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Department of Statistics

NIH Public Access Policy

The NIH Public Access Policy went into effect in April 2008 with the goal of making the results of research funded by the National Institutes of Health (NIH) accessible to the public. Full details on the policy may be found at the policy website; the purpose of this page is to provide only a summary of some key features and requirements of the policy that directly affect faculty, students, and staff in the Department. If you are an investigator on a NIH grant, a student who is supported on a research assistantship or traineeship on a NIH grant, or a staff member who deals with faculty and students funded on NIH grants, you should read this in full and then visit these websites and familiarize yourself with the policy.

If you are not funded by NIH, do not think that this does not apply to you; similar requirements will be coming to other funding agencies, as directed in a White House Office of Science and Technology Policy memo released in February 2013.

What does the policy require? The policy requires that all papers accepted in a peer-reviewed journal that were supported all or in part by NIH funding be deposited in an archive called PubMed Central (PMC). PMC contains the full text of all such papers in a common format, and the full text is fully accessible to the public. Papers must be deposited within three months of publication. A paper deposited in PMC is assigned a unique PMCID number, which is used to identify it (see below).

What is the difference between PubMed and PubMedCentral? PubMed and PubMed Central are NOT THE SAME. PubMed is an archive of citations and abstracts of virtually every article published in health sciences-related journals. It does not contain full text, and is meant only as a bibliographic research resource. PubMed Central contains the full text and is meant to make research results accessible to the public. Accordingly, if a paper is indexed in PubMed and has a PMID number, this DOES NOT satisfy the public access policy. The PMID and PMCID number are NOT THE SAME, so if a paper has a PMID number, this does not mean it has a PMCID number. A paper that satisfies the public access policy MUST have a PMCID number.

Why is the PMCID number so important? As of July 1, 2013, principal investigators (PIs) of NIH grants must report publications resulting from the grants in their annual progress reports or grant renewal applications using a system called My NCBI. Papers must be reported and linked electronically to the progress report or renewal application using the PMCID number (or something called the NIHMSID number; see below). If a paper is not in PMC and does not have a PMCID or NIHMSID number, it cannot be reported. Furthermore, if a paper that was supported by NIH funding is not reported, it is noncompliant and is in violation of the public access policy and federal law (see below).

What happens if a paper is not deposited within the three month limit? Unlike NSF, NIH awards funds on a year-to-year basis. E.g., for a three year grant, the first year of funding is awarded initially. Two months before the start of the second year, the PI is required to submit a progress report; if this is satisfactory, the second year of funding will be awarded, and similarly for the third year. If a paper is deposited outside this limit, My NCBI will flag it in the progress report as being noncompliant. If a paper is not deposited at all and is flagged by NIH, it is also noncompliant. As of July 1, 2013, if a PI submits a progress report that contains noncompliant paper(s) or otherwise has papers that have not been reported, the next year’s funds will be withheld, and the PI will be required to submit an explanation. Only if the explanation is accepted will the funds be awarded.

How are papers deposited in PMC and PMCID numbers assigned? Papers are deposited through a web portal called the NIH Manuscript Submission (NIHMS) system. The final manuscript version of the paper, i.e., the final version prepared by the authors and accepted by the journal, is the version that should be deposited. It is generally a violation of most copyright agreements for the final publisher’s pdf version, i.e., the typeset version created by the publisher, to be deposited. If there is supplementary material, it must also be deposited.

There are two main ways deposits can take place:

  1. Many journal publishers will deposit the accepted final manuscript version and supplementary material as a courtesy to authors. In general, authors must inform the journal at the time of acceptance that the paper is subject to the NIH public access policy. If the journal allows grant numbers to be acknowledged in the manuscript, you should include these in the final version, e.g., R01 CA012345; this is not only required by NIH, it is also an additional prompt to the publisher that the paper is subject to the policy. Some publishers are very good about doing this in a timely fashion, while others say they will do it and don’t. It is the responsibility of the PI to ensure that, if a publisher is to deposit the paper, the publisher actually does it.
  2. If the journal does not deposit on behalf of authors, they must do it themselves.

In either case, one of the authors of the paper MUST be able to login to the NIHMS system. For most of us, this will be through having a valid NIH eRA Commons login. If you are PI of a NIH grant, you have this credential already; if you are a student or faculty member and don’t, you can request it from, for example, the College of Sciences Research Office.

If the paper is deposited by the publisher, one of the authors will be designated as the “approving author.” The approving author will receive an email from the NIHMS system instructing him/her to login to the system and approve the deposit. Warning: Publishers often choose the corresponding author to be the approving author or they choose an author arbitrarily. This can be a major problem if the chosen author does not have access to the NIHMS system or has changed positions and has a defunct email address. It is a good idea to request the author to be designated the approving author at the time of acceptance; however, be aware that many publishers may ignore this anyway. You will need to follow up with the production editor for the journal if one of the authors does not receive an email within a month or so.

Some authors go ahead and deposit on their own even if the publisher does it; however, this results in a “double deposit” that may cause problems later. It is best to let the publisher do this if it is their practice, but you must be diligent and follow up to make sure it happens. This can be exceptionally frustrating, and you must keep after the publisher.

When a paper is deposited in the NIHMS system, it is assigned a NIHMSID number. This is a temporary number by which the paper is identified until it is placed in the PMC format and a PMCID number is assigned. Once it is placed in this format, the approving author will receive another email prompting him/her to enter the NIHMS system to approve the formatted version of the paper. Papers are released into PMC once a number is assigned, but they may not be accessible right away. Journals are allowed to impose an “embargo period,” which may range from 0 to 12 months after the paper is actually published, when the paper is not accessible. The embargo period is often given on the copyright form and is either set by the publisher (method 1) or by the submitting author (method 2).

What are my responsibilities?

  • If you are the PI of any grant from NIH (R01, R03, R21, T32, etc), you are responsible for ensuring that all papers resulting from these awards are deposited. For research grants, you must make sure that all of your investigators are aware of the need to follow this policy and that they inform you of any papers on which they are authors. For a T32 training grant, any publications on which trainees are authors are also subject to the policy.
  • If you are an investigator or student supported or formerly supported on a NIH grant, you should inform the PI of any papers on which you are author that (i) you worked on while being supported and (ii) that have been accepted that s/he may not know about and be prepared to assist in making sure the papers are deposited and compliant.