For Sponsored Programs

The NIH Public Access Policy is a legal requirement, as well as a term and condition of award.  Awardee institutions may wish to consider the following issues as they implement the Policy.

• NIH Applications, proposals and reports: Who ensures that NIH applications, proposals and reports  are compliant with the NIH Public Access Policy?

• Training: How are your authors and Principal Investigators (PIs) trained on the NIH Public Access Policy, its requirements and its implementation?

• Publishing Agreements: Who supports authors and PIs in ensuring that publishing agreements comply with the NIH Public Access Policy?

Who ensures that NIH applications, proposals and reports  are compliant with the NIH Public Access Policy?

On all NIH applications, proposals and reports, PIs are to include the PMC reference number (PMCID) at the end of the full citation of all papers that fall under the Public Access Policy and are authored by them or arise from their NIH award. NIH expects institutions will not send NIH applications, proposals and reports that are inconsistent with the terms and conditions of their NIH awards.

NIH program staff check for compliance with the Policy in the same way that any institutional signing official can- they look for a PMCID at the end of each applicable citation. NIH staff pay particular attention to the progress report publication list and PI biosketches. See http://publicaccess.nih.gov/citation_methods.htm for more information.  

How are your authors and Principal Investigators (PIs) trained on the NIH Public Access Policy, its requirements and its implementation?

At many universities, libraries have taken on this task. Some train any author or PI upon request, and others work to ensure there is at least one person in every department or unit who can answer author and PI  questions. NIH offers training materials that can be downloaded and adapted for your institution. Third party software can also help manage bibliographies and PMCIDs.

Who supports authors and PIs in ensuring that publishing agreements comply with the NIH Public Access Policy?

There are many approaches and experts institutions could use to help with this issue. At NIH, we found we needed to change our authorship policies for our employees. We created a publishing addendum and asked our technology transfer coordinators, with help from our counsel, to support our employees in interpreting and negotiating any publishing agreement issues. We require applicable papers to be submitted in accordance with the NIH Public Access Policy before we count them as productivity for an employee or research unit. Our guidance to our employees is publically available. Other institutions have developed similar approaches.