Data Services
Data Management and Sharing Policies and Services
Overview
Information below discusses federal public access policies related to:
- Sharing of articles resulting from federal funding (NIH Public Access Policy and the OSTP Memo)
- Sharing of data resulting from federal funding (NIH Data Management and Sharing Policy)
Article Sharing: 2024 NIH Public Access Policy - Accelerated Effective Date
Note a new Effective Date: starting July 1, 2025, the 2024 NIH Public Access Policy will require that all peer-reviewed journal articles resulting from NIH-funded research be submitted to PubMed Central (PMC) and made immediately publicly available upon publication—embargo periods will no longer be permitted.
What This Means for You
Previously, many publishers deposited articles into PMC after an embargo period at no cost. Under the new policy:
- Articles must be deposited into PMC at the time of publication.
- Embargo periods are no longer allowed.
- Submitting to bioRxiv or other preprint repositories does not meet the requirements
- Some publishers may still submit the article on your behalf, but may now charge a fee for immediate open access.
- Author self-deposit to PMC is available and free
- Uploading the publisher's PDF may violate copyright, depending on your publication agreement.
How the Health Sciences Library Can Help
We’re here to support you in navigating these changes and ensuring compliance:
- Online guidance on how to comply with the policy
- Free consultations on submission processes.
- Guidance on uploading the correct version—whether the publisher’s PDF (when allowed) or the final peer-reviewed Author Accepted Manuscript, which also meets NIH requirements.
- Help using the NIH Manuscript Submission (NIHMS) system or My NCBI to track compliance.
What You'll Need to Do:
The NIH Public Access Policy requires immediate public access to articles resulting from NIH funding for manuscripts accepted for publication on or after July 1, 2025. Typically this occurs through one of two existing submission pathways:
- submission of the final peer-reviewed manuscript to PubMed Central (PMC) directly by the author, OR
- submission of the final published article to PMC from a journal that has a formal agreement with the National Library of Medicine (NLM)
- Publishers may charge Article Processing Charges (APCs) to make your article available as open access and comply with the policy. Note option 1 above allows authors to submit to PMC for free to comply with the policy.
Get Help
Remember you do NOT have to pay article processing charges (APCs) to submit your manuscript to PubMed Central to comply with the policy. Need help? View step-by-step instructions here on how to submit your manuscript, or click below to request assistance.
Data Sharing: NIH Data Management and Sharing Policy
Summary of the NIH Data Management and Sharing Policy
NIH issued the Data Management and Sharing (DMS) policy (effective January 25, 2023) to promote the sharing of scientific data. Read more at sharing.nih.gov, but in short, under the DMS policy, NIH expects that investigators and institutions:
- Plan and budget for the managing of data, and the sharing of data no later than the time of an associated publication or end of award (for unpublished data), whichever comes first.
- Submit a DMS plan for review when applying for funding
- Comply with the approved DMS plan, including reporting on your progress
Get full details at our guide below:
View HSL's NIH Data Management and Sharing Plan Guide
Get Help
Request a custom consultation on your draft plan or your data sharing needs via the button below:
Get Started: Request a Consultation
Learn about public access policy support (e.g. data sharing) assistance for UVA Health affiliates:
- from the Health Sciences Library (free consultation)
- from the Bioinformatics Core (free service for UVA Health Cancer Center members and fee-based services for others)
- from Public Health Sciences (fee-based collaboration model)
OSTP Public Access Policy Memo aka "Nelson Memo"
Summary of the 2022 OSTP Public Access Policy Memo, aka the "Nelson Memo"
A memorandum titled “Ensuring Free, Immediate, and Equitable Access to Federally Funded Research,” widely referred to as the Nelson Memo was released on August 25, 2022 from the White House Office of Science and Technology Policy (OSTP). This directive requires that federal agencies funding research must:
- Revise their public access policies so that publications and supporting data from federally funded research are "made freely available and publicly accessible by default agency-designated repositories without any embargo or delay after publication."
- Implement clear and transparent processes to uphold scientific and research integrity in these public access policies; and
- Work in partnership with OSTP to ensure equitable public access to the results and data of federally funded research.
Key dates include:
- December 31, 2024 - The date by which agencies should publish their new or updated public access policies. See box below for the new NIH Public Access Policy.
- December 31, 2025 - The date by which agencies' public access policies will be in effect, affecting investigators applying for funding.
Get Help
Request a custom consultation on the OSTP Public Access Policy requirements and how to ensure you are compliant:
Get Started: Request a Consultation
- Learn about the OSTP Public Access Policy support assistance for UVA Health affiliates:
- From the Health Sciences Library
- UVA Library Guide to the 2022 OSTP Public Access Policy Memo
Frequently Asked Questions
What is the difference between the NIH DMSP mandate and the 2022 OSTP Public Access Policy Memo?
