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The Cost of Confusion: Dispelling Myths about the NIH Public Access Policy and Article Processing Charges

Last July, the NIH issued an RFI on limiting direct spending on article processing charges (APCs). Over 900 public responses offered valuable perspectives but also exposed widespread misconceptions about the NIH Public Access Policy and scholarly publishing.

Nine black vultures perched on a log and one in flight about to land on it. The image is in monochrome. Vultures on a log. CC-BY 4.0 Christopher Marcum
Vultures on a log. CC-BY 4.0 Christopher Marcum

Last July, the NIH issued a Request for Information (RFI) on maximizing research funds by limiting direct spending on Article Processing Charges (APCs) in allowable publishing costs. More than 900 members of the public responded to the RFI, providing valuable insights into the diverse perspectives the NIH should consider in deciding on a path forward with APCs. The responses also revealed a landscape cluttered with misconceptions, misinformation, and myths about the NIH Public Access Policy and scholarly publishing in general. Here, we look at the responses from the lens of dispelling a few of those myths. We include a selection of excerpts from the RFI responses that reflect both the myths and the realities they betray. 


"The Only Way to OA is Pay-to-Play" Myth: NIH's immediate public access mandate requires researchers to pay expensive APC fees to journals.

The Reality: Authors can achieve full compliance with the NIH policy at zero cost by depositing their author accepted manuscript directly into PubMed Central, even when publishing in traditional subscription journals.

By far the most common misconception appearing in the RFI responses is that NIH public access policy has essentially forced researchers into a "pay-to-play" system. One respondent captured this myth perfectly: "The NIH recently mandated that research paid for with NIH funding must be available immediately upon publication, authors are currently required to pay OA fees for many journals, which becomes quite expensive quickly." (Respondent 48). Another researcher reported being told by Wiley that "U.S. based investigators" must now "pay for open access and we are not allowed to submit to PubMed Central prior to their embargo period." (Respondent 325). These stories reveal how publishers have sent misinformation to effectively scare researchers into paying Article Processing Charges (APCs).

In reality, the challenge is not the NIH policy itself, but publishers attempting to monetize a compliance requirement that should cost researchers nothing. Authors can achieve full compliance with the NIH policy at zero-cost by utilizing the "Green" Open Access (OA) route. This preferred path involves depositing the author accepted manuscript (the version of the paper after peer review but before the publisher's final formatting) directly into PubMed Central. Crucially, this option remains available even if the author chooses to publish their final version in a traditional subscription journal behind a paywall. Some publishers may assert that authors must pay-to-play but that is wrong: NIH-funded researchers can exercise their rights to share the author accepted manuscript without ever having to pay an APC.

As one commenter noted, "Authors need explicit communication from NIH stating that when they agree to receive funding from NIH they also agree to the Federal Purpose License which allows them to retain the rights to deposit their author accepted manuscript, in PMC (or another agency approved repository), irrespective of any conflicting statements from publishers." Another urged that "practices such as blocking repository deposits or charging additional fees for copyright retention should not be permitted."

Selected excerpts from comments related to this myth:  


“Many journals still have a 6-month embargo on publications being deposited in PMC, so authors are forced to pay very high open access fees to comply with this NIH policy.” - Respondent 800


“To comply with this, Wiley, for example, is now requiring U.S. based investigators to pay for open access and we are not allowed to submit to PubMed Central prior to their embargo period.” - Respondent 325

“We recently had a paper published in Nature, with a requirement of paying an APC of $11,000, or publishing by the subscription model. We had to choose the latter. But now our paper is locked up from PubMed for a year.” - Respondent 393

“Due to the sudden change in NIH policy I have an article that was submitted before NIH announced the change in policy and published after July 1. The publisher is Elsevier. They expect me to now pay $3,250 for OA fees and do not allow depositing the author accepted manuscript without an embargo. This is ridiculous.” - Respondent 210

“Practices such as blocking repository deposits or charging additional fees for copyright retention should not be permitted.” - Respondent 768


“Authors are therefore feeling forced to opt for gold OA and pay. Authors need explicit communication from NIH stating that when they agree to receive funding from NIH they also agree to the Federal Purpose License which allows them to retain the rights to deposit their author accepted manuscript, in PMC (or another agency approved repository), irrespective of any conflicting statements from publishers.” - Respondent 811


"Price = Quality" Myth: High APCs (e.g., $10k+) are necessary to fund "rigorous" peer review and high-quality science.

The Reality: The integrity of peer review depends primarily on the expertise and diligence of reviewers and editors, not on the price of publication.

Several respondents associate higher APCs with greater scientific rigor and journal quality. However, recent high-profile scandals have proven that high APCs often act as a "prestige tax" rather than a guarantee of accuracy. Comments like "the better the journal, typically, the higher the publication cost" and "I think that having a HIGHER QUALITY JOURNAL as rated by its impact factor or rank in its field as a TOP TIER journal, should be the main criteria for whether the journal is allowed to have a higher APC" reflect a widespread belief that price signals quality. One respondent even argued that journals like "Nature Communications or Cell Reports, that cost around $5,000" attract "higher quality papers and reviewers, making the costs somewhat justifiable."

High-profile incidents—such as AI-generated anatomical diagrams that passed peer review in a Gold OA journal, or retractions of ambient temperature superconductor studies in prestige journals—illustrate that even substantial publication fees do not guarantee accuracy or rigor. These cases reveal an important distinction: the integrity of peer review depends primarily on the expertise and diligence of reviewers and editors, not on the price of publication. Instead of funding rigorous validation, these exorbitant costs often subsidize corporate profit margins and the marketing of "impact factors." 

As one commenter observed, "The burden of evidence should be on the publishers to justify charging the creators of the work for the rights and then turning around and charging subscription fees. They have stumbled into a monopoly on journal prestige and that's it." While publication fees support infrastructure and services, they do not directly enhance the quality of peer review or the research itself. Understanding this distinction can help researchers make more informed decisions about where to publish, focusing on journals with strong editorial practices and rigorous peer review processes regardless of their business model or fee structure.

Selected excerpts from comments related to this myth:

“The better the journal, typically, the higher the publication cost.” - Respondent 134


“Existing costs of high quality publishing cannot be met by the proposed cap” - Respondent 797


“The burden of evidence should be on the publishers to justify charging the creators of the work for the rights and then turning around and charging subscription fees. They have stumbled into a monopoly on journal prestige and that's it” - Respondent 106


“Simple examples are Nature Communications or Cell Reports, that cost around $5,000. These journals attract higher quality papers and reviewers, making the costs somewhat justifiable. Although I do agree that some Springer Nature costs are needlessly excessive.” - Respondent 142

“I think that having a HIGHER QUALITY JOURNAL as rated by its impact factor or rank in its field as a TOP TIER journal, should be the main criteria for whether the journal is allowed to have a higher APC .” - Respondent 576



“Compliance is Burdensome” Myth: Depositing research into PubMed Central is a difficult, time-consuming administrative hurdle.

The Reality: The NIHMS system used by PubMed Central is designed to be a straightforward process that takes minutes, not hours.

Less evident, though still present in a few responses, is the myth that complying with the NIH Public Access Policy is onerous. A few respondents complain that depositing into PubMed Central is an "administrative burden" that steals time from actual science. This myth persists because the legacy publishing system has led researchers to believe that only a publisher can handle the "heavy lifting" of distribution. 

However, the NIHMS system used by PubMed Central is designed to be a straightforward process that takes minutes, not hours. The perceived "difficulty" reflects a publishing culture that has traditionally prioritized commercial channels over public stewardship. Shifting our perspective from viewing deposition as a 'burden' to recognizing it as stewardship reveals that this small act ensures research remains a public good, accessible to everyone regardless of their institution's budget or remaining grant balance 

Many commenters recognized this, noting that "researchers conflate OA with payment of APCs and it would be so helpful if NIH could continue to emphasize use of the repository ecosystem." One suggested that "a more effective and cost-neutral solution would be to mandate the deposition of preprints, including the final revised version submitted to the journal, in a public repository." Another advocated that "NIH should strengthen repository-based access by requiring immediate deposit of manuscripts in PubMed Central through no-cost options. Investment in community-owned infrastructure—such as repositories, preprint servers, and diamond open access platforms—would provide lasting alternatives to extractive commercial publishing practices."

