The report: GAO-26-107738
On May 21, 2026, the U.S. Government Accountability Office published GAO-26-107738, “Federal Research: Agencies Should Better Manage Anticipated Publishing Cost Increases Amid Shift to Public Access”. It is the first major GAO audit of how federal science agencies are actually implementing the 2022 OSTP public-access directive (the “Nelson Memo”) rather than a restatement of the policy itself — CASRAI already covers the mandate’s mechanics in Federal Public-Access Mandates Beyond NIH: 2026 Status. This piece focuses specifically on what GAO found when it checked agencies’ actual implementation against that mandate: where compliance is lagging, why publishing costs are becoming a management problem nobody has fully planned for, and what GAO told Congress needs to change.
Which agencies GAO reviewed
GAO selected nine federal agencies with substantial extramural research funding for the review: the National Institutes of Health (NIH), National Science Foundation (NSF), U.S. Department of Agriculture (USDA), Department of Defense (DOD), Department of Energy (DOE), Department of Transportation (DOT), NASA, the Nuclear Regulatory Commission (NRC), and the Social Security Administration (SSA). That set spans agencies with decades of public-access experience (NIH’s PubMed Central program predates the Nelson Memo by more than 15 years — see NIH Public Access Policy) alongside smaller research funders with far less compliance infrastructure.
Compliance findings: who is behind, and on what
OSTP’s 2022 guidance directed every covered agency to have an updated public-access policy in place, with plans and policies taking effect no later than December 2025. GAO’s review found a mixed picture as of its review cutoff: of the nine agencies examined, five had released an updated public-access plan and two had released a formal policy — seven in total with some form of updated guidance on the books — while two agencies had issued neither a plan nor a policy. NIH was the clear front-runner, having moved its own zero-embargo effective date up to July 1, 2025, ahead of the December 2025 government-wide deadline.
Beyond the binary question of whether a policy exists, GAO flagged a substantive gap at two agencies specifically: NSF and USDA had not fully addressed the reuse-rights requirements in OSTP’s guidance — the provisions governing what rights the public and other researchers have to reuse publicly accessible manuscripts and data, not just view them. A published policy that is silent or incomplete on reuse rights does not fully satisfy the 2022 directive, which is part of why GAO treated policy existence and policy completeness as separate findings rather than folding them together.
The cost problem GAO says nobody is managing
The report’s more novel finding is financial rather than procedural. As agencies shift away from subscription-funded access toward the article-processing-charge (APC) and pay-to-publish models publishers are increasingly using to recoup lost subscription revenue (see CASRAI’s full cost-to-publish breakdown for how APCs compare with other publishing costs), GAO estimated that federal public-access-related publishing fees could reach roughly $1 billion a year, with per-agency costs potentially tripling on an annual basis as the zero-embargo requirement takes full effect across more awards. GAO’s central concern is not the dollar figure alone but that, of the nine agencies reviewed, only NIH had developed a documented strategy for managing that cost growth — the other eight had not conducted the kind of cost-impact analysis GAO considers necessary to budget for, or negotiate around, an increase of that scale.
GAO also noted a market-structure concern raised by stakeholders during the review: as publishers lean further into pay-to-publish revenue, some stakeholders warned the incentive structure could pressure publishers to lower publication standards in order to maximize accepted-manuscript volume. GAO’s report is about legitimate publishers’ revenue incentives, not fraudulent operators, but the underlying worry — that pay-to-publish economics can weaken editorial gatekeeping — is the same dynamic CASRAI covers from the screening side in Beall’s List and Cabells Predatory Reports.
GAO’s recommendations
GAO issued eleven recommendations across the nine agencies reviewed, directed at three things: (1) agencies without a finalized public-access policy or plan should complete one, (2) agencies should conduct a documented cost-impact analysis of the anticipated shift toward pay-to-publish models rather than absorbing cost increases without a plan, and (3) agencies whose policies are incomplete on reuse rights (naming NSF and USDA specifically) should revise them to fully align with OSTP’s 2022 guidance. As is standard GAO practice, the report reflects agency comments received during the review; it does not carry independent enforcement authority — implementation depends on the named agencies acting on the recommendations, and on continued Congressional and OSTP oversight of whether they do.
What this means for research offices
For research administrators and sponsored-programs staff, three practical implications follow directly from the report. First, an agency’s public-access policy being “live” is not the same as it being complete — NSF’s and USDA’s reuse-rights gaps are the kind of detail that affects what a co-PI or licensee can actually do with a deposited manuscript, not just where it gets deposited (CASRAI’s NSF-PAR guide covers NSF’s specific deposit mechanics as they stand today). Second, publishing-cost exposure is likely to keep growing across award budgets, and GAO’s finding that only NIH has a real cost-management strategy suggests other agencies’ guidance on allowable publishing costs may lag the market shift for some time — institutions budgeting APCs into grant proposals should not assume agency guidance will move as fast as journal pricing does. Third, because GAO frames this as an active oversight matter with unresolved recommendations, agency public-access policies covered by this report are more likely to change again over the next reporting cycle than settle into their current form — worth monitoring rather than treating as final.
How this report relates to CASRAI’s other public-access coverage
This piece is intentionally narrow: it summarizes what GAO’s audit found, not how the underlying mandate works. For the government-wide public-access mandate itself — its legal basis, which agencies are covered, and the embargo and deposit requirements each has adopted — see Federal Public-Access Mandates Beyond NIH: 2026 Status. For NIH’s specific policy mechanics, see NIH Public Access Policy; for NSF’s repository and deposit workflow, see the NSF-PAR guide; and for how APCs and other publishing costs compare across routes to compliance, see How Much Does It Cost to Publish a Paper?