The NIH Data Management and Sharing Policy (DMSP) mandate, effective December 2023, requires a detailed data management and sharing plan as part of NIH grant applications. This plan must address six key elements. For more information, visit the UVA NIH Data Management and Sharing Plan Guide or request a consultation through the library.
The 2022 OSTP Public Access Policy Memo applies broadly to all federal agencies awarding grants. While the NIH DMSP is more specific, compliance with its requirements also ensures compliance with the OSTP policy. However, the OSTP policy further mandates that peer-reviewed research articles or final manuscripts be made openly available immediately upon publication, without an embargo period.
Which of my research outputs will be affected by the OSTP Public Access Policy?
All Peer Reviewed Scholarly Publications and scientific data underlying peer-reviewed scholarly publications. According to the memo, “scientific data” include 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. The definition of “scientific data” is similar to but broader than the term “research data” defined by 2 CFR 200.315 (e) and 45 CFR 75.322 (e).”
I'm confused! I'm an investigator with experience with NIH awards and my funded publications have been made public in PubMed Central for years! What's changing with this new OSTP Public Access Policy?
Great question! You're right that the existing NIH Public Access Policy also mandates sharing of publications. See below for some key differences. Note that as of November 2024, we do not know exactly what workflows the publisher may put in place to help you comply with the OSTP requirements. But you do NOT have to pay article processing charges (see below).
Publications
| NIH Data Management and Sharing Policy (2023) | OSTP Public Access Policy (2025) | |
|---|---|---|
| Timeframe | Publishers may require that public access be delayed up to 12 months after publication. | No embargo allowed |
| Publication Types | Only applies to peer-reviewed journal manuscripts resulting from the federally funded research | All peer-reviewed scholarly publications resulting from the federally funded research (e.g. could include book chapters, etc). |
Do I need to pay for open access Gold or other Article Processing Charges with the vendors to make my scholarship open access?
NO! You can comply with the OSTP Public Access Policy by depositing your last edited draft (aka your author accepted manuscript) in PubMed Central for free. To learn more, request a consultation with the library.
OK, let's talk data! Doesn't the new NIH Data Management and Sharing Policy require me to address data sharing? Why does the OSTP Public Access Policy require this as well?
Another great question! NIH does have its own data sharing requirements, but the new OSTP policy applies to all agencies. Also, NIH emphasizes that shareable data is not only that associated with publications.
Data
| NIH Data Management and Sharing Policy (2023) | OSTP Public Access Policy (2025) | |
|---|---|---|
| Applies To | NIH-funded research | All federal agencies awarding grants |
| Definition of data per the Policies |
"scientific data is defined as data commonly accepted in the scientific community as of sufficient quality to validate and replicate research findings, regardless of whether the data are used to support scholarly publications. Scientific data includes any data needed to validate and replicate research findings." "Scientific data underlying findings not disseminated through peer-reviewed journal articles should be shared by the end of the performance period unless the grant enters into a no-cost extension. If a no cost extension is permitted, then the recipient should share the data by the end of the extended performance period. These scientific data may underlie unpublished key findings, developments, and conclusions; or findings documented within preprints, conference proceedings, or book chapters. For example, scientific data underlying null and negative findings are important to share even though these key findings are not always published." |
"scientific data underlying peer-reviewed scholarly publications, e.g. the recorded factual material commonly accepted in the scientific community as of sufficient quality to validate and replicate research findings" |
Are there any existing DMS plans that I can check out so I have an idea what a plan looks like?
NIH has several sample plans for you to review. Our guide highlights each NIH DMSP Element with suggested language. Coming soon: links to approved plans from UVA investigators.
Where can I find help with identifying an appropriate repository for my DMSP?
The NIH guidance on choosing a repository recommends researchers to choose the repository that best suits their specific data type and field of study. Researchers have several options depending on their award. NIH maintains over 140 different repositories and there are generalist repositories at UVA and online. To learn more, see our guide or request a consultation with the library.
About the new Policy
About the New NIH Public Access Policy
On Dec 17 2024, NIH announced a new NIH Public Access Policy to make the results of NIH-funded research accessible as quickly as possible. The new Policy, when effective, removes the twelve-month embargo period to make NIH-funded published manuscripts publicly available without delay. Specifically, the Policy applies to final, peer-reviewed articles (i.e., Author Accepted Manuscripts) accepted for publication in a journal on or after the Effective Date that result from NIH funding in whole or in part. As of 4/30/25, the Effective Date has been moved from December 31, 2025 to July 1 2025.
View this guide from SPARC to learn more.
Related to the new plan, and in response to the 2022 OSTP memo, NIH has outlined plans to increase findability and transparency of research results through the use of metadata and persistent identifiers (PID). A Comment Form is accepting feedback through February 21, 2025, and the full Plan is available here.
Need more information on public access requirements? We are here to help or refer you to an appropriate expert or resource: just Ask Us.