How to comply with the NIH's Public Access Policy

On April 30, 2025, the NIH released a notice that the 2024 NIH Public Access Policy would become effective on July 1st, 2025.

All PhD student and postdoctoral publications for individuals appointed to T32 training grants are subject to this NIH policy by virtue of their full-time ongoing stipend support.

If you are an investigator submitting a manuscript to the NIH for publication on or after July 1st, 2025, you must comply with this policy.

Previously, upon acceptance for publication, the NIH required that researchers submit their final peer-reviewed manuscripts to PubMed Central (PMC), to be freely available to the public, no later than an embargo period of 12 months after the official date of publication.

The new policy removes the allowance for an embargo period, and now requires all investigators to make their Author Accepted Manuscript (AAM) freely accessible on PubMed Central upon the official date of publication.

The new policy also requires:

1. Statement of acknowledgement of NIH as your funder in both the Author Accepted Manuscript and the Final Published Article during the Paper Submission Process to a Publisher. The Welch Library has suggested language for this statement:

   1. “This manuscript is the result of funding in whole or in part by the National Institutes of Health (NIH). It is subject to the NIH Public Access Policy. Through acceptance of this federal funding, NIH has been given a right to make this manuscript publicly available in PubMed Central upon the Official Date of Publication, as defined by NIH.”

2. When your Author Accepted Manuscript is submitted to the NIH, your agreement to a standard license that grants the NIH the right to make the Author Accepted Manuscript publicly available through PMC without embargo on the official date of publication.

We understand this policy is confusing. We welcome your input on your experience navigating the policy and suggestions on how to better explain the process. Please let us know what how we can improve at bsph.research@jh.edu.

There are several ways to ensure you comply with the new policy, some which are more simple than others, and some of which may not apply to you.

First, check if your journal is “compliant,” with the NIH policy, or select one that is (“compliance” means the journal will submit the AAM to PMC for you; see below). Publishers on the PMC Journal List are compliant.

Alternatively, publishers in the Selective Deposit Collection will deposit your Final Published Article into PMC upon request or special arrangement by the author.

If your journal is compliant with the new policy, the journal will submit the AAM on your behalf to the NIH Manuscript Submission System (NIHMS), which will route your AAM for publication on PMC. You (an author on the paper or a PI of the grant cited by the paper) will be prompted to approve the PMC version. Then, the article will be assigned a PMCID within 24 hours, and will appear in both PMC and PubMed.

If you are having trouble determining whether or not your journal is compliant, please contact the Welch library.

If your journal is NOT compliant with the new policy, it may be your responsibility to:

1. Pay an Article Processing Charge for the journal to submit the AAM to PMC without author involvement.

   1. In this case, the publisher may require one of these additional submission criteria are met:

      1. The article is published in a MEDLINE-indexed journal; or

      2. The article acknowledges support of a PMC designated funder or a member of the Europe PMC Funders Group.

2. Negotiate with the journal to come to an agreement regarding your ability to publish open access.**

   1. If this is the case, in order to comply with the new policy you must:

      1. Submit an electronic version of the AAM through the NIH Manuscript Submission System (NIHMS) to PMC. When you submit, indicate your article should be:

         1. Made publicly available

         2. Without embargo

         3. Upon the Official Date of Publication

• If your journal is not compliant with the new policy and you negotiate your responsibility to submit the article to PMC, it is best to submit your AAM to NIHMS as early as possible after acceptance of publication to ensure compliance; it can take several weeks from your article to be processed and issued a PMCID.

** Welch Library offers support regarding negotiating with your journal, including APC waivers for select journals.

Monitor your article through MyNCBI’s My Bibliography by linking your eRA Commons account.

Add your manuscript information as a new citation that is “forthcoming” in your MyNCBI’s My Bibliography. Once you receive a NIH Manuscript Submission identifier (NIHMSID), edit the status of your citation and add your NIHMSID number. A NIHMSID may be used temporarily in lieu of a PMCID for up to three months following the Official Date of Publication. After that, the PMCID is required.

Edit your citation manually in your MyNCBI’s My Bibliography and add your PMCID number upon receipt. The addition of your PMCID* number into your MyNCBI article citation is your verification of compliance.

• You may not be automatically notified your PMCID has been issued. If you are unsure if your PMCID has been issued, check by entering the DOI for your article into the PMC ID Converter. If the article is in PMC, the PMC ID Converter will return the PMCID.

*PubMed Central and the PMCID differs from PubMed. The NIH requires your PMCID to verify compliance.

If compliant, both the PMC version of the article and the journal’s final published version of the article will be available on the Official Date of Publication. However, the PMC version may differ from the final published version in copyediting, layout or formatting, and other changes the publisher may make. Notably, the NIH requires the AAM be peer-reviewed.

Review the Q&A from the January 7, 2026 Brown Bag session on the Public Access Policy:

Open

Find BSPH-created slides on how to comply with the Open Access Policy:

Open