Selected excerpts from comments related to this myth:

"Researchers conflate OA with payment of APCs and it would be so helpful if NIH could continue to emphasize use of the repository ecosystem. Leverage the Federal Purpose License in order to make publications (and other research outputs) resulting from taxpayer funding freely available (at least to read- if not reuse) to the public that paid for the underlying research." - Respondent 30

“The current problem stems from the NIH mandate requiring open access publication. In practice, this functions as a subsidy to publishers. A more effective and cost-neutral solution would be to mandate the deposition of preprints, including the final revised version submitted to the journal, in a public repository.” - Respondent 129

“While open access is nice, it is expensive, can be burdensome for researchers to comply (particularly when they are not corresponding author) and I have to question whether it's necessary when a person can typically reach out to get a copy of a manuscript by contacting the corresponding author.” - Respondent 186

“While I agree that some limits make sense, I would urge you not to put a large new regulatory burden on us. There is already a ridiculous amount of money spent dealing with NIH regulations and reporting requirements.” - Respondent 128


“NIH should strengthen repository-based access by requiring immediate deposit of manuscripts in PubMed Central through no-cost options. Investment in community-owned infrastructure—such as repositories, preprint servers, and diamond open access platforms—would provide lasting alternatives to extractive commercial publishing practices.” - Respondent 694



The "Cost Recovery" Myth: Publishers charge high APCs simply to cover their essential "production costs.

The Reality: Major commercial publishers consistently report surplus revenues and profit margins that exceed those of tech and automotive giants, suggesting APCs far exceed actual production costs.

Some respondents, particularly those within the publishing community, contend that high APCs are a direct reflection of the underlying labor and infrastructure costs required to publish a scholarly article as open access. Several argued that "it is fair that a publisher gets paid for adding this value [formatting/editing]" and that "APCs are needed to support their own journal operations." One detailed response noted that "a journal with a low acceptance rate will need to charge a significantly higher APC than one with a high acceptance rate - to recoup costs associated with processing articles ultimately rejected."

While it's true that publishers have operating expenses associated with article production, there is a remarkable lack of transparency on what those costs truly are. Publishers rarely, if ever, disclose itemized per-article costs or the specific value added at each stage of production. Without this data, "cost recovery" becomes a black box used to justify pricing that far exceeds the actual expense of (predominantly) digital hosting and editorial management. As one experienced editor observed: "I have been an editor for two different journals, and far more time is spent now by the editors triaging papers; less than half go out for peer review. Science supposedly only sends out 10% of its submitted papers for review. So the charge to authors now bears little resemblance to the actual costs of publishing.

Publishers claim they are simply covering their bases, the reality is that major commercial houses consistently report surplus revenues and profit margins that exceed those of many tech giants. Much of those margins result from the free labor of researchers and reviewers and are further subsidized by public funders. We do not know how much surplus revenue a single article generates because that data is not readily disclosed, making it impossible to verify if a $500, $2500, $5,000, or $10,000 fee is a necessity for survival or a strategic contribution to a double-digit profit margin.

Selected excerpts from comments related to this myth:

“I have been an editor for two different journals, and far more time is spent now by the editors triaging papers; less than half go out for peer review. Science supposedly only sends out 10% of its submitted papers for review. So the charge to authors now bears little resemblance to the actual costs of publishing.” - Respondent 24

"It is fair that a publisher gets paid for adding this value [formatting/editing]." -  Respondent 56 


“APCs are needed to support their own journal operations." - Respondent 80 


“Any potential limit on costs needs to recognize that the costs of publishing vary considerably across publishers – depending on size, selectivity and additional services provided to authors and readers. Notably, a journal with a low acceptance rate will need to charge a significantly higher APC than one with a high acceptance rate - to recoup costs associated with processing articles ultimately rejected.” - Respondent 757


“A blanket cap on APCs can undermine efforts to push for greater pricing transparency, allowing lower quality journals to charge the maximum allowable cost, while journals with higher per-article production costs may be forced to make compromises and cut corners to compete.” - Respondent 819



“Censorship” Myth: Capping the amount of grant money spent on APCs is an attempt to "block" science or "censor" findings.

