting VA-funded research will be required to develop prospective data management plans for that research.(Effective date: December 31, 2015)


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

Investigators are responsible for depositing manuscripts in PubMed Central, operated by the National Institutes of Health's National Library of Medicine (NLM), upon the manuscripts' acceptance for publication. Manuscripts resulting from funded work must be submitted directly to the NIH Manuscript Submission System (NIHMS).