Research Data Management

Resource for best practices in managing, storing, and sharing your research data

Public Access Funder Mandates

On this page you'll find information about new data management requirements resulting from the 2022 OSTP Memo.  For more information about open access funding requirements and where to publish your final manuscripts, please visit our research guide below:

2022 OSTP Memo (aka the Nelson Memo)

In the last two decades, the federal government has been moving increasingly in the direction of public access to taxpayer funded research. NIH has required the sharing of journal articles based on NIH funded research since 2008. In 2013, the Office of Science and Technology Policy (OSTP) released a memo Expanding Public Access to the Results of Federally Funded Research (aka the Holdren Memo) requiring the inclusion of data management plans for all grant proposals to agencies with at least $100 million in research funds.

In August 2022, Dr. Alondra Nelson of OSTP released a memo, Ensuring Free, Immediate, and Equitable Access to Federally Funded Research, which recommends that all federal agencies develop plans indicating how they will provide public access to the results of federally funded research.

The Nelson memo applies to ALL federal agencies (regardless of research budget), it includes both peer reviewed publications and their underlying scientific data, and the ultimate goal is to provide free, immediate access to research.

Timeline

  • August 25, 2022: Nelson memo published.
  • December 31, 2024: Deadline for all agencies to submit their final public access policies.
  • December 31, 2025: New and updated public access policies for each federal agency will be in effect no later than this date. Any grants awarded after the new policies go into effect have to be compliant with the new requirements.

Upcoming Changes to Current Public Access Policies

The following chart outlines major differences between the current federal public access mandates under the 2013 Holdren memo and upcoming changes outlined in the Nelson memo. Chart courtesy of University of Arizona Libraries.

2013 OSTP Holdren Memo 2022 OSTP Nelson Memo
Articles must be made publicly available no later than 12 months after publication. Articles must be made publicly available immediately upon publication.
Data from unclassified research should be made publicly available. Scientific data* associated with peer-reviewed publications must be made publicly available upon publication.  All data from federally funded projects should be publicly accessible as well.
Applicable only to funding agencies with more than $100 million in R&D budget. Applicable to all federal funding agencies.
Applies to peer-reviewed manuscripts. Applies to peer-reviewed manuscripts, peer-reviewed book chapters, editorials and peer-reviewed conference papers published in other scholarly outlets.
Allows the inclusion of appropriate costs for data management and access in proposals. Allows the inclusion of publication, data curation, and archiving costs in research budgets.

*Per Nelson memo, “scientific data” include the recorded factual material commonly accepted in the scientific community as of sufficient quality to validate and replicate research findings.

Such scientific data do not include laboratory notebooks, preliminary analyses, case report forms, drafts of scientific papers, plans for future
research, peer-reviews, communications with colleagues, or physical objects and materials, such as laboratory specimens, artifacts, or field notes. The definition of “scientific data” is similar to but broader than the term “research data” defined by 2 CFR 200.315 (e) and 45 CFR 75.322 (e).

What to Expect from Agency Plans

Researchers should expect agency plans to eliminate any post-publication embargo period before the results of federally funded research can be publicly shared. The 2013 Holdren Memo specified a 12 month embargo period after publication, but the 2022 Nelson Memo specifically mentioned eliminating that embargo period to provide for more equitable access to research.

Additionally, according to the Nelson memo, agency plans should describe:

  • How peer-reviewed scholarly publications should be made publicly accessible
  • How to maximize equitable reach of public access to peer-reviewed scholarly publications, including by providing free online access to peer-reviewed scholarly publications in formats that allow for machine-readability and enabling broad accessibility through assistive devices
  • The circumstances or prerequisites needed to make the publications freely and publicly available by default, including any use and re-use rights, and which restrictions, including attribution, may apply

Where to Locate Agency Requirements for Research Data: