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NIH Public Access Policy: How to Comply

Step by step instructions regarding new NIH law for Yale staff, faculty, and researchers- provided by the Yale Medical Library.

The New NIH Public Access Policy

Overview

As of July 1, 2025, the 2024 NIH Public Access Policy requires that on the date a scholarly article based on research funded by the NIH is published, a peer-reviewed, full-text version of that article must also be accessible to the public on PubMed Central (PMC). This change means researchers are responsible for ensuring public access to research earlier than ever before to comply with NIH funding requirements. While the previous NIH Public Access Policy (2008) also required authors to make their NIH-funded publications available in PMC, it allowed an embargo period of 12-months before the publications were publicly accessible. That embargo period is removed with the implementation of the 2024 NIH Public Access Policy on July 1, 2025, an implementation date  which was announced in an NIH notice on April 30, 2025.


How to Comply

All of your papers that fall under the 2024 NIH Public Access Policy must include evidence of compliance in your NIH applications and reports. Please note that the language of many NIH websites has not yet been updated to reflect changes effective as of July 1, 2025.

  • Determine Applicability - Does the 2024 NIH Public Access Policy apply to your paper?
     
  • Address Copyright - Ensure your publishing agreement allows the paper to be posted to PubMed Central in accordance with the 2024 NIH Public Access Policy.

 

  • Submit Paper - Submit papers to PubMed Central and agree to the revised Manuscript Submission Statement  associated with the 2024 NIH Public Access Policy, which gives the NIH the right to post your accepted manuscript without embargo. Please see the How to Submit tab in this guide for step-by-step instructions.

 

  • Include PMCID in Citations - Include the PubMed Central ID (PMCID) at the end of the full citation in your application or report.
    You do not need to find PMCIDs for all articles in an NIH grant application, proposal or progress report. You only need to include the PMCID when citing applicable papers that you author or that arise from your NIH-funded research.

Inside the 2024 NIH Public Access Policy:

  • Background: The 2024 NIH Public Access Policy was drafted to replace the 2008 NIH Public Access Policy to meet the expectations of the 2022 Nelson Memo issued by the White House Office of Science and Technology Policy (OSTP).
  • Responsibility: Authors are directed to stake steps to comply with the policy; the Policy also states that "compliance with the policy is the responsibility of the institution".
  • Budgeting: The Policy directs authors and institutions to the NIH's Guidance on Publication Costs.
  • Two versions of an article are defined:
    • Author Accepted Manuscript: A final peer-reviewed manuscript, upon author notification of acceptance by a journal.
    • Final Published Article: The journal's authoritative copy. This is a version produced later in the publishing process than the Author Accepted Manuscript, and exhibits further changes due to copyediting, stylistic edits, and formatting processes.
  • Three requirements of the Policy are listed:
    • Acknowledge NIH funding in the manuscript (also required by the 2008 Policy).
    • Submit the manuscript to PMC upon acceptance for publication (also required by the 2008 Policy).
    • License the NIH to make the manuscript publicly available upon the publication date, with no embargo (new requirement of the 2024 Policy).
  • Some scenarios are addressed:
    • When an article has been submitted to PMC and needs to be reported before a PubMed Central Identifier (PMCID) has been assigned, an NIH Manuscript Submission Identifier (NIHMSID) may be used.
    • When an article is only partially the result of funding by the NIH, the Policy still applies.
    • Author Accepted Manuscripts may also be deposited in institutional repositories.

Questions?

If you have any questions or need help complying with the NIH Public Access Policy, please contact the Cushing/Whitney Medical Library at AskYaleMedicalLibrary@yale.edu.