NIH Public Access Policy and Manuscript Submission: How to Comply

The NIH has a number of resources further explaining their policy and processes:

To comply with the Public Access Policy:

1. Determine if the Policy Applies to Your Publication
2. If policy applies, determine submission method
3. If journal does not handle the submission for you, submit author accepted manuscript to NIHMS
4. Include PMCIDs in Citations that are Reported to the NIH in Grant Reports via eRA Commons

Notes:

Policy applies to

• Peer-reviewed journal manuscripts arising from NIH funding
  • even if the specific study was not funded by NIH, it still falls under the policy if you were receiving a stipend or salary from NIH when the work was done
  • even if the research was only partially funded by NIH
  • even if the article is available for free on the publisher's website or in an open access journal it must also be deposited in PubMed Central

There are multiple methods of submission to PubMed Central, depending primarily on your choice of journal.

• Find out more about submission methods

Before choosing a journal in which to publish your NIH funded work, make sure the journal policies allow you to comply with the NIH Public Access Policy.

• Find journal compliance policies.

Authors are responsible for compliance with the policy. You must make sure that all publication agreements that you sign will allow you to submit your manuscript to PubMed Central. When submitting the manuscript to a journal, make the editor aware that the work was NIH funded and needs to comply with their public access policy. 

The NIH provides sample language that can be used to transparently communicate this with the editor: NIH Guidance for Communicating Rights in Submitted Manuscript

The NIH previously stated that it had not yet encountered a publisher that refused to comply with NIH policy. However, this does not mean that you won't encounter one going forward. The 2024 policy no longer allows for an embargo period, but many journals still impose one. See the Journal Policies section of this guide for more information on the relevant policies of some major publishers.

Some publishers are now instituting fees (e.g., Article Development Charge) to authors needing to make their publication available immediately upon publication with no embargo, aka Zero-Embargo Green Open Access. While this charge should be less than the Article Publishing Charge (APC) fees associated with publishing Gold Open Access, they can still be substantial.

Authors Alliance addresses many questions authors have related to the new NIH policy: https://www.authorsalliance.org/2025/06/06/the-nih-public-access-policy-qa-for-authors/

Contact the NIH at PublicAccess@nih.gov for more information and assistance. 

The use of MyBibliography allows the user to link articles both in and outside of PubMed to grants, to easily view compliance status on all articles, and to rapidly generate lists of articles by grant award in pdf format. All grant-linked articles in My Bibliography are automatically imported into eRA Commons. Also, once a grant has been linked to a citation in MyBibliography for one author, the grant association to the citation will automatically appear linked in the MyBibliography of all authors. This is extremely helpful for articles which did not originally cite the grant award.

To use MyBibliography:

1. Sign up for a MyNCBI Account, utilizing your eRA Commons login.
2. Enter citations into MyBibliography within MyNCBI.
3. Manage compliance with the Public Access Policy for each citation in MyBibliography.
4. Assign grant numbers to citations in MyBibliography.
5. Generate compliance report for your RPPR.

Note that it NOT necessary for an article to be in PubMed and have a PMID for compliance. An article that is not in PubMed can be added to MyBibliography and linked to a grant award. The requirement for compliance is that the article is in PubMedCentral and has a PMCID. See the "PMCIDs" section of this LibGuide for more information on the difference between a PMID and a PMCID.