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Issued by

NATIONAL INSTITUTES OF HEALTH (NIH)

Purpose

NIH aims to maximize the value of each research grant, and as such, NIH grantees should utilize as much of their grant funds as possible for research activities. While NIH recognizes the value of disseminating and publishing findings, journals with large publishing fees can lead awardees to pay unreasonably high fees from their NIH awards that lessen the funds available for conducting research and which burden American taxpayers. 

Background

On July 8, 2025, NIH announced an intent to establish new policies limiting allowable publication costs. 

To inform policy options, NIH undertook two analyses of recent publication costs. The first analysis used publicly available data from the Directory of Open Access Journals (DOAJ) to find the average article processing charges (APCs) reported in this database. The (DOAJ) is an index of open access journals from around the world. It contains entries for over 20,000 journals that are accompanied by descriptions which include information on APCs. 

Data from the DOAJ index was accessed on June 30, 2025. For analysis, NIH included only those journals with APCs listed and that were updated between 2020 and 2025. Currency exchange rates from the United States Treasury Department (effective on March 31, 2025) were used to convert APCs listed in foreign currencies to 2025 U.S. dollars (USD). One APC was removed from analysis as an extreme outlier ($15,584,416.00 USD). Using information from 7,350 journals, the average APC reported worldwide was $1,235.51 ($0.01 to $8,900.00), and the median was $950. Using information from 598 journals published in the U.S., the average reported APC was $2,176.84 ($30.00 to $8,900.00), and the median reported APC was $2,040.00. 

For the second analysis, NIH examined the requested budgets from more than 1,500 R01 grants awarded in Fiscal Year (FY) 2025 as of July 8, 2025, to assess publication costs requested by NIH applicants, which include APCs and other fees. When applicants provided the anticipated costs of publishing in a specific journal or of a single publication, the costs varied from $0 to $12,000.00, averaging between $3,225.92 to $3,647.47. NIH also found that applicants expected to produce between one and 30 publications over the life of an R01, averaging between 5.7 to 6.9 publications. Using the average requested publication cost given the average anticipated number of publications, NIH estimated that the average cost requested per publication was $2,565.07 to $3,104.06. Overall, when requesting more than $0, applicants requested on average 0.8% of their total requested direct costs for publication costs.

Additionally, NIH recognizes that a cap on allowable publication costs affects a research product that is often relied upon in NIH grant reviews. Therefore, in parallel, NIH intends to undertake additional steps to ensure consideration of the value of other research products (e.g., shared datasets) in the review of funding applications and other mechanisms. 

Proposed Scope

NIH proposes that this Policy apply to all direct publication costs (including APCs and other publishing fees) for grants, contracts, and Other Transactions. Any publication costs would only be allowable for accepted articles, as noted in NIH’s Publication Cost Guidance, which outlines other applicable cost considerations. Commensurate guidance will be developed for the NIH Intramural Research Program and NIH employees. 

Proposed Effective Date

NIH proposes an Effective Date of this Policy as January 1, 2026.

All new and competing awards and proposals for contracts submitted to NIH for receipt dates on or after January 1, 2026, or Other Transactions executed on or after January 1, 2026, will be expected to comply with this policy.

All other awards, contracts, and Other Transactions active on or after January 1, 2026, are expected to comply with this policy by the start of the first budget period or start of the first reporting period following January 1, 2026.  

Proposed Options for Limiting Costs

To balance feasibility of providing research results with maximizing the use of taxpayer funds to support research, NIH seeks input on the following policy options to keep journal publication costs, including APCs and other publication fees paid by NIH, reasonable. NIH is not proposing to prevent awardees from publishing in any particular journal, but rather NIH seeks to set a reasonable threshold for what the Agency spends on publication expenses from direct costs of awards.

Option 1: Disallow all publication costs. NIH could no longer support publication costs through any funding mechanism. Some private funders have disallowed costs for peer-reviewed publications as they seek to place increased value on preprints.

Example: NIH awardees may not use NIH funds to cover any publication expenses.

Option 2: Set a limit on allowable costs per publication. NIH could limit allowable direct costs to $2,000.00 per publication, including APCs and other fees. This amount is between what NIH found as the average global APC ($1,235.51) and the average requested in budgets (approximately $2,600.00-3,100.00), and close to the average for U.S. published journals’ APCs ($2,177.00).   

Example: The number of publications that may be paid from grant funds is not limited, but the allowable direct cost from NIH is limited to $2,000.00 for any single publication resulting from NIH funding.

