Office of Science and Technology (OSTP)/Nelson Memo (2022)

We want to inform the University of Arizona community about the impacts of the new memorandum from the Office of Science and Technology Policy (OSTP) that was published in August 2022. The policy directs US federal agencies to develop plans for how they will ensure free, immediate, and equitable access to federally funded research.

This page links to appropriate information and resources whenever possible and will be updated as new information becomes available. Please check back frequently.

Who is impacted?

The OSTP policy may impact several stakeholders, including:

  • Primary investigators
  • Research administrators
  • Academic leaders
  • Publishers
  • Librarians
  • Scholarly communications experts
  • Advocacy organizations

How federal agencies and stakeholders will respond to the policy is evolving.

What's new about the OSTP/Nelson Memo?

The 2013 Holdren Memo required federally funded researchers to make their research papers publicly available no later than 12 months after publication. This policy applied to agencies with research and development (R&D) budgets of $100 million or more and required researchers to develop data management plans.

The 2022 OSTP/Nelson Memo is now directing federal agencies with any level of R&D budget to create policies requiring that funded researchers provide immediate public access to research papers and data upon publication.

Here is a summary of the key differences:

2013 Holdren Memo 2022 OSTP/Nelson Memo
Articles must be made publicly available no later than 12 months after publication Articles must be made publicly available immediately upon publication
Data from unclassified research should be made publicly available Research data associated with peer-reviewed publications must be made publicly available upon publication. All data from federally funded projects should be publicly accessible as well.
Applicable only to funding agencies with more that $100 million in R&D budget Applicable to all federal funding agencies
Applies to peer-review manuscripts Applies to peer-reviewed manuscripts, peer-reviewed book chapters, editorials, and peer-review conference papers published in other scholarly outlets
Allows the inclusion of appropriate costs for data management and access in proposals Allows the inclusion of publication, data curation, and archiving costs in research budgets

How are we responding?

A working group with members from Research Innovation and Impact (RII)UA Libraries (UAL), the Associate Deans for Research Council, University of Arizona Health Sciences (UAHS) Research Administration, the Data Science Institute, and others is monitoring how federal agencies, philanthropic societies, libraries, the broader academy, publishers, and scholarly communications organizations and advocacy groups are responding to the policy requirements. The working group will use this page to share news and resources as appropriate for the UA community.

Want to know more?

Contact: For questions about:
Tara Radniecki (UAL) OSTP/Nelson Memo working groups
Ellen Dubinsky (UAL, Scholarly Communication Librarian) Potential policy implications, open access publishing options, and campus repository services
Jim Martin (UAL, Research Engagement) Research data management services, including ReDATA (UA's data repository)


Federal agencies will be developing their plans according to these dates included in the memo:

  • August 25, 2022: OTSP/Nelson Memo published
  • February 21, 2023: Draft public access policy implementation plans due for federal agencies with more than $100 million in annual research and development (R&D) expenditures.
  • August 20, 2023: Draft public access policy implementation plans due for federal agencies with less than $100 million in annual R&D expenditures.
  • December 31, 2024: Final public access policy implementation plans due. Agencies must publish their final policies addressing all requirements outlined in the memo. Policies will go into effect no later than 1 year after they're published.
  • December 31, 2025: New policies will be in effect no later than this date.



Public access means that research outputs be made freely accessible for all to read. Public access does not require that outputs be free of copyright or reuse permissions.

Open access provides both free and unrestricted online access to read published research outputs with the addition of reduced copyright restrictions. Open access publications are released with a copyright license (such as a Creative Commons license) that allows some type of reuse, re-distribution, modification, or adaptation.

Slightly over 40% of UA-authored research is the result of federal funding. From 2017 to 2021, UA authors published about 35,800 peer-reviewed research articles; of that total, over 14,500 were the result of federally funded research grants.

This data is from research conducted by Eric Schares at Iowa State University. Eric’s study, Impact of the 2022 OSTP memo: A bibliometric analysis of US federally funded research, was published in March 2023. You can also explore the data using the interactive dashboard created by the author.

Scientific data is defined as: "the recorded factual material commonly accepted in the scientific community as of sufficient quality to validate and replicate research findings. Such scientific data do not include laboratory notebooks, preliminary analyses, case report forms, drafts of scientific papers, plans for future research, peer-reviews, communications with colleagues, or physical objects and materials, such as laboratory specimens, artifacts, or field notes."

  • Start using persistent identifiers (PIDs), also know as digital persistent identifiers (DPIs), for your researcher identity, publications, and data.
    • If you do not already have an ORCID account, go to or ORICD @ UA and sign up for an account
    • Connect your ORCID account to UA via ORICD @ UA. UA has integrated ORCID with UA Vitae to enable a seamless syncing of data between the two agencies, making your research more discoverable.
    • Include the DOIs for your research outputs (such as publications and datasets) in your ORCID record. Data you deposit into ReDATA will be assigned a DOI.
    • Funders often use PIDs to identify the funding body and specific grants. Make sure to reference those PIDs in your publications, reports, and in your ORCID account.
  • Develop data management plans (DMPs) as part of your project planning
    • Some federal agencies already require DMPs and many more agencies will in the coming months. DMPs will help ensure that you have viable plans for the collection, management, long-term storage, and access to your data.

These two sites are updated as new proposed plans/guidance are released:

Page last updated: 5/3/2024