You’ve Received Federal Funding – What Comes Next? Understanding Public Access Requirements

By: Gabrielle Matinkhah, Compliance Specialist, Office of Research Integrity & Compliance

First, congratulations on securing federal funding. This is a significant milestone for your research and a testament to the strength of your work. As you begin this next phase, there are many priorities to manage. One that deserves early attention is compliance with evolving public access policies.

What’s Changing in Federal Public Access Policy

The landscape for sharing research outputs is changing. The 2022 Office of Science and Technology Policy (OSTP) Nelson Memo directs federal agencies to update their public access policies in order “to make publications and their supporting data resulting from federally funded research publicly accessible without an embargo.” In response, many agencies have revised their policies, now requiring immediate public access to both publications and underlying data.

Why Early Planning Matters

While publication may seem distant at the start of a project, it is important to consider these requirements early. Planning ahead can help you avoid complications later. Key considerations include:

• Publisher policies: Not all publishers permit immediate (no-embargo) repository deposit, and some maintain embargo periods that may conflict with federal requirements.

• Publication costs: Certain publishing pathways that allow immediate public access may involve article processing charges (APCs), making early budgeting essential.

• Compliance timing: Public access requirements must be met at the time of publication; delayed deposit can result in non-compliance.

• Funding implications: Non-compliance may affect award renewals, future funding eligibility, and could increase institutional oversight or auditing.

Although these new federal agency public access requirements may seem complex, support is readily available. The University of Utah offers a range of resources to help researchers navigate public access policies. The University of Utah Public Access website provides clear guidance on agency-specific requirements and links to tools that support compliance.

In addition, the Marriott Library has secured funding agreements to help offset article processing charges with select publishers (availability may vary and funding is subject to

change). Librarians at both the Marriott and Eccles libraries are also well-versed in open access policies, and data management, and can assist in identifying publication strategies that align with federal requirements.

Furthermore, while Data Management and Sharing Plan (DMSP) requirements are generally distinct from public access policies, there is important overlap between the two. As outlined in the OSTP Nelson Memo, research data—like publications—should be made publicly accessible without embargo.

To support researchers in meeting these expectations, the Marriott Library offers expertise through its team of data librarians. They can assist with developing Data Management and Sharing Plans, as well as provide guidance on appropriate data repositories and best practices for data deposit.

By considering public access early in your research process, you can ensure compliance while maximizing the visibility and impact of your work. See our University Public Access website for additional information on public access requirements by agency.