In September, Stratos, Rapid Science, and ICOR submitted a joint open letter in response to an open request for information by the National Institutes of Health (NIH). The NIH requested feedback on how it might maximize the impact of tax-payer funded research grants by placing limits on publishing costs. The proposal would limit Article Publishing Charges (APCs) beginning January 1, 2026.
The agency proposed five possible policy approaches with different levels of grant support for APCs, as follows:
- Disallow all publication costs — Under this model, the NIH would no longer support APCs
- Set a limit on cost per-publication — Under this model the NIH would limit direct APCs to $2,000 apiece based on research into average APCs and average budget requests
- Limit costs per-publication but offer a higher amount in cases where peer reviewers are compensated — Under this model, the same $2,000 APC limit would apply, with an additional $1,000 to allow journals to compensate peer reviewers. The increased amount might also apply to automated tools.
- Limit the percentage of the grant that can be put toward publication costs — Under this model, .8% or $20,000 of the grant could be put toward publication costs, whichever is higher.
- Limit both the percentage of the grant and the cost per-publication — Under this model, 8% or $20,000 of the grant could be put toward publication costs. The cost per-publication would be limited to $6,000.
Our letter endorses the first option: Disallow all publication costs. We believe this is the only way to change the incentivization structure and bring about a true paradigm shift that empowers faster, more efficient, innovative, and transparent scholarly communication — and by extension more rapid scientific progress.
In addition to disallowing publication costs, we also encourage the NIH to mandate preprints with underlying data and other research outputs, and to credit data-complete preprints and preprint reviewing in grant decisions and research assessment, making preprints, rather than journal articles the primary method of sharing research.
September 15, 2025
Dr. Jay Bhattacharya
Director
National Institutes of Health
Dr. Lyric Jorgensen
Director, Office of Science Policy
National Institutes of Health
Dear Drs. Bhattacharya and Jorgensen,
Rapid Science is writing in response to the NIH NOT-OD-25-138 Request for Information on Maximizing Research Funds by Limiting Allowable Publishing Costs (RFI). Rapid Science, founded in 2013 to accelerate the pace and accuracy of scientific discovery through open, equitable and collaborative practices, and its family of associated projects support the NIH’s efforts to lower costs for scholarly publishing. In addition to this letter, we have submitted our responses to the specific questions in the RFI using the online comment form.
As a 501(c)(3) fiscal sponsor, Rapid Science connects and strategizes with organizations offering real-world solutions that transform vision to policies and practices, including Incentivizing Collaborative Open Research (ICOR) and Strategies for Open Science (Stratos).
We believe that the first option, disallow all publication costs, provided in the RFI is really the only viable way to achieve an ecosystem shift. The current paradigm that incentivizes journal publishing has proven to be costly, opaque, and lacking in innovation. It has created a static, incomplete record of science that is frequently not accessible.
Neither the current slow and expensive publishing process nor the article as an endpoint reflect the dynamic, iterative, and data-rich nature of science. We are paying ever increasing prices for a product that gets less and less useful in the digital era. Articles frequently do not even contain links to underlying data and other supporting materials and often have to remove metadata and reduce figure fidelity or image quality to fit the work into the print paradigm that has persisted for more than 25 years since journals went online.
The National Academies Strategic Plan, released in 2024, calls for reform: “There is growing awareness that current promotion and tenure decisions are far too focused on publications in high-profile journals. Other essential contributions to the research enterprise such as mentoring, promoting diversity, communicating with the public, improving the research process, or striving to elevate public trust in science are either not recognized or insufficiently rewarded.”
While the challenges posed by the current system are well understood, the open science and publishing reform movements have not yet provided an alternative for research sharing that is more efficient and data-complete. The logical choice is a preprint that includes underlying data and other research outputs needed to reproduce the work. And additionally an ecosystem in which AI validation and human peer review of many types can flourish.
Repurposing a fraction of the funds used to pay for APCs today could evolve data sharing, preprinting, and independent peer review, resulting in a new faster and more efficient ecosystem that makes all research outputs available earlier and more broadly. Rapid Science, ICOR, Stratos, and our affiliated projects propose standing up this preprint-based alternative and investing in and incentivizing open-first, born-with-integrity workflows and tools that capture research as it is being conducted and credit researchers for sharing early and often.
We believe it is only through convergence of ideas and collective action that we will achieve a true shift away from an expensive, print based system towards a dynamic paradigm that will accelerate the benefits of our collective investment in science.
With this in mind, we suggest that NIH take the following actions:
- Mandate preprints with underlying data and other outputs as the primary method of sharing research prior to or instead of journal publishing
- Do not pay for APCs
- Credit data-complete preprints and preprint reviewing in grant decisions and research assessment
Thank you for the opportunity to respond.
Best wishes,
Kristen Ratan
Executive Director, Rapid Science
CEO, Stratos
CoFounder, ICOR