Data Management

In August 2022, the White House Office of Science and Technology Policy (OSTP) released a memorandum titled "Ensuring Free, Immediate, and Equitable Access to Federally Funded Research." This document is commonly referred to as the “Nelson Memo” or the "OSTP Memo." It details new requirements that will affect both faculty and students who conduct research using federal funding. The memo requires all federal agencies that fund research to:

1. "Update their public access policies as soon as possible, and no later than December 31st, 2025, to make publications and their supporting data resulting from federally funded research publicly accessible without an embargo on their free and public release;
2.  Establish transparent procedures that ensure scientific and research integrity is maintained in public access policies; and,
3.  Coordinate with OSTP to ensure equitable delivery of federally funded research results and data."

Important Points

• The goal of the Nelson Memo is to provide free, immediate (without embargo), and equitable access to all research that is federally funded.

• It applies to every federal agency, including those providing funding in the Arts, Humanities, and Social Sciences.

• It applies to both peer reviewed publications and the underlying scientific data.

Timeline and Key Dates

• August 25, 2022: Nelson Memo issued.

• December 31, 2024: Deadline for federal agencies to publish their final public access policies.

• December 31, 2025: New policies must become effective no later than this date.

Will my current research be affected?

The memo requires that all agency policies will be in effect by December 31, 2025. You can expect that most agencies will take the full amount of time to develop and enact their new procedures. It is likely that any projects receiving funding in 2025 or later will be expected to adhere to these new policies or procedures.  
 

Does the new memo require me to publish as open access?

Not necessarily. Publishing with open access is only one way to provide immediate availability and accessibility to publications and data. Another way is to share the final manuscript in a repository that is designated by the funding agency. For example, you could share your research on PubMed, NIH's designated repository, if you have received NIH funding. You can also share your manuscript and data on an Institutional repository such as Coastal Carolina University's Digital Commons. 

However, you should verify that you have permission to upload your publication to a repository under the provisions of your publisher's self-archive policy. An author may not be able to share the final manuscript without an embargo. If the publisher requires an embargo, you may need to negotiate with your publisher before you accept the terms of publication, choose a different publisher, or choose to publish as open access, which may involve an Article Processing Charge (APC). If you choose to pursue open access publication, University Libraries encourages you to explore available funding opportunities through our Open Access Fund. 

How do I go about making my research data publicly available?

Along with your final published manuscript, your associated research data will also need to be immediately available for dissemination and analysis. This may include items such as collected metrics, charts of results, figures, spreadsheets, transcripts, recordings, or other raw data that you used to substantiate your findings. As a requirement for funding, most agencies require you to specify how you will archive and distribute your data with a Data Management Plan. In your plan, you should specify a publicly accessible repository, such as the university's Digital Commons or another repository that is required or recommended by your funding agency. 
 

How do I know if my funding agencies are subject to this new policy?

All federal agencies that fund research will be subject to this new policy, but the individual agencies will have discretion in how this policy is enacted. Grants.gov provides a list of all the grant-making federal agencies.
 

Are there any existing policy examples that I can read to get an idea what a public access policy looks like?

Yes. Science.gov provides a list of current U.S. Federal Agencies’ Public Access Plans. This list is updated as new plans are enacted. 

Portions of this page were adapted from texts compiled by Princeton University Library and Yale University Library.