IOI recently responded to the US National Institutes of Health Request for Information on Maximizing Research Funds by Limiting Allowable Publishing Costs. In this post, you will find the prompts from the Request for Information and our responses.
NIH seeks input on the option, or other option not considered in the Request for Information, that best achieves the goal of balancing flexibility in providing research results with maximizing the use of taxpayer funds to support research.
We commend the NIH for its leadership in ensuring publicly funded research is freely and rapidly accessible. Since its first public access policy in 2005, NIH has consistently advanced transparency, reproducibility, and the public value of research.
Invest in Open Infrastructure (IOI) works globally with academic institutions, infrastructure providers, publishers, and funders to strengthen the systems that enable open research. Our experience, including our 2023-2025 NSF-funded “Reasonable Costs” study on the costs of public access to research, resoundingly shows that investments made in shared, open infrastructure that make research outputs maximally available to the public, offer a higher return on taxpayer dollars than payments made towards rising article processing charges (APCs).
We respectfully recommend that NIH prioritize direct investment—centrally and/or through allowable costs—in existing open infrastructure to disseminate research outputs. This includes repositories that support “green” open access, preprint servers, open data platforms, and “diamond” open access publishers that operate without APCs. These models are proven, widely used, and more cost-effective than channeling funds into APC-based publishing systems.
There are precedents for this approach, as documented in IOI’s NSF-funded study on “Reasonable Costs”. As one example, in a Costing Case Study conducted by the Digital Endangered Languages and Musics Archiving Network (DELAMAN), the authors propose that grant budgets set aside 8% of direct costs to an archive that will host the data of a funded project. A similar percentage-based allowance could ensure NIH-funded outputs are preserved and openly disseminated through repositories and community-led infrastructure, while containing overall costs.
By shifting investment from escalating APCs to shared infrastructure, NIH can maximize the impact of every taxpayer dollar, accelerate knowledge dissemination and use, and strengthen the integrity and sustainability of the open research ecosystem.
NIH seeks any evidence (either from your own work or other publicly available sources) that can be publicly shared that addresses the considerations of one or more of the options.
The operational complexity of administering the current APC-driven system results in inefficiencies and hidden costs for both research performing organizations and the NIH. Research institutions, for example, bear significant hidden costs related to negotiating and managing publisher agreements (such as read-and-publish agreements) and individual APC payments. In IOI’s 2023-2025 NSF-funded “Reasonable Costs” study, we found that research institutions, including liberal arts colleges, R1 and R2 universities, and research laboratories, struggled to estimate the magnitude of hidden and direct costs related to meeting future public access requirements due to a lack of price transparency and the complexity each institution faces in managing hundreds of distinct publisher agreements, some through consortial environments. Our project produced a model “cost calculator” that aimed to assist with such estimations; in our pilots with major institutions, we found that the cost calculator still required a level of clarity and consistency in local accounting and invoicing practices that is effectively and structurally hindered and undermined by publishing agreement practices.
Consider a case study illustrating this complexity: An NIH-funded researcher tries to publish in Journal A. They hit a paywall with an article processing charge and a note saying, “Your institution may have a discount, contact your librarian.” The librarian chases down a licensing specialist, confirms whether the contract covers this particular journal, checks fine print about eligible article types, determines if a special discount code is needed, and finally logs the transaction in a tracking system so the institution doesn’t exceed its quota in the next contract negotiation. What looks like a simple discount turns into a chain of emails, checks, and compliance steps—an invisible burden on institutional staff and resources, and a convoluted and hard-to-trace financial trail. These costs don’t show up clearly in publisher invoices, but they are real costs, and they add up. If NIH is serious about efficient, equitable public access, it has to account for the true cost of managing increasingly complex arrangements.
In an analysis of published research resulting from NIH-funded studies, Haustein et al. (2025) found that the lowest of the proposed caps ($2,000) would not cover APCs in the majority of cases and that some APCs already exceed even the highest of the proposed caps. Specifically, the $2,000 cap would only fully cover 6 percent of papers the authors identified in their study. APC prices have been rising for decades, outpacing inflation, as have large, conglomerate publisher revenues, in part owing to their shift to APCs over subscriptions. Most publishers have offered little transparency about what APC fees cover and how they relate to actual costs of publishing. Given these trends, we respectfully contend that the proposed caps would not incentivize publishers to lower their APCs, and would instead leave researchers and academic institutions scrambling to fill gaps through other sources, further straining limited research and library budgets. Researchers unable to make up the difference between the allowable costs and actual APC (which could run more than $6,000 per article according to Haustein et al.) could be forced to choose less prestigious outlets, limiting author choice and potentially damaging the visibility of high-impact research.
One key step in this process is greater pricing transparency. We encourage the NIH and other agencies to submit APC data to the OpenAPC project in order to improve global reporting on APC costs.
NIH is interested in hearing ideas about factors related to paying for peer review. Specifically, NIH invites input on factors that NIH should consider in determining whether peer reviewers are appropriately compensated.
Peer review has been operated by publishers (both for and non-profit), usually as a volunteer contribution from academic researchers that comes with no monetary compensation and that lacks transparency. This expected volunteerism becomes especially problematic when publishing organizations, who rely on the volunteer-based peer reviewers’ work to inform their own selection and editing of research works, yield significant profits from these published works without reinvesting back into the research ecosystem, reviewers, or supporting infrastructure. We are inspired by open infrastructure models for more equitable peer review such as initiatives led by PREreview and PeerCommunityIn.
In addition to compensating peer reviewers, other kinds of publishing best practices, such as use of automated fraud detection capabilities, may contribute to higher publishing costs. NIH is seeking further input on additional factors that it should consider in determining the allowability of a higher per publication cost.
The traditional closed scholarly publishing system does not sufficiently serve NIH’s interest in rapid, transparent, and cost-effective public access to research results or the acceleration of scientific discovery. Encouraging the use of (and directly supporting) trusted preprint and open data repositories and other open infrastructures aligns with the NIH’s goals and decouples the specific goals of public access from the distinct processes of formal publication and evaluation.
At IOI, we have reviewed hundreds of open infrastructure solutions as part of our development of Infra Finder. These include robust and varied tools that enhance the potential for discovery and reuse; support research integrity by facilitating transparent review; accelerate progress by rapidly disseminating results; and link diverse outputs such as preprints, data, and code. These tools were developed to address gaps and dissatisfaction with traditional publishing. They use open standards, machine-readable metadata, persistent identifiers, and other technologies that advance the goals of public access. We see investment in improving and connecting these systems as a key to increasing the impact of NIH-funded research. Choosing open infrastructure for this work means that efforts made to improve one system will be magnified as others interoperate with and build off of its capabilities.