Option 3: Set a limit on allowable costs per publication and allow a higher amount to be paid when peer reviewers are compensated. NIH could adopt the $2,000.00 limit per publication in Option 1, and allow a higher limit of $3,000.00 per publication when publishing in journals that compensate peer reviewers at a level equivalent to the average hourly wage reported by the U.S. Bureau of Labor Statistics for Medical Scientists and Biochemists/Biophysicists (approximately $50.00 in 2025) and that publicly provide all reviews resulting from the peer-review process of accepted, NIH-funded manuscripts. This option considers the limit in Option 2, with an additional $1,000.00 to allow journals to compensate peer reviewers. Given surveyed reports that reviewers spend 6 hours per review,¹ three peer reviewers can be compensated at $50.00 per hour for 6 hours per peer review ($300.00 for each reviewer), while rounding up to $1000.00 to account for additional costs of organizing peer review and accompanying payments. There may be other situations where a higher rate may be justified (e.g., use of automated fraud protection capabilities).

Example: The number of publications that may be paid from grant funds is not limited, but the amount allowable from NIH direct costs is limited to $3,000.00 per publication in journals for which peer reviewers are compensated for their services and peer reviews are made public.

Option 4: Set a limit on the total amount of an award that can be spent on publication costs. NIH could limit the maximum amount of an award that could be spent on publication costs to 0.8% of the award’s direct costs over the length of the award or $20,000.00, whichever is greater, in order to not disproportionately impact smaller awards. Limiting the award to 0.8% or $20,000.00 is consistent with recent requested average amounts for publication costs and provides institutions flexibility in publication while containing future cost increases. NIH may consider exemptions to the cap with agency approval for unusual, high-volume publication situations. 

Example: NIH awardees may not request more than $20,000.00 from their award or 0.8% of the direct costs of the award, whichever is higher, with no limit on the per publication costs, until the maximum allowable amount is reached.

Option 5: Set a limit on both the per publication cost and the total amount of an award that can be spent on publications. NIH could limit both the total amount of an award that could be spent on publication costs to the greater of 0.8% of the award’s direct costs or $20,000.00 over the life of the award, in addition to limiting the amount per publication to $6,000.00.

This option considers the limit in Option 4, as well as NIH applicants’ range of estimated per publication costs of $0 to $12,000.00. A per-publication limit of $6,000.00 reflects the mid-point of the range of applicants’ estimated per publication costs, and encompasses the majority of reported per-publication costs. By combining an overall percentage of the budget and a generous per publication limit of half of the maximum that NIH applicants estimated, this option allows awardees more flexibility while prohibiting use of taxpayer funds for unreasonably high fees.

Example: NIH awardees may spend up to $6,000.00 per publication up to their per-award spending limit on publication costs. In this example, awardees are explicitly allowed a greater per publication maximum while limiting the total amount.

Request for Information

NIH seeks information from all interested individuals and communities, including, but not limited to, researchers, universities and research institutions, librarians, scientific societies, publishers, and other members of the public. Comments are welcome on any aspect of this proposal, including the specific issues provided below:

1. The option, or other option not considered here, that best achieves the goal of balancing flexibility in providing research results with maximizing the use of taxpayer funds to support research;
2. Any evidence (either from your own work or other publicly available sources) that can be publicly shared that addresses the considerations of one or more of the options;
3. Factors that NIH should consider in determining whether peer reviewers are appropriately compensated;
4. In addition to compensating peer reviewers, other kinds of publishing best practices that NIH should consider as factors in determining the potential allowability of a higher per publication cost, such as use of automated fraud detection capabilities;
5. Other evidence or information not considered here that NIH should consider in its policy on limiting allowable publication costs.

How to Submit a Response

Comments should be submitted electronically to the following webpage: https://osp.od.nih.gov/comment-form-maximizing-research-funds-by-limiting-allowable-publishing-costs/. Responses will be accepted through September 15, 2025. Responses to this RFI are voluntary and may be submitted anonymously. You may also voluntarily include your name and contact information with your response. Other than your name and contact information, please do not include in the response any personally identifiable information or any information that you do not wish to make public. Proprietary, classified, confidential, or sensitive information should not be included in your response. After the Office of Science Policy (OSP) has finished reviewing the responses, the responses may be posted to the OSP website without redaction.

Footnotes

[1] See, for example, LeBlanc AG, Barnes JD, Saunders TJ, Tremblay MS, Chaput JP. Scientific sinkhole: estimating the cost of peer review based on survey data with snowball sampling. Res Integr Peer Rev. 2023 Apr 24;8(1):3. doi: 10.1186/s41073-023-00128-2. PMID: 37088838; PMCID: PMC10122980; and Aczel B, Szaszi B, Holcombe AO. A billion-dollar donation: estimating the cost of researchers' time spent on peer review. Res Integr Peer Rev. 2021 Nov 14;6(1):14. doi: 10.1186/s41073-021-00118-2. PMID: 34776003; PMCID: PMC8591820.

Inquiries

Please direct all inquiries to:

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NH Office of Science Policy

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