Comment Letter

COGR, AAMC, AAU, and APLU Submit Joint Comments to NIH on Publication Cost Limits

The Association of American Medical Colleges, Association of American Universities, Association of Public and Land-grant Universities, and COGR submitted joint feedback to the NIH opposing proposed limitations on allowable publishing costs for NIH-funded research, arguing that such limits could impede effective dissemination, create inequities among institutions, and hinder early-career researchers. The organizations support NIH’s goals for broad public access and responsible stewardship of federal funds but assert that arbitrary caps on publication costs—such as article processing charges—would not address the underlying issues, which are determined by publishers, not researchers or institutions. They recommend maintaining current flexibility for investigators, monitoring cost trends, and, if limits are necessary, adopting scalable caps with appropriate waivers and phased implementation to prevent adverse impacts on research quality and equity.

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