This page provides guidance for the University of Arizona community about impacts on the sharing of articles, data, and other information produced as part of funded research for specific agencies as a result of the 2022 Public Access memorandum from the Office of Science and Technology Policy (OSTP). The memorandum directed all US federal agencies to implement plans for how they will ensure free, immediate, and equitable access to federally funded research.
The current federal funding agency landscape is in a state of rapid change and disruption and the information on this page may change without notice. We recommend consulting the resources provided by the funding agencies as well.
This guidance is specific for each funder and generally includes:
- The effective date
- The requirements for making articles publicly available
- The requirements for making data and other research products publicly available
- Copyright (where available)
- Additional guidance (where available)
- External resources (where available)
Abbreviations:
- AAM = Author's Accepted Manuscript (final, peer-reviewed manuscript prior without the journal's formatting and processing).
- PMC = PubMed Central
- PID = Persistent Identifier
- DOI = Digital Object Identifier (a kind of PID)
Below are specific details about agency policies that have been released to date.
Effective date: Dec. 31, 2025
Publication requirements:
- ACF will use PubMed Central (PMC) as the agency’s public access repository for research publications.
- Grantees will be required to deposit the most permissible version of their manuscript in PMC. This may be the Author Accepted Manuscript (AAM) if the article is not published open-access, or the Final Version of Record if published in an open access journal.
- Reasonable costs may be written into the grant or contract for ACF coverage of article processing charges (APCs), to publish in open access journals.
Data requirements:
- Research data produced by ACF grants and contracts will be required to be published in a repository regardless of having a companion peer reviewed publication.
- Research data produced by ACF grants and contracts will be required to be made publicly available by publication in a data repository, when permissible, by either a) the time of article publication if underlying a peer reviewed manuscript or b) the end of the grant or contract period.
- ACF research grantees and contractors will be required to submit a Data Management Plan (DMP) prior to start of their research study.
- Research data that can be made publicly accessible will be required to be published in a data repository that meets the desirable characteristics outlined in the OSTP Desirable Characteristics of Data Repositories for Federally Funded Research, assigns a DOI for each published dataset, and meets Section 508 accessibility standards.
- Data curation, publication, and preservation costs should be written in to grants and contract budgets as justifiable costs.
Copyright:
- ACF reserves a royalty-free, nonexclusive and irrevocable right to reproduce, publish, or otherwise use agency funded peer reviewed publications for federal purposes, and to authorize others to do so. ACF-funded Authors should avoid signing any agreements with publishers that do not allow for a version of the manuscript to be deposited to PMC, in accordance with the ACF Public Access Policy.
- Sensitive data that cannot be made publicly available and proprietary data with legal restrictions are excluded from this plan.
Additional guidance:
- ACF-funded research grantees and contractors will be required to report any peer reviewed manuscripts accepted for publication in their annual and final reports (grantees) and through agreed upon mechanisms in ACF research contracts, noting compliance with the ACF Public Access Policy.
External resources:
Effective date: Dec, 31, 2025. Applies to ACL-funded extramural research under initial awards made on or after December 31, 2025.
Publication requirements:
- ACL uses PubMed Central (PMC) as its designated peer-reviewed publications repository
- All peer-reviewed publications generated from ACL-funded research must be publicly available via PMC upon the official publication date, with no embargo.
- Authors must include a statement acknowledging ACL as a funding agency, along with the award number in the full text of the publication.
Data requirements:
- Underlying scientific data must be made publicly available when the accompanying peer-reviewed publication is made publicly available.
- All Scientific data, in complete datasets, must be publicly available no later than 24 months after an award’s end date. While an embargo is allowed for up to 24 months, awardees must deposit the datasets within 90 days of the end of the award and provide a Digital Object Identification (DOI) of each data set in their Final Performance Report.
- ACL designates the Interuniversity Consortium for Political and Social Research (ICPSR) as its preferred data repository for scientific data from all ACL-funded research.
