NIH has proposed capping the amount of grant funding that can be used to pay for open access publishing fees — article processing charges (APCs) and related publication costs — charged to NIH awards. As of this writing, the proposal is not finalized: NIH issued a Request for Information (RFI) in mid-2025, is not yet law or binding grants policy, and no specific cap has been formally adopted. This guide explains what NIH actually proposed, why, the options on the table, and what research administrators should do while the policy remains unsettled.
This is a distinct issue from the NIH Public Access Policy, which governs when and how peer-reviewed manuscripts must be deposited in PubMed Central — that policy is already in effect (zero embargo for manuscripts accepted on or after July 1, 2025) and does not itself set a dollar limit on what NIH will pay for publishing. The publication-fee cap proposal is a separate question: not whether a manuscript must be made public, but how much of an NIH grant budget can go toward the fee a publisher charges to make it public.
Background: why NIH proposed a cap
On July 30, 2025, NIH issued Notice NOT-OD-25-138, "Request for Information on Maximizing Research Funds by Limiting Allowable Publishing Costs." NIH’s stated rationale is that APCs charged by some journals have risen to levels the agency considers difficult to justify as a use of federal research funds — the notice and accompanying NIH statements cited individual APCs reported as high as roughly $13,000 for a single article. NIH framed the proposal as an effort to keep more grant funding available for the research itself rather than for publication fees, while explicitly stating it was not proposing to restrict which journals a grantee could publish in.
The RFI followed, and is related to, NIH’s acceleration of its Public Access Policy compliance date (moved up from December 31, 2025 to July 1, 2025) — both moves reflect a broader push by NIH toward tighter, faster enforcement of open-access obligations on federally funded research, part of implementing the 2022 OSTP public-access directive.
The proposed cap options
NOT-OD-25-138 did not commit to a single mechanism. It asked for public comment on five possible approaches to limiting allowable publication costs charged as direct costs to NIH awards:
- Disallow publication costs entirely — NIH funds could no longer be used to cover APCs or other publication fees through any award mechanism.
- A flat per-publication cap of $2,000 — NIH would reimburse up to $2,000 in publication costs for a single article, regardless of the journal’s actual charge.
- A tiered per-publication cap — the same $2,000 limit, with a higher $3,000 limit allowed for journals that compensate peer reviewers at a specified rate.
- A percentage-of-award cap — publication costs limited to 0.8% of an award’s total direct costs over its full period, or $20,000, whichever is greater.
- A combined per-publication and award-level cap — up to $6,000 per publication, within an overall award ceiling of 0.8% of direct costs or $20,000, whichever is greater.
Under every option NIH described, only publication costs for an accepted article (not article submission or rejected-manuscript fees) would be allowable, consistent with how publication costs are already treated under the NIH Grants Policy Statement‘s existing allowable-cost framework.
Timeline and current status
NIH’s original comment period on NOT-OD-25-138 closed September 15, 2025, and the notice proposed an effective date of January 1, 2026 for any adopted policy. As of the most recent verification for this page, industry trackers reported the proposal was still under consideration and had not been formally finalized into a published NIH Guide notice setting a specific cap — meaning research administrators should not yet treat any single dollar figure above as binding grants policy.
Because this is an active rulemaking-style process rather than a settled rule, the only reliable way to confirm current status is to check the NIH Guide for Grants and Contracts directly for a superseding notice, rather than relying on secondary summaries (including this one) once one is issued.
How this differs from the NIH Public Access Policy
These two NIH requirements are frequently conflated but govern different things:
- NIH Public Access Policy — a compliance mandate. It requires the author’s accepted manuscript from NIH-funded research to be deposited in PubMed Central and made publicly available (zero embargo as of July 1, 2025). It applies regardless of which publishing route (subscription, hybrid, or fully open access) a researcher uses, and it does not, by itself, cost the grant anything if a green open access route (self-archiving the accepted manuscript) is used.
- Publication cost / APC cap proposal — a spending-allowability question. It concerns how much of an NIH award’s direct costs can be spent reimbursing a publisher’s article processing charge or other publication fee, if a researcher chooses (or a journal requires) a paid open-access route.
A researcher can be fully compliant with the Public Access Policy without spending a cent of grant funds on an APC, by depositing the accepted manuscript directly. The fee-cap proposal only bears on cases where the researcher pays a publisher for immediate open access (gold or hybrid open access) and charges that fee to the grant. See CASRAI’s guide to article processing charges (APCs) for open access for how APCs work more generally, including gold, hybrid, and diamond open-access models.
What research administrators should do now
- Do not budget against an unconfirmed number. None of the five options in NOT-OD-25-138 has been confirmed as final NIH policy as of this page’s last verification; treat any specific dollar figure circulating as a proposal, not a rule, until a superseding NIH Guide notice says otherwise.
- Watch new and competing awards closely. NIH’s proposed effective date structure in the RFI would have applied to new and competing awards from the effective date forward, not retroactively to existing awards — a common pattern for NIH policy changes, but confirm the actual applicability language once a final notice is published.
- Separate the two obligations in guidance to PIs. Public Access Policy compliance (manuscript deposit) is already mandatory and unrelated to journal choice or cost; the APC cap is a separate, not-yet-final, budget question. Conflating them in internal guidance risks either unnecessary alarm or missed compliance.
- Track institutional Read & Publish and transformative agreements. Where a library already has an agreement that waives or discounts APCs for a given publisher, that arrangement may reduce or eliminate the direct-cost exposure a per-publication cap would otherwise create.
- Budget publication costs as a distinct, justified line item in grant applications rather than an assumed pass-through, consistent with the existing allowable-cost standard in the NIH Grants Policy Statement that costs must be reasonable, allocable, and consistently treated.
Frequently asked questions
Has NIH actually capped open access publishing fees?
Not as a finalized policy as of this page’s last verification. NIH issued a Request for Information (NOT-OD-25-138) in July 2025 proposing several possible caps on allowable publication costs and requesting public comment; it had not been converted into a final, superseding NIH Guide notice with a confirmed cap at last check. Confirm current status directly on the NIH Guide for Grants and Contracts before relying on any specific figure.
Is this the same as the NIH Public Access Policy?
No. The NIH Public Access Policy is an already-effective mandate requiring deposit of accepted manuscripts in PubMed Central. The publication-fee cap is a separate, not-yet-finalized proposal about how much of a grant’s direct costs can be spent reimbursing a publisher’s article processing charge.
What dollar amounts has NIH discussed?
NOT-OD-25-138 discussed five options ranging from disallowing publication costs entirely to per-publication caps of $2,000–$6,000, or an award-level cap of 0.8% of direct costs or $20,000 (whichever is greater). These were proposed options for comment, not an adopted figure.
Does the proposed cap affect NIH’s manuscript deposit requirement?
No. Even under the strictest proposed option (disallowing publication costs entirely), researchers would still be required to comply with the Public Access Policy by depositing the accepted manuscript in PubMed Central; that obligation does not depend on paying an APC.
Where can I check the current, authoritative status?
The NIH Guide for Grants and Contracts is the primary source for any superseding notice. Institutional sponsored-programs or grants-management offices typically issue their own guidance once a final notice is published.
