The EDCH's Response to the NIH Request for Information on Maximizing Research Funds by Limiting Allowable Publishing Costs

General
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The European Diamond Capacity Hub (EDCH) would like to respond to the NIH Request for Information on Maximizing Research Funds by Limiting Allowable Publishing Costs. As they stand now, the NIH proposals lack nuance in that they treat all publishing services in the same undifferentiated way. In addition, these proposals represent a missed opportunity to use public funds to nudge the scholarly publishing system towards fairer and financially transparent publishing solutions, the adoption of more Open Science principles, and not-for-profit, scholar-led academic publishing.

The EDCH agrees with NIH that it is important to limit publishing costs that currently channel 28-40% profits to the shareholders of large corporate publishers (Springer Nature reported an adjusted operating profit margin of 28% in 2024 and Elsevier has a “roughly 40% profit margin). The EDCH believes it is imperative that the funding to support such costs be redirected to bring scholarly publishing back under the control of the academic community. We would recommend that NIH mandate that its funded authors deposit their preprints and Author Accepted Manuscripts (AAM) into PubMed Central at no cost to NIH or themselves. This measure would enable NIH to invest funds previously directed to APCs in shared infrastructure, repositories, and community-driven publishing models such as Diamond Open Access (OA). Diamond OA is a not-for-profit publishing model in which content-related elements are entirely controlled by the academic communities, no costs are charged to either readers or authors, and service-related elements (copy-editing typesetting etc) can be outsourced competitively to publishing service providers. The EDCH also believes that any measures to limit the cost of publishing should be formulated in such a way as to ensure access to reading and publishing for all researchers worldwide, to encourage and reward Open Science practices including open/transparent peer review, and to increase the trustworthiness, transparency, and openness of the scholarly process.

Option 1: Disallow all publication costs

NIH could no longer support publication costs through any funding mechanism. Some private funders have disallowed costs for peer-reviewed publications as they seek to place increased value on preprints.

The EDCH does not believe that NIH should stop supporting publication costs for peer-reviewed publications as this will undermine peer review, the cornerstone of science itself. A scholarly communication system that merely consists of unreviewed preprints would be a disaster for knowledge curation. The most valuable part of publishing is the conversation between authors, reviewers and editors, which is part and parcel of research and should be funded. The publication of peer-reviewed articles should thus be financially supported, and this should not be reduced to a binary choice between paying for APCs or not. NIH support for publication costs should be directed towards fair and community-owned publishing solutions. For example, NIH may want to phase out or stop paying for APCs to publishers who do not provide fair publishing solutions to authors who cannot afford APCs. One such fair solution is Subscribe to Open (S2O) for example: NIH could consider allowing authors to make fixed contributions to their institutional libraries who support S2O publishers and journals. In addition, NIH should allow researchers to use their funds to pay for contributions to Diamond OA journals, for instance the Voluntary Author Contributions (VACs) that Diamond Open Access journals often accept. These contributions should not be capped, as they are typically a fraction of APCs, and contribute to a not-for-profit, scholar-owned publication system. This will accelerate the necessary and welcome transition from corporate publishing to community-controlled not-for-profit Diamond OA publishing. In addition, NIH should indeed follow the example of some private funders such as the Bill & Melinda Gates Foundation, Wellcome, and HHMI, who place increased value on (open or transparently peer reviewed) preprints, as these represent a less expensive publishing process that in addition supports the principles of Open Science in a way that typical corporate publishing does not. Various repositories can be marshalled with minimal investment into managing and accommodating peer-reviewed preprint services, as shown by repository projects from Arxiv to Notify.

Option 2: Set a limit on allowable costs per publication

NIH could limit allowable direct costs to $2,000.00 per publication, including APCs and other fees. This amount is between what NIH found as the average global APC ($1,235.51) and the average requested in budgets (approximately $2,600.00-3,100.00), and close to the average for U.S. published journals’ APCs ($2,177.00).

The EDCH does not believe that setting a cap on APCs will contribute to a financially healthy and sustainable publishing environment. First of all, setting a cap implicitly recognizes the arbitrary and untransparent prices that corporate publishers have assigned to their services without ever providing a transparent breakdown of such costs. The lack of enthusiasm of corporate publishers for providing financial transparency has been amply proven by the limited success and discontinuation of the cOAlition S price and services transparency framework and its attendant Journal Comparison Service.