- ACL-funded awardees may include justification and evidence that support their request to use a different repository in the data management plan submitted as part of the original proposal.
- ACL awardees who work with secondary data are not required to share such data. However, they are required to share sources of the secondary data, and any algorithm or formulas used to derive unique variables from such data for the purpose of ACL-funded research.
- The following types of data are excluded from the current data sharing requirements: personally identifiable data, proprietary trade data, and other data whose release is limited by law, regulation, security requirements, or policy.
- ACL requires that applicants for all applicable ACL grants, cooperative agreements, contracts, and other types of awards submit a data management plan.
Copyright:
- Authors must maintain necessary rights to share their final manuscript with the public via PMC with an appropriate level of Creative Commons or equivalent license that will allow the re-use of the publications with appropriate attributions.
Additional guidance:
- ACL awardees are required to report any peer-reviewed manuscripts that have been accepted for publication in their annual performance reports and final reports.
- ACL requires supported investigators to report their submission of scientific data to ICPSR or an equivalent repository. These submissions must include a DOI for each dataset. Awardees are required to report the date that the data will be released within 24 months after the award’s end date. Awardees will be required to report this information in the Final Report for each award.
External resources:
Effective date: TBA (“upon finalization of the policy”)
Publication requirements:
- Requires all taxpayer-funded scientific studies to be immediately available to the public for free and full use.
- All peer-reviewed scholarly publications funded by CDC, regardless of the funding mechanism used (e.g., grant, cooperative agreement, contract).
- All peer-reviewed scholarly publications authored or co-authored by CDC employees as part of their official duties and by non-employees working under agreements with CDC, but consistent with their underlying agreement with CDC.
- Peer-reviewed, accepted manuscript (post-peer-reviewed version accepted for publication) must be made available on PubMed Central and CDC Stacks.
- Submit to PubMed Central using the National Institutes of Health Manuscript Submission (NIHMS)
Data requirements: Forthcoming
Additional guidance:
- Budgets associated with these awards should include allowable expenses, reasonable publication costs, and costs associated with submission, curation, management of data, and special handling instructions. Such costs may be deemed allowable and consistent with applicable grant or acquisition regulations, policies, and the relevant grant, cooperative agreement, or contract award.
External resources:
Effective date: Dec. 31, 2025
Publication requirements:
- Applies to any peer-reviewed manuscript accepted for publication in a journal on or after 12/31/2025.
- CMS-funded researchers are required to submit to CMS their final, peer-reviewed manuscripts upon acceptance for publication to be made publicly available at the time of publication via the National Library of Medicine’s PubMed Central (PMC)
- In lieu of the final peer-reviewed manuscript, CMS will accept the final published article, provided the authors can ensure CMS has the rights to make the published version public.
- Prior to submitting a manuscript for publication, CMS-supported extramural researchers will be required to notify CMS of their intent to publish as well as their plan for providing free, immediate access to the publication by sending an email to PublicAccessPolicy@cms.hhs.gov.
- CMS-supported researchers are required to deposit, or have deposited on their behalf, the final peer-reviewed manuscript to CMS via email (PublicAccessPolicy@cms.hhs.gov) at the time of acceptance for publication in a journal. CMS will make the manuscript accessible in PMC via the National Institutes of Health Manuscript Submission (NIHMS) system.
- CMS will consider compliant those CMS-supported researchers who choose to publish in journals that already have formal agreements with NLM to submit final published articles to be available in PMC at the time of publication.
- Publication costs, including article processing charges often associated with open access publishing, may be charged to CMS grants and contracts with prior approval by CMS.
Data requirements:
- Scientific data underlying peer-reviewed scholarly publications resulting from federally funded research will be made freely available and publicly accessible by default at the time of publication.
- Digital scientific data that is outside the scope of this policy include:
- Personally identifiable data (however, CMS will work toward increasing access to research data by creating de-identified public use data files);
- Proprietary or commercially sensitive data;
- Data related to protecting critical infrastructure;
- Other data for which disclosure is limited due to applicable laws, regulations, privacy or security requirements or CMS policies.
