The joint letter from the Association of Public and Land-grant Universities (APLU), Association of American Universities (AAU), Association of American Medical Colleges (AAMC), and the Council on Governmental Relations (COGR) responds to the NIH Draft Public Access Policy, expressing general support for the policy’s objective of maximizing public access to NIH-funded research. The organizations note their appreciation for the increased clarity in the policy, particularly regarding terminology, submission requirements, and the distinction between manuscript and final published article. However, they raise significant concerns about the proposed accelerated timeline for implementation and advocate for a phased approach, recommending retention of the current 12-month embargo for awards made before October 1, 2025, and requesting consideration for supplemental funding to cover potential new publishing costs for existing grants.
The letter further addresses the policy’s accessibility goals, supporting NIH’s plans to ensure machine-readable content on PubMed Central but seeking assurance that researchers and institutions will not bear added burdens in this process. The organizations strongly object to mandating an additional government use license, citing legal and copyright concerns and recommending policy language that does not expand NIH’s rights beyond existing statutory authority. Concerns are also raised about publication costs, urging NIH to allow reasonable and clearly defined publication expenses as direct grant costs, including for peer review and post-award publications. The signatories call for NIH to collaborate with the research community to provide comprehensive guidance on allowable costs, consider supplemental funding mechanisms, and ensure that new policies do not inadvertently hinder open access transitions or institutional publication resource management. The letter concludes by emphasizing the importance of ongoing stakeholder engagement as NIH finalizes its public access policy.