Secondly, setting a cap will make some publishers increase their prices to meet the cap, while others will see the cap as a baseline they can comfortably rely on while charging authors for additional services. Third, setting a cap will exacerbate current imbalances between researchers nationally and internationally: by setting a cap, NIH will further contribute to imbalances between funded and unfunded researchers in the US on the one hand–with only funded researchers be able to afford the capped price from their research funds–and on the other hand researchers from less privileged countries, who will simply not be able to afford even a capped price. The proportional financial weight of NIH on the global research ecosystem in terms of grants funded is such that an APC cap would have considerable repercussions worldwide, as it would de facto set a baseline price for publishing services for the rest of the world as well. Finally, an APC cap represents an implicit recognition that the cap corresponds to a reasonable publication cost that does not require any further motivation in terms of price breakdown and transparency.

Option 3: Set a limit on allowable costs per publication and allow a higher amount to be paid when peer reviewers are compensated

NIH could adopt the $2,000.00 limit per publication in Option 1, and allow a higher limit of $3,000.00 per publication when publishing in journals that compensate peer reviewers at a level equivalent to the average hourly wage reported by the U.S. Bureau of Labor Statistics.

The EDCH very much disfavors this option for various reasons. First of all, compensating reviewers would be an invitation to corporate publishers to further monetize the publishing ecosystem. We would be leaving behind the current system that is based on reciprocity: researchers review because they expect their work to be reviewed in turn. A pay-for-reviews system will also introduce perverse incentives to scholarly publishing: in addition to paper farms, a cottage industry of superficial reviewing farms will spring up, causing problems for editors and journals worldwide. Secondly, payments for reviews are very impractical, as they would put a considerable administrative burden on any publisher: it is well known that the micro-payments that compensation for peer reviewing represents result in disproportional administrative costs on those who have to manage it. This will considerably add to the cost of publishing rather than alleviating it.

Rather, NIH should develop other measures to value and recognize peer reviews, for example by asking applicants to mention their Open Peer Reviews alongside their publications, or by asking them about their review-to-submission ratio: typically, a researcher should contribute two reviews for every paper they submit to a journal, since every paper requires two reviews. The balance of the reviewing commons must be preserved by valuing, and recognizing it appropriately without financial compensation (see also Chan, T. T., Pulverer, B., Rooryck, J., & CoARA Working Group on Recognizing and Rewarding Peer Review. (2025). Recognizing and Rewarding Peer Review of Scholarly Articles, Books, and Funding Proposals: Recommendations by the CoARA Working Group on Recognizing and Rewarding Peer Review. Zenodo. https://doi.org/10.5281/zenodo.15968446)

Option 4: Set a limit on the total amount of an award that can be spent on publication costs

NIH could limit the maximum amount of an award that could be spent on publication costs to 0.8% of the award’s direct costs over the length of the award or $20,000.00, whichever is greater, in order to not disproportionately impact smaller awards.

The EDCH would be in favor of setting a progressively decreasing limit on publication costs for APCs charged by corporate publishers and by publishers who do not provide fair publishing solutions to authors who cannot afford their APCs. NIH should consider eventually phasing out payments to such publication services. However, the EDCH would plead for not putting such a limit on the amount that can be spent on Voluntary Author Contributions to Diamond OA journals, with the aim of promoting not-for-profit scholarly publishing whose content-related elements are controlled by the scholarly community. Similarly, there should be no limit on spending on APCs for journals that provide open/ transparent peer review.

Option 5: Set a limit on both the per publication cost and the total amount of an award that can be spent on publications

NIH could limit both the total amount of an award that could be spent on publication costs to the greater of 0.8% of the award’s direct costs or $20,000.00 over the life of the award, in addition to limiting the amount per publication to $6,000.00.

While this option offers authors flexibility, it does nothing to inflect authors’ choices towards fair publishing solutions such as Subscribe-to-Open or the not-for-profit scholarly publishing options of Diamond OA. The EDCH strongly believes that the NIH options for the payment of publishing costs should be flanked by measures that increase fair publishing solutions for authors who cannot afford APCs, and not-for-profit publishers who serve the sovereignty of science and scholar-led academic publishing.

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The NIH has published the public comments submitted in response to their RFI on Maximizing Research Funds by Limiting Allowable Publishing Costs:

A total of 914 responses were received, including the one submitted by the EDCH. For discussion, I’m sharing here the LinkedIn thread by Ashley Farley (Senior Officer for Knowledge & Research Services at the Gates Foundation). It’s an interesting thread, which I am copying below for reference:

  • Excellent point “I suggest NIH give serious thought and debate to evolving our publication model to a system that would minimize these hidden costs. Because I would estimate very roughly that anywhere from 10% to 25% of a grant budget is consumed doing unnecessary and unproductive/uninformative experiments required for publication acceptance which otherwise would be spent on advancing the research grant aims further by new investigations.”
  • Continued excellent point “As scientists, we have abdicated our responsibility to evaluate new science. Instead we turn it over to the impact factor of journals in which the science is published. This leads to a large fraction of grant costs going to support research for the sake of publishing in a “high-impact” journal rather than to advance scientific knowledge per se.”
  • After reading through the first few it strikes me (or continues to strike me as I’ve been thinking about this more and more as of late) how comfortable many researchers are at the thousands of dollars of price tag for APCs without knowing really what that is paying for. I would then assume that authors are seeing value for that money spent aside from the article being openly available but it’s difficult to say. I know that most of these responses will be US/Global North focused. And I’ve always been accused of “selling out of my own pocket” but it pains me process APC invoices for multiple thousands of dollars.
  • It seems wild to me that there is a comfortability that one award may have $20,000 dollars of APCs. Knowledge dissemination is critical and we know publishing does cost. But it doesn’t have to cost that much for one award. So much of that budget could be funding the people or research work.
  • This is an interesting claim that I would love to see a citation for “Recent analyses of biomedical journal publishing indicate substantial editorial and quality-control expenses justify higher APCs”. Is that APC money really going to improved quality control? Much of the editorial work is unpaid. Peer reviewer do not have access to tools to improve quality or catch fraud. Most times they don’t even have access to the underlying data. From the research I’ve seen it’s prestige and commercial publishing that is resulting in higher APCs. This is not justifiable.
  • Some responses mention working with and regulating journals around cost transparency and price adjustments. I just don’t see this ever being successful - especially for the large commercials. There has already been a lot of experimentation in this space and not a lot of success. There is no motivation to make the APC business model more fair.
  • The theme of high APCs = high impact journals = higher chances of promotions should be very concerning to the research community. It is already the case that the better funded an institution the higher than chances those researchers will have to publish in higher impact journals. This shows that high impact journals are not necessarily sharing the best/most impactful/novel research - just the highest funded work. This isn’t how we should want the overall system to work
  • “although the entire manuscript was freely available via preprint, we had to pay $3,500 instead of $0 due to open-access requirements for rights to upload to PMC. Tax payers paid $3,500 for material they had free access to.” This is the fault of the publisher policies! Not the funder policy!! This is how publishers will continue to extract as much money from the research publishing ecosystem as possible.
  • Many academics are very much still concerned about predatory publishing. Haven’t seen much recent research as of late on how big the issue may be.
  • If this ends up being the case doesn’t this show that equating journal title to quality is inherently wrong? And that publishing has become very pay to play? “Where will the funds come from to publish NIH supported research? The journals are still charging the amounts they charge. This may result in NIH funded research being relegated to journals of lesser stature, which may be interpreted by the scientific community and the lay public as meaning of lesser importance or lesser quality studies, even when they are rigorous and important studies.”
  • I would love to hear the story behind this “There is a reason why PubMed used to be called “Publish or Perish””
  • Now this is a fantastic idea! “The easy way is for NIH to start a publication system along with NCBI/Pubmed, such that all the articles emerging from NIH-funded research must be submitted through this platform, which will automatically be incorporated into Pubmed. The NIH can ask funded researchers to serve as reviewers and editors. In fact, NIH can give a small incentive to researchers interested in being reviewers/editors. This incentive can be built at the time of grant budgeting. Why pay $20,000 from an NIH grant to an outside publisher as APC, when the same $$ could be used wisely within the NIH framework to get the article published. Plus, as an NIH-funded research output, the articles should have fewer issues with scientific misconduct etc.,”
  • If “NIH research will be limited to being published in garbage journals” becomes true would those journals no longer be garbage?
  • Yup! “Given the existence of PMC and of pre-print servers, high cost of publishing is really just a tax by prestigious journals that is being paid by researchers. Just as a Chanel handbag costs more than a Target handbag, publishing in Nature or Science is more expensive due to branding. Taxpayers should not support fancy brands, it should be to make work accessible. Therefore I think the $2000 per article cap will achieve that goal”
  • :heart_on_fire: “Given how hard scientists work for their grant money, I don’t see the same level of effort from publishers and therefore I resent sharing my hard-earned grant money with them in the form of incredibly high publishing costs.” :heart_on_fire:
  • :clap: :clap: :clap: “For-profit editorial work is lengthy, costly, and simply not worth it.”
  • It’s clear by the comments that the current peer review structure is incredibly overtaxed - it seems mixed as to whether or not compensation would improve this. I think this points to the larger need to rethink the structure, need, and execution entirely. It’s clearly overburdening the system in many ways.
  • It’s concerning to see the number of researchers who state that the NIH should have a preference for non-profit or society journals but then list society journals that are managed by the large commercial publishers.
  • This is a laughable comment “Most journals (for example, non-profit society journals like the American Chemical Society) do not have money available for peer review.” From the ACS 2024 financial overview “As of December 31, 2024, the American Chemical Society (ACS) had $75.1 million in cash and cash equivalents”. They could pay peer reviewers easily.