- All CMS-funded researchers will be required to submit to CMS a data management and sharing plan for sharing de-identified final research data in a digital format, or state why data sharing is not possible. This plan must be submitted at the start of the CMS-funded research award or project
Copyright:
- CMS-supported authors must retain rights to the final peer-reviewed manuscript, regardless of the pathway to publication, to ensure that their CMS-supported research can be made freely available at no cost and publicly accessible without any embargo or delay after publication.
External resources:
Effective Date: December 31, 2025
Publication requirements:
Per the Implementation Plan:
- DoD seeks to ensure that publications documenting the results of DoD-funded research are:
- Available without embargo or delay.
- In machine-readable format. DoD will investigate methods to convert articles in Word or PDF format to ANSI/NISO Z39.96-2021, Journal Article Tag Suite (JATS) format. DoD will also investigate whether such conversion services are available for commercial purchase.
- Broadly accessible through assistive devices.
- DoD policy will not direct a specific open access publication model (green, gold, diamond, etc.)
Data requirements:
- DoD plans to adopt, through appropriate guidance and policy, a systematic approach to ensure:
- Scientific data underlying peer-reviewed scholarly publications will be publicly accessible by default at the time of publication consistent with law, regulation, and DoD policy.
- Data sets will be accompanied by metadata that describes the data in sufficient detail to support analysis and reuse.
- Metadata describing data sets will be freely available for reuse to include downloading, analysis, and data or text mining.
- For extramural researchers, DOD will issue guidance on where data is to be deposited that is aligned with the National Science and Technology Council’s Desirable Characteristics of Data Repositories for Federally Funded Research
Data management plan: yes. See Enclosure 3, section 3c of instruction 3200.12.
Copyright:
- Consistent with law, regulation, and DoD policy, publications and data sets produced by intramural researchers will be released to the public for reading, downloading, and use for analysis and data or text mining without any embargo or delay.
- Data and reuse rights will be consistent with Title 17, United States Code, and government license rights in intangible property as determined by the terms and conditions of contract or award instruments.
Additional guidance:
- Persistent Identifiers (a/k/a Digital Persistent identifiers) will be required for:
- Research output, including data sets and scholarly publications (DOIs)
- Individuals, including authors and principal investigators (such as ORCID)
- Scientific research and development awards and intramural research protocols (when an appropriate web-based resource infrastructure for awards and intramural research protocols is identified or created)
External resources:
Effective Date: October 1, 2025
- Fiscal Year 2025 (i.e., 10/1/2025 – 9/30/2026) will serve as a transition year for making scholarly publications immediately available. Accepted manuscripts should be submitted as soon as possible and DOE will monitor efforts as grantees transition from the previous 12-month embargo period.
Publication requirements:
- Peer-reviewed scholarly publications to be made available without any embargo or delay after publication in DOE’s PAGES repository
- Other research outputs including conference tasks, scientific software, technical reports, books/monographs, theses/dissertations, and technical workshop reports to also be made publicly available
- Submission of metadata associated with research outputs
Data requirements:
- Scientific data underlying publications to be made available at the time of publication
- Other research outputs including conference tasks, scientific software, technical reports, books/monographs, theses/dissertations, and technical workshop reports to also be made publicly available
- Submission of metadata associated with research outputs
Data management and sharing plan requirement: yes (guidance forthcoming)
Copyright:
DOE grantees will also be required to include this rights notice in their accepted manuscripts:
- “This manuscript has been authored by [insert the name of the Contractor] under Contract No. [insert the contract number] with the U.S. Department of Energy. The United States Government retains and the publisher, by accepting the article for publication, acknowledges that the United States Government retains a non-exclusive, paid-up, irrevocable, world-wide license to publish or reproduce the published form of this manuscript, or allow others to do so, for United States Government purpose.”
