SPARC has submitted formal comments to the Office of Management and Budget (OMB) on its proposed revisions to the Uniform Guidance for Federal Financial Assistance (2 CFR Part 200, Docket No. OMB–2026–0034), a rulemaking that touches everything from how federal grants are administered to how the results of federally funded research reach the public.
The proposed rule covers broad changes to federal grantmaking, and SPARC expressed concerns over provisions that would prioritize political appointee opinions over scientific expertise, grant agencies’ unchecked discretion to suspend or terminate awards at any time, and undercut internal collaborations that currently fuel scientific discovery. However, the bulk of SPARC’s comments focus on the provisions most directly relevant to our work: how the rule treats publication costs and what that means for public access to taxpayer-funded research.
The Core Issue: Who Pays for Public Access?
Federal agencies require that research they fund be made immediately and freely available to the public. For years, a costly misconception has shaped how researchers and institutions try to meet that requirement: the idea that complying with a public access policy requires paying a publisher’s Article Processing Charge (APC).
That’s not true, and has never been true. The Federal Purpose License (2 CFR 200.315(b)) gives the government a royalty-free right to reproduce and distribute research produced with federal funding. Depositing a final accepted manuscript into an agency-designated repository, such as PubMed Central, DOE PAGES, or NSF-PAR, fully satisfies public access requirements at zero cost. No publisher fee is required.
Yet publishers have increasingly restructured their business models so that paying an APC feels like the only route to compliance. The financial impact is significant: select Federal agencies paid an estimated $295 in publishing charges in 2024 alone, with projections reaching $3–4.5 billion between 2026 and 2030 if current trends continue.
What SPARC Told OMB
SPARC’s comments support the proposed rule’s core principle that a general requirement to make research publicly available does not authorize charging APCs to a federal award. But we also flagged a gap: removing the funding pathway for APCs doesn’t, by itself, tell researchers what to do instead. Without clear guidance, researchers may default to case-by-case exceptions, recreating the very costs the rule is meant to eliminate.
To close that gap, SPARC recommended that OMB:
- Add an affirmative compliance statement confirming that depositing a manuscript in a designated repository fully satisfies public access requirements, at no cost to the award or the author.
- Direct federal agencies to issue implementing guidance identifying the specific no-cost deposit pathways available to researchers, paired with investment in repository infrastructure, diamond open access platforms, and researcher education.
Additionally, SPARC asked that OMB clarify the scope of a separate provision (§ 200.454(b)), which as drafted could be read to make institutional library subscriptions unallowable indirect costs.
Researchers and libraries have been left to navigate publisher pressure to treat APC payment as mandatory largely on their own, often absorbing costs based on a misconception. That burden shouldn’t fall on individual authors or libraries and it doesn’t have to. Authors have a ready no cost compliance option, and agencies don’t need to pay publishers to meet their own public access mandates. They already have the legal authority and infrastructure to make no-cost deposit the default, but what’s missing is the regulatory clarity that would finally make that the obvious, well-supported path for every federally funded researcher.
Read SPARC’s full comments.