This guide is a living resource that will develop as information is released, and policies are updated. It will be kept up to date to the best of the Libraries’ ability.
This guide was last updated: 2025-05-29.
For assistance interpreting federal public access policies, please contact your subject librarian or librarians who specialize in a specific area of the policies. The specialist librarians are Stephen Wolfson for copyright and licensing, and Lauren Phegley for data management and data sharing.
Note for library staff: Further details about triage assistance for public access policy needs can be found below in the admin view of this guide.
This resource provides guidance on the United States federal funding policies that require making research outputs supported by federal funding publicly accessible, with a focus on data and publication sharing. It will address requirements to share additional research outputs like software when required by an agency policy.
The guide provides information, references, and support from Penn Libraries for federally funded researchers who need to share their publications and datasets. This guide will be useful to anyone whose research is federally funded and falls under the requirements to make their research output publicly accessible, but some information will be specific to the University of Pennsylvania community.
Only a handful of federal funders have released their final public access policies in response to the 2022 Nelson Memo. Information on current final public access policies from federal agencies can be found by navigating to the side of this guide. Each federal agency page will provide an overview of the policy, the requirements for making research outputs publicly accessible, and additional resources. This guide will grow as more federal agencies release their final policies.
"Public Access Policies" is the general term for the federal government requirements for federally funded researchers to make their final research outputs, such as publications and datasets, publicly available. Each federal department or agency either has or will have their own plans outlining how researchers will share their scholarly outputs. Certain federal agencies have not released their final policies, while others have their final policies published with implementation deadlines for 2025.
The basic overview across all policies is the mandate that a funded researcher must share their author accepted manuscript of any peer reviewed publications in a designated government document repository, and that final scientific data must be shared in an appropriate and established data repository. The first federal wide public access policies were instituted in 2013, but they are being updated due to the new 2022 Nelson memorandum. The largest change from the 2013 round of policies is that the automatic twelve-month embargo for publications submitted to the designated government document repository is being removed. This means that the publications must be publicly available immediately upon publication. Additionally, the 2022 policies for public access now apply to all federal agencies, regardless of their funding level.
These policies impact researchers who are funded in part or in whole by funding from the federal government. The specific details of what is required of recipients can vary depending on the type of funding (grant, contract, "Other Transactions", etc.), the date of grant application, the type of work being completed, the funding agencies own specific implementation rules, and other legal, ethical, or technical factors.
Unfortunately, detailed information on what is required of you as a grantee is often dispersed. This guide will provide you with a starting point for understanding your mandates and additional resources, but there are other locations you will need to check. The most important starting place is your Notice of Funding Opportunity. Another suggestion is to search your federal agency’s website for keywords like "data sharing", "publication deposit", and "public access". Additionally, read the documentation for the data repository you have chosen for depositing data into and be in close contact with your Program Officer.
The first federal wide public access policy was the Office of Science and Technology Policy (OSTP) "Memorandum on Increasing Access to the Results of Federally Funded Research" which is often referred to as the Holdren Memo or the 2013 Holdren Memo. This policy directed all federal departments and agencies with more than $100 million in research and development expenditures to develop plans for increasing access to the results of federally funded research.
Agencies aligned themselves with the 2013 Holdren Memo by:
The most recent public access policy impacting all federal agencies was the Office of Science and Technology Policy (OSTP)’s "Memorandum on Ensuring Free, Immediate, and Equitable Access to Federally Funded Research" which was released by Dr. Alondra Nelson in August 2022. The 2022 Nelson Memo built on the existing 2013 Holdren Memo by requiring that all federal agencies update their public access policies to make peer reviewed publications and their supporting data that result from federally funded research publicly accessible without an embargo. The 2022 Nelson Memo also changed the field by requiring that all federal agencies, regardless of research and development expenditure costs, create or update public access plans.
2025-04-30: NIH director moves up deadline for NIH public access compliance to July 1, 2025
The 2024 NIH Public Access Policy is effective July 1, 2025. It requires author accepted manuscripts accepted for publication in a journal on or after July 1, 2025 to be submitted to PubMed Central upon acceptance for publication, for public availability without embargo upon the Official Date of Publication. The NIH defines the Official Date of Publication as “the date on which the article is first made available in final, edited form, whether in print or electronic (i.e., online) format.”
Article processing charge (APC): A fee charged to authors to make a work available in an open access format. This fee may be covered by the author, the author’s institution, or their research funder.
Author accepted manuscript (AAM): The version of a scholarly or scientific paper that includes changes recommended during the peer review process. This version has not been formatted or copyedited by the publisher and is not the version typically seen in library databases. Also referred to as author final manuscript, final peer-reviewed manuscript, and postprint.
Author final manuscript: See Author accepted manuscript.
Data management and sharing plan (DMSP): A project-specific document by grant applicants that outlines how data will be managed, documented, preserved, and shared during and after the research project. Also referred to as a data management plan, although most federal agencies are shifting away from this term and using data management and sharing plan instead.
Data management and sharing policy (DMS Policy): A set of requirements established by funding agencies that outline the expectations for how data should be managed and shared across all research projects funded by the agency.
Disciplinary repository: Repositories that preserve and share scholarly output in a specific disciplinary area. These repositories may be hosted and managed by a variety of bodies, including scholarly societies, federal agencies, university departments, and libraries.
Extramural awards: Awards provided to a research institution other than the federal agency from where the funding is appropriated (e.g. federal funding to universities).
Final peer-reviewed manuscript: See Author accepted manuscript.
Final published article: See Version of record.
Institutional repository: Repositories that are hosted and managed by educational institutions. Institutional repositories preserve and publicly share the scholarly output of their own institution. The University of Pennsylvania’s repository is called ScholarlyCommons and is managed by Penn Libraries.
Metadata: Data that describes other data. Metadata commonly includes information such as author, date created, and date published.
Notice of Funding Opportunity: A formal announcement inviting grant award applications from extramural investigators, where the announcement includes summary information, availability period, and the full text of the funding opportunity. May have previously been referred to as a Funding Opportunity Announcement (FOA), though this terminology is being phased out.
ORCID: Open Researcher and Contributor ID. While ORCID and ORCID iD are often used interchangeably, ORCID refers to the organization that supplies ORCID iDs.
ORCID iD: A unique and persistent identifier for researchers. Often called “an ORCID.”
Persistent identifier (PID): A long-lasting reference assigned to a specific entity like a document, researcher, dataset, or other object. A PID ensures that the entity can be reliable and persistently retrieved and cited over time. The ‘persistent’ part indicates that an organization made a promise to keep it updated. The ‘identifier’ part focuses on a globally unique string of characters.
Preprint: The version of a scholarly or scientific paper before peer review and publication. Also called the submitted version.
Postprint: See author accepted manuscript.
Principal investigator (PI): The primary individual responsible for a grant, typically serving as the lead researcher on a grant-funded project. The PI is responsible for the completion of a funded project, including directing the research and reporting to the funding agency.
Publisher’s version: See Version of record.
Repository: A digital platform used to collect, preserve, and provide public access to scholarly outputs. These outputs include preprints and manuscripts, technical reports, working papers, conference proceedings, data sets, and theses and dissertations.
Scientific Data: Defined in the 2022 Nelson Memo 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.
Transformative agreement: A contract between a publisher and a library, library system, consortia, or other organization that aims to shift costs away from a subscription-based model (pay to read) toward a publishing-based model (pay to publish). These agreements are intended to promote open access by covering article processing charges (APCs) for authors.
Version of record: The version of a scholarly or scientific paper formatted and disseminated by a publisher. This is the version typically found in library databases. Also referred to as final published article, and publisher’s version.