Additional guidance:
- Persistent identifiers for:
- Accepted manuscripts or journal articles
- Scientific data underlying publications
- Technical reports with no distribution limitations
- Scientific software with no distribution limitations
- Persistent identifiers for researchers (both DOE federal and contractor employees conducting R&D work) that meet the common/core standards specified in the NSPM-33 Implementation Guidance (e.g., ORCID iD)
External resources:
Effective Date: Awards made on or after October 1, 2025
Publication requirements:
- A machine-readable copy of the published manuscript (either the Author’s Accepted Manuscript or the Version of Record) to be submitted to the IMLS-designated repository without embargo. This applies to publications and may include peer-reviewed book chapters, editorials, and conference proceedings.
- IMLS has yet to announce the agency-designated repository
Data requirements:
- Data underlying publications to be deposited immediately upon publication into an appropriate repository of the researcher’s choice.
Copyright:
- IMLS award recipients may copyright any work that is subject to copyright and was developed, or for which ownership was acquired, under the award. Under that provision, IMLS reserves a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use the work for federal purposes, and to authorize others to do so. This includes the right to require recipients and sub-recipients to make such works available through agency-designated public access repositories.
- IMLS encourages recipients, upon submission of an applicable peer reviewed scholarly publication, to communicate to the journal or publisher that the article is subject to the IMLS Public Access Policy, under which IMLS, as the funding agency, is permitted to make the most-appropriate version of the manuscript publicly available without any embargo or delay upon publication.
External resources:
Effective date: December 31, 2025
Publication requirements:
- Peer-reviewed publications and the associated metadata to be made freely available at the time of publication in NASA’s designated repository, PubSpace.
- Researchers can either submit their accepted manuscripts directly to PubSpace or publish with a journal that has an agreement with NASA to deposit the Version of Record in PubSpace (e.g., journals that are part of CHORUS).
Data requirements:
- Scientific data underlying publications to be made freely available and publicly accessible by default at the time of publication.
- The data must also have a persistent identifier, use metadata standards, and be shared in a repository designated by the appropriate NASA program or meet the guidelines provided by the Desirable Characteristics of Data Repositories for Federally Funded Research.
- Requires scientific software underlying peer-reviewed publications or used to support data analysis to be made freely available and publicly accessible by default at the time of publication.
Data management plan requirement: yes. Refer to p. 9 of the public access plan.
Copyright
- For authors who wish to publish in an open access journal, NASA allows all Article Processing Charges (APCs) to be included in the grant proposal budget.
- Researchers should deposit their NASA-funded publications in the NASA PubSpace collection within the NASA Technical Report Server (NTRS)
- The final published article may appear in the CHORUS repository (where appropriate), the ADS archive, or the STI repository.
- NASA intends for researchers to pay reasonable costs to publish an article as open access
- NASA states it may make funding conditional upon awardees granting the Government a broad license that enables the repository to transfer more limited rights to users of publications drawn from the repository (i.e., the Federal Purpose License) OR it may require that grantees, through award terms, ensure publishing agreements allow for the deposit of accepted manuscripts into PubSpace.
External resources:
Effective date: Applies to all new awards made on or after October 1, 2025
Publication requirements:
- Recipients must submit a copy of the author’s accepted manuscript (AAM) for any peer-reviewed scholarly article resulting in whole or in part from award activities. Recipients must submit a copy of the AAM to NEH no later than the article publication date, defined here as the date the final publisher’s version is available online. NEH will deposit each article in a free and publicly available designated repository. (Submission instructions still TBA.)
Data requirements:
- Programs Requiring Data Sharing:
Data management and sharing plan requirement: yes. Must detail expected points of access and preservation. DMSPs should follow both the FAIR Principles and the CARE Principles for Indigenous Data Governance.
Copyright:
- Consistent with 2 CFR § 200.315(b), award recipients may copyright any work that is subject to copyright and was developed, or for which ownership was acquired, under the award. Under this provision, NEH reserves a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use the work for federal purposes, and to authorize others to do so. This includes the right to require recipients and sub-recipients to make such works available through agency-designated public access repositories.
