• NIH-Funded Authors: For manuscripts accepted after July 1, 2025, you must deposit the final peer-reviewed author manuscript (AAM) into PubMed Central (PMC) via the NIH Manuscript Submission System (NIHMS) at the time of acceptance so that it is available in PMC by the time of its official publication. 
• NSF-Funded Authors: For awards funded after January 2026, you must deposit resulting AAMs in the NSF Public Access Repository (NSF-PAR) via Research.gov.

These federal public access requirements and Government Use/Federal Purpose licenses precede any individual publication agreements authors enter into with a journal/publisher.  

• Manuscript Submission: You should notify journals of your requirement to comply with the NIH Public Access Policy by including the text provided by NIH upon manuscript submission.
• Incompatible Policies: Some journals require a 12-month embargo before depositing an AAM; these policies are not compatible with current NIH and NSF Public Access Policies.
• Subrecipient Responsibility: Authors funded via subawards are also solely responsible for ensuring their publication agreements do not conflict with federal terms.

If a journal’s policy requires an embargo that conflicts with federal mandates, authors have two primary options:

• Option 1: Pay for Open Access. You may pay an Article Processing Charge (APC) to opt into immediate open access. You should speak with your Principal Investigator (PI) about charging this to the grant as an allowable cost. The APC in these cases is an allowable cost because the APC applies to all authors regardless of funding by NIH or NSF (see OSP page on publication charges). 
• Option 2: Resubmit Elsewhere. You may withdraw the manuscript and resubmit it to a journal that does not have an embargo policy (see the Library’s research guide for zero embargo publishing options).

Authors enter into publication agreements with their publishers as individuals. Consequently, they are solely responsible for ensuring they have the funds to cover any publication fees incurred, including article processing charges (APCs) for opting in to publishing their article immediately open access.

• PI Oversight: In the case that a NIH/NSF-funded author opted to embargo an AAM, the PI(s) will be notified of non-compliance via a report from NIH, and/or the PI(s) may become aware of the non-compliant embargo status at the time of preparing Research Performance Progress Report (RPPR). 
  • PIs should contact authors and ask them to contact the relevant help desks to remove the non-compliant embargoes. 
  • Brown and PIs share the responsibility for complying with the NIH and NSF Public Access Policies, including ensuring compliance for resulting manuscripts even in the cases when the PIs are not authors on the paper. 
• Corrective Action: If, after notification, the NIH/NSF-funded authors do not lift the non-compliant embargo, the PI, in the course of their duties to fulfill their responsibility to comply with the NIH/NSF Public Access policy, may manually remove the embargo.