Clarification on the Use of an NIHMSID to Indicate Compliance with the NIH Public Access Policy

Notice Number: NOT-OD-09-136

Update: The following update relating to this announcement has been issued:

  • November 16, 2012 - See Notice NOT-OD-12-160. Upcoming Changes to Public Access Policy Reporting Requirements and Related NIH Efforts to Enhance Compliance.
  • October 30, 2009 - See Notice NOT-OD-10-009 Until further notice, only papers written in Latin script will be collected via the NIH Manuscript Submission System for the NIH Public Access Policy.

Key Dates
Release Date: August 12, 2009

Issued by
National Institutes of Health (NIH), (

Other Relevant Notices  

  • May 26, 2015 Clarifying Publication Reporting Instructions for Research Performance Progress Reports (RPPR) and Renewal Applications. - See Notice NOT-OD-15-091.
  • March 19, 2009, (NOT-OD-09-070) - Notice of Legislative Mandates in Effect for FY 2009
  • September 23, 2008, (NOT-OD-08-119) - Reminder Concerning Grantee Compliance with Public Access Policy and Related NIH Monitoring Activities
  • January 11, 2008, (NOT-OD-08-033) - Revised Policy on Enhancing Public Access to Archived Publications Resulting from NIH-Funded Research


The NIH Public Access Policy ensures that the public has access to published results of NIH funded research.  One requirement of the policy is that institutions submitting an application, proposal or progress report to the NIH must include the PubMed Central (PMC) reference number (PMCID) when citing applicable papers that are authored by the Principal Investigator (PI) or that arise from the PI’s NIH-funded research.

An awardee may demonstrate compliance with the Public Access Policy by including an NIH Manuscript Submission Reference Number (NIHMSID) in lieu of a PMCID at the end of a full citation.  The NIHMSID is a temporary substitute for a PMCID  when using either  Submission Methods C or  D under the NIH Public Access Policy.  It is intended to be used only in cases where an awardee needs to cite a paper soon after its acceptance by a journal, when there is not enough time to complete every step of the NIH manuscript submission process. 

However, NIH has observed that the NIHMSID is being used incorrectly to indicate compliance many months after the publication of a paper, by which time the awardee has had adequate time to complete the submission process and obtain the final PMCID.  Because the Policy requires submission at the time of acceptance and the NIH manuscript submission process can generally be completed within a few weeks, this is an unacceptable use of the NIHMSID. 

NIH is clarifying the temporary nature of NIHMSIDs by defining the specific period during which an NIHMSID may be used to indicate compliance.  This Notice also reminds awardee institutions of the actions they can take to ensure compliance with the NIH Public Access Policy.

Encouraging timely submission of papers to the NIHMS and the completion of the submission process

Effective August 21, 2009, an NIHMSID may be used to indicate compliance with the Public Access Policy for up to three months after a paper is published. After that period, a PMCID must be provided in order to indicate compliance. Specifically:

  • If an applicable paper is in press, or was published less than three months before the submission of an application, proposal or report, the awardee must include either a PMCID or an NIHMSID at the end of the full citation. 
  • If an applicable paper  was published three or more months before an NIH application, proposal or report is submitted, the awardee must include a PubMed Central Reference number (PMCID) at the end of the full citation for the paper.  An NIHMSID is not acceptable in this case.

Additional Information

  • The NIHMS will indicate when an NIHMSID is invalid and no longer acceptable evidence of compliance with the NIH Public Access Policy.  This information will also be available in a Principal Investigator’s (PI) eRA Commons Profile, provided that the manuscript was linked with the PI’s award in the NIHMS.

  • NIH calculates delay periods and compliance deadlines related to the Public Access Policy based on the uses the Publication Date [DP] field in PubMed.  NIH uses the following  default publication dates when the publication date in the article’s citation is not in the month-day-year format: 

Publication Date

Default Publication Date Used by NIH

Year Only

Jan 1


Jan 1


April 1


July 1


Oct 1


The first of the month

Month Range

The first of the first month
(i.e. Jan/Feb – Jan 1; April-June – April 1)

If an article has an ePub date that is later than the default date listed in the table above, NIH will use the ePub date as the publication date for our calculations. 

 Reminders for Awardee Institutions

Awardees are reminded that compliance with the NIH Public Access Policy is an institutional responsibility.  Failure to provide evidence of compliance with the NIH Public Access Policy in an application, proposal or report is a violation of the terms and conditions of the NIH award.  NIH may suspend awards found to be out of compliance, pending corrective action, or may terminate the award for cause (per 45 CFR 74.61, 74.62, and 92.43).  

NIH provides materials that institutions may use to support their authors and investigators in meeting Public Access requirements.


Send questions concerning this Notice or other aspects of the NIH Public Access Policy to:

Office of Extramural Research
National Institutes of Health
1 Center Drive, Room 144
Bethesda, MD  20892-0152

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