The Reality: Fiscal caps are a standard tool for responsible stewardship of public funds and have been successfully implemented by other major research funders without blocking science.

More than a few respondents to the RFI expressed concern that NIH capping APCs, or engaging in any form of publication control at all, amounts to a form of censorship. Some worried that "with the financial burden of mandated open access, we will be forced to limit the number of publications, combine findings that would otherwise merit individual papers, and reduce opportunities for trainees." Others saw more sinister implications, suggesting that "one can also see the process effectively leading to financial censorship of science. Novel ideas can be suppressed to archival journals if the authors don't have the money for page charges."

Several commenters expressed concern about equity impacts, noting that such policies "will do nothing but disadvantage smaller and/or public schools with less discretionary funding.” One respondent warned that "placing per-publication limits may impact the ability of certain disciplines differently, introducing a new form of unintentional censorship on research findings."

This narrative mistakenly equates a refusal to pay APCs with an appetite to suppress research. In reality, fiscal caps are a standard tool for responsible stewardship of public funds. Other major research funders have already paved this way without "blocking" science: the Gates Foundation and HHMI both recently shifted to a model that prioritizes preprints and no longer pays for APCs at for-profit journals, while PCORI (the Patient-Centered Outcomes Research Institute) has long maintained specific limits on publication costs. These organizations recognize that science is "blocked" by paywalls, not by budget caps that encourage researchers to use more equitable and cost-effective publishing venues.

Selected excerpts from comments related to this myth: 

“With the financial burden of mandated open access, we will be forced to limit the number of publications, combine findings that would otherwise merit individual papers, and reduce opportunities for trainees.” - Respondent 148


“One can also see the process effectively leading to financial censorship of science. Novel ideas can be suppressed to archival journals if the authors don't have the money for page charges.” - Respondent 702


“Critically: you will do nothing but disadvantage smaller and/or public schools with less discretionary funding. This rule would mean little to the Harvards, but would mean a lot to schools without huge endowments and thus very little discretionary funding.” - Respondent 794

“Completely disallowing publication costs (option 1) or severely limiting them (options 2-3) would prevent researchers from publishing their work, blocking the primary mechanism for disseminating scientific findings to the public.” - Respondent 803

“Placing per-publication limits may impact the ability of certain disciplines differently, introducing a new form of unintentional censorship on research findings.” - Respondent 914


Conclusion
The RFI responses reveal the tremendous pressures NIH-funded researchers face within a publishing system that has created widespread confusion and financial burdens. Respondents shared firsthand accounts of publishers blocking manuscript deposits, demanding thousands of dollars in fees, and providing contradictory information about compliance requirements.  These misconceptions are not the fault of researchers or NIH’s policy, but the direct result of certain publisher practices designed to extract maximum revenue from federally funded research. These publishers have exploited the policy transition to spread misinformation, assert rights they do not hold, and position themselves as gatekeepers to compliance that should cost researchers nothing.

Myths about pay-to-play access, cost-driven rigor, administrative burden, and censorship persist largely because they serve existing power structures and incentives that reproduce inequities in the system. These myths do not reflect policy reality. NIH and the researchers they fund already possess the tools and infrastructure needed to comply with public access requirements at no cost: rights retention, the Federal Purpose License, and author accepted manuscript deposit. 

Researchers should not have to navigate publisher misinformation or face financial penalties to fulfill a public good. Dispelling these myths is a prerequisite for redirecting public research dollars away from extractive publishing practices and toward community-owned infrastructure that better serves science and the public. If NIH’s goal is to maximize the impact of taxpayer-funded research, then protecting researchers from extractive publishing practices and ensuring free, equitable access to publicly funded science must be the priority.

Copyright © 2026 Christopher Steven Marcum, Corinna Turbes. Distributed under the terms of the Creative Commons Attribution 4.0 License.

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