- NEH encourages recipients, upon submission of a manuscript, to communicate to the journal or publisher that the article is subject to the NEH Public Access Policy, under which NEH, as the funding agency, is permitted to make the author’s accepted manuscript publicly available without embargo upon publication.
External resources:
Effective date: 7/1/2025
Publication requirements:
- Upon accepting NIH funding, recipients grant to NIH the right to make Author Accepted Manuscripts resulting from the funding publicly available in PubMed Central upon the Official Date of Publication
- The NIH Public Access Policy applies regardless of whether the NIH-funded principal investigator or project director is an author and regardless of whether non-NIH funds contributed to developing or writing the Author Accepted Manuscript.
- Journal or publisher fees that arise during the course of the publication process for the sole purpose of submitting the Author Accepted Manuscript to PubMed Central are not allowable costs. Compliance with the Policy does not require the payment of an open access fee to a journal.
Data requirements:
- The 2023 policy requires ALL grant applications or renewals that generate Scientific Data to include a robust and detailed plan for data will be managed and shared during the entire funded period. This includes information on data storage, access policies/procedures, preservation, metadata standards, distribution approaches, and more. This information must be provided in a data management and sharing plan (DMSP).
- Shared Scientific Data should be made accessible as soon as possible, and no later than the time of an associated publication, or the end of performance period, whichever comes first.
- Data should be shared data in an appropriate NIH-supported or generalist repository. When selecting a repository, consult the NIH's list of desirable characteristics.
- Compliance will be tracked via specific questions in the Research Performance Progress Reports (RPPRs).
Copyright:
- Under the Government Use License (2 CFR 200.315), the NIH “reserves a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use the work for Federal purposes and to authorize others to do so.”
- NIH encourages authors to be clear with journals and publishers to ensure journals and publishers understand that NIH has a right to make Author Accepted Manuscripts publicly available upon the Official Date of Publication.
- Authors are not expected to provide rights to NIH to the Final Published Article
Additional guidance:
- NIH encourages authors to be transparent during the journal submission process by indicating to the journal that should the submitted manuscript be accepted, the Author Accepted Manuscript must be made publicly available in PubMed Central upon the Official Date of Publication.
- NIH provides the following sample language that may be included in the Submitted Manuscript and then, should the submission be accepted, the Author Accepted Manuscript:
- “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.”
- Publication costs (such as article processing charges for open access publication) are allowable when they comport with the existing NIH cost principles GPS 7.2 and GPS 7.9.1. Cost principles clarify when costs should be allocated as direct versus indirect costs, and they clarify charges and fees that are allowable.
- If, during the course of the publication process, an author is asked to pay a fee for submission of the Author Accepted Manuscript to PubMed Central, such costs are not allowable.
- Institutional oversight of data sharing
- PIs are ultimately responsible for ensuring the DMSP is executed.
- HSPP/IRB is responsible for ensuring that the sharing of data pertaining to human subjects is consistent between the DMSP and informed consent.
- PIs and Sponsored Projects and Contracting are responsible for ensuring appropriate data use agreements are in place before sharing sensitive data.
- If a PI chooses to deposit data into U of A's ReDATA repository to comply with the data sharing aspects of the DMSP, prior to making the data public, the repository is responsible for ensuring the data can be shared. The repository will collect an attestation from the PI that data has been deidentified (where applicable), and that proper consents and permissions have been obtained to share the data. Additionally, the repository will coordinate with the HSPP/IRB, Native Peoples Technical Assistance Office, or other offices as appropriate.
- PIs should contact their college's Associate Dean for Research if a program officer requests an institutional official that is not part of the research team to be responsible for data management and sharing in a DMSP.
External resources:
The information below is based upon the draft PAPPG released in late 2024. Updates will follow when the final version of the PAPPG is released later this year.
Effective Date: October 2025 (anticipated)
Publication requirements:
- Final versions of peer-reviewed manuscripts accepted for publication or juried conference proceedings (collectively referred to as the Author’s Accepted Manuscripts or AAMs) must be deposited in NSF’s Public Access Repository (PAR) along with the assigned PID/DOI if one exists for the Version of Record. If a PID/DOI does not exist for the AAM, minimal descriptive metadata must be provided manually.
- The deposit of AAMs does not require the payment of a special fee to publishers or other third parties, though grant recipients are allowed to use award funds to pay special fees to make the Version of Record publicly accessible.
- A minimum set of descriptive metadata elements should be provided with AAMs. NSF notes the metadata elements are normally generated with a PID. If a PID is not available, metadata must be manually entered.
Data requirements:
- Data underlying publications should be made freely available and publicly accessible at the time of publication in a repository that assigns persistent identifiers (PIDs). The assigned PID must also be recorded in NSF’s PAR repository.
- A minimum set of descriptive metadata elements should be provided with datasets. NSF notes the metadata elements are normally generated with a PID. If a PID is not available, metadata must be manually entered.
- Software and curriculum material should also be publicly shared within a reasonable timeframe.
- Repositories used for public archiving of research data should conform to the Desirable Characteristics of Data Repositories for Federally Funded Research, when possible
Data management and sharing plan requirement: yes. The DMSP is to be prepared using an online form in research.gov
Copyright Guidance:
- NSF reserves the non-exclusive rights to works resulting from agency-funded research under the Federal Purpose License.
- NSF normally allows recipients to retain principal legal rights to intellectual property developed under NSF awards to provide incentives for development and dissemination of inventions, software and publications that can enhance their usefulness, accessibility, and upkeep. However, whenever such incentives are not deemed pertinent, such material should be assigned permissive licenses that allow for public reuse. Further, these incentives do not reduce the responsibility that PIs and co-PIs and organizations have as members of the scientific and engineering community, to make results, data, and collections available to other researchers.
Additional guidance:
Persistent identifiers
- An ORCID iD is mandatory for Senior and Key Personnel in both the Biographical Sketch and the Current and Pending Support sections of proposals.
- PIDs of datasets must be entered in NSF’s PAR
External resources:
Effective date: December 31, 2025
Publication requirements:
- For journal article publications, all accepted manuscripts must be deposited in the internal USGS Information Product Data System (IPDS) repository at the time of publication.
- Journal articles are made publicly available free-of-charge by the publisher or the accepted manuscript archived in IPDS is made publicly available through the USGS Publications Warehouse at the time of publication.
Data requirements:
- All scientifically-relevant data, (data associated with a scholarly publication and the supporting data collected by the project) will be made available for public access, unless the Bureau determines that a demonstrated circumstance restricts the data from being made publicly available; for example, in cases where access must be restricted because of security, privacy, confidentiality.
- Data not subject to restrictions must be released prior to, or at the time of the release of the associated publication. For data not associated with a publication, it must be released at the end of the project.
- Data are to be submitted to the most appropriate USGS repository.
- Scientific data management requirements must be followed, including the development of data management plans (DMPs), which must be part of the approved USGS project plans.
- Scientific data approved for release are assigned a USGS digital object identifier.
Copyright:
- 2 CFR § 200.315 Intangible property provides the Federal awarding agency the right to reserve a royalty-free, nonexclusive and irrevocable right to reproduce, publish, or otherwise use any work that is subject to copyright and was developed, or for which ownership was acquired, under a Federal award for Federal purposes, and to authorize others to do so; and pursuant to 2 CFR 215.36 Intangible Property, the Federal government has the right to: (1) Obtain, reproduce, publish, or otherwise use the data produced under a Federal award; and (2) Authorize others to receive, reproduce, publish, or otherwise use such data for Federal purposes.
Additional guidance:
- Researchers are allowed to include reasonable costs associated with submission, curation, management of data/publications, and special handling instructions in research budgets.
- Researchers are required to obtain a persistent identifier and to include the identifier in published research outputs.
- USGS will develop a process for assigning persistent identifiers to scientific research and development awards and intramural research protocols to enable proper reference of funding source from metadata associated with publications and data.
External resources: