The National Institutes of Health (NIH) released a Request for Information (RFI) seeking public comment on a new draft policy aimed at limiting allowable publication costs for NIH-funded research. As a pioneering independent open access publisher, JMIR Publications responded to this RFI, sharing our unique perspective on the economics and practices of scholarly publishing. Please find our full response below, which argues for an approach that supports genuine open access without undermining the quality and integrity of the scientific record.
NIH seeks input on the option, or other options 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.
JMIR Publications thanks the National Institutes of Health (NIH) for the opportunity to provide feedback on the Request for Information (RFI) regarding the Draft Public Access Policy. We charge modest Article Processing Charges (APCs) in the range of $950 to $3500—charges that are generally much lower than the APCs of hybrid journals, even though the latter have additional revenue streams from subscriptions. As a pioneering independent open access (OA) scholarly publisher in digital health and informatics research, data science, and health services research, we support the NIH's overarching goal of ensuring free, immediate, and equitable public access to the results of federally funded research. We believe that open access is the optimal path to accelerate scientific discovery and enhance public well-being. Our operations and infrastructure were built from the ground up with OA as a foundational principle, giving us a unique understanding of the challenges and opportunities in this space. We are only one of 6 remaining independent full open access publishers represented in the Open Access Scholarly Publishers Association (OASPA). The others are the two non-profits eLife and PLOS, the two very large publishers Frontiers and MDPI, and Copernicus and JMIR Publications as small mission-driven publishers.
JMIR Publications is a small, scientist-owned, and mission-driven company, which is very different from large commercial “legacy” publishers that built their brand with subscription journals and which now attempt to “flip” these to OA or try to maximize profit by double-dipping (charging APCs plus subscriptions), but are also very different from larger fully open access publishers like MDPI or Frontiers. Our APCs are substantially lower than APCs of hybrid journals. As such, while we understand the sentiment against APCs, we do not believe that APCs as a whole are “unsustainable.” Rather, the market needs to be opened up and existing funds need to be funneled to the most cost-effective quality journals. One such mechanism could be what we called Plan P: Preprints first, then peer-review, then publication through a subsequent “manuscript marketplace.” Plan P was suggested by JMIR Publications in 2021 (Eysenbach G. Plan P – A Publishers' Offer to Institutions and Funders to Transform to Open Science. https://zenodo.org/records/5786370) but is now administered by the OpenSci.foundation (see separate response to the RFI).
Medical informatician Dr. Gunther Eysenbach started our first open access journal, the Journal of Medical Internet Research (JMIR) (https://www.jmir.org), in 1999, as one of the world’s first “Diamond Open Access Journal”—i.e., run by scientists for scientists out of an editorial office that was affiliated with the university. Eysenbach intentionally did not launch the journal with one of the large commercial publishers because he believed in the power of the Internet to disseminate research for free without access barriers, also empowering consumers and patients, and also saw the oligopoly of large publishers as problematic. As early as 1999 the journal also embraced preprints and subsequent knowledge translation through journals (Eysenbach G. Challenges and changing roles for medical journals in the cyberspace age: electronic pre-prints and e-paper. J Med Internet Res. 1999 Oct-Dec;1(2):E9 https://www.jmir.org/1999/2/e9/):
“These days, information is often first published on the Web and sometimes read by millions of users before printed journals can cover the story (...) A similar development in science seems to be inevitable and desirable. Medical journals—at least general medical journals—should give up their aim of being the primary and sole source of scientific information, but shift their aim toward acting as catalysts to get evidence-based medicine into practice. Their principal mission should not be newsworthiness, but putting "primary" information (which may have already been published on the Internet) into context and perspective, by evaluating, commenting, and weighting raw information.”
Twenty-six (26) years ago, this was an early call for what we call today post-publication peer review, or the “PRC” (publish as preprint, review, curate) model, which JMIR Publications has pioneered with its JMIRx series of journals and Plan P.
In the early 2000s, JMIR became one of the pioneering “Diamond” (free for authors and readers) open access journals that quickly gained recognition and was even ranked the top medical journal in the medical informatics discipline according to Journal Citation Reports (then Thomson Reuters, now Clarivate). We learned back then that the “diamond” (free for authors and readers) ideal of scientists working voluntarily on editorial tasks may be realistic for small journals that publish a small number of articles per year, but it hits its limits once a journal becomes very successful, is confronted with thousands of submissions, and where editorial, typesetting and marketing services require highly educated professionals who demand fair compensation, which is key for any successful journal in particular in the biomedical space. We emphasize this because NIH will no doubt receive submissions to their RFI from people and organizations that advocate an “APC-free,” “Diamond” model as a solution, which we deem “magical thinking” and unrealistic for the biomedical space, which has different pre- and post-publication quality requirements than for example humanities and social science journals, that constitute 60% of Diamond journals, are usually very small publishing less than 25 articles a year, and have sustainability issues due to volunteer work and exploitation of university staff (Bosman J et al. OA Diamond Journals Study. Part 1: Findings https://zenodo.org/records/4558704). We firmly believe that in order to offer professional, responsible and sustainable publishing services especially in the biomedical area, highly qualified staff including medical doctors, PhDs, and professional editors need to be on staff and need to be fairly compensated. To run such operations as part-time endeavors out of a university has proven to be impossible, at least in the case of JMIR, which quickly grew from an amateur side hustle. Universities or governments should not take on the liabilities that come with running a journal or making sometimes uncomfortable or unpopular choices. As long as publications are also part of Tenure & Promotion or graduation requirements, and play a role in university rankings and national rankings on research output, there is also an obvious question on how the perceived conflict of interest should be handled. Trust in science is at an all-time low and if universities, academic institutions or even governments “own” journals and/or the peer-review process, this will lead to further erosion of trust in science. This is a major argument on why commercial publishing entities should exist—in addition to being able to hire and incentivize the best people, invest in publishing innovations (as JMIR has done; see https://support.jmir.org/hc/en-us/articles/115002923468-What-are-JMIR-s-innovations), smaller mission-driven publishers can serve as “independent” entities that help to judge the quality of research outputs and maximize knowledge translation. The latter is a key component to achieve NIH’s vision to “turn discovery into health.” In a seminal study, gold open access was shown to be associated with an increased citation rate (as a marker of knowledge uptake) if adjusted for various confounders, compared not only to toll-access research (behind subscription pay-walls), but also compared to “green open access,” where preprints or accepted manuscripts are made available (Eysenbach G. Citation Advantage of Open Access Articles. PLoS Biol 2006;4(5):e157. https://journals.plos.org/plosbiology/article?id=10.1371/journal.pbio.0040157). This is a major justification for why “gold open access” should exist and needs to be supported by funders as well as libraries.
We acknowledge that the NIH Draft Public Access Policy states that submission of manuscripts to PubMed Central (PMC) remains free for authors, and that any fee requested for submission to PMC is not an allowable cost. However, this position inadvertently devalues the substantial work that precedes deposition of an “accepted manuscript” and ensures the quality and integrity of published research. The pathway to a peer-reviewed author-accepted manuscript or final published article involves critical services with costs necessary for routine operations in support of a high-quality, high-integrity scientific record. Costs for such services include:
Editorial research integrity checks.
Expert assessment of quality and methodological rigor.
Comprehensive peer review management. This includes robust submission tracking, workflow configuration, task automation, and integrated communication tools, ensuring adherence to rigorous quality standards and ethical guidelines, and an optimal experience and support for all involved in the manuscript lifecycle, especially authors, peer reviewers, editors, and journal staff. Many hours of work by medical editors, statistical experts, manuscript editors, illustrators, proofreaders, and production staff contribute to this.
Production services like professional copyediting, typesetting, layout, reference checks, XML data production, and generating various article file formats.
Content delivery, including indexing and archiving with DOIs and metadata distribution to various services.
Marketing and dissemination to maximize global distribution and visibility, towards knowledge translation and real-world impact.
These activities are essential for producing vetted, quality research outputs and are not "free." In medicine, and in particular the area where we are publishing in (digital health as the intersection of medicine and engineering), quality publishing requires paying fair salaries to highly qualified editors with a background in medicine. The often stated narrative that “peer-reviewers do all the work for free, and publishers cash in” demonstrates a lack of understanding of what publishers and editors do. Publishing is an increasingly complex endeavor that requires professionals to handle the 100+ things publishers do (see list by Kent Anderson in the Scholarly Kitchen, Focusing on Value — 102 Things Journal Publishers Do (2018 Update). https://scholarlykitchen.sspnet.org/2018/02/06/focusing-value-102-things-journal-publishers-2018-update/).
For full open access publishers such as JMIR Publications, which does not sell any subscriptions and does not benefit from “transformative agreements” (because it is already transformed to 100% open access), and can also not bundle publishing with “read” access due to having been open access from the beginning, Article Processing Charges (APCs) are the only viable income stream other than institutional memberships. We advocate for these essential quality assessment and peer review, editing, and knowledge dissemination costs to be recognized as allowable expenses under the policy, whether through individual article fees or through broader institutional agreements.
We are concerned that the NIH's strong emphasis on the "free" PMC deposit route (green Open Access), while crucial for accessibility, may unintentionally reinforce existing market power dynamics, and motivate researchers to publish in subscription journals, locking away the version of record for the future. Critiques of "transformative agreements" (TAs) highlight that they often channel resources to a few large commercial publishers, perpetuating their dominance rather than fostering true bibliodiversity and competition. These agreements can "trap" institutions in models that primarily benefit large legacy publishers, creating significant barriers for smaller independent OA publishers who lack a traditional subscription base to "transform."
We encourage NIH to:
Recognize and support the full value chain of scholarly publishing, including the costs incurred for quality assessment, peer review, and editorial services that lead to a reliable published article.
Promote financial models that foster bibliodiversity and genuine competition, such as direct support for independent, mission-driven, scientist-led open access publishers with annual subscription-like payments. This approach can provide financial stability without relying solely on burdensome APCs for authors or perpetuating entrenched legacy business models.
Support independent open access publishers, rather than reinforcing legacy models.
Support a “free market” by exerting its influence on academic institutions and libraries to provide mechanisms to support publication in any quality open access journal or platform (e.g., any journal indexed in Web of Science, PubMed, or Scopus) through Institutional Open Access Funds (financed by subscription cancellations and/or NIH funding, i.e., indirect costs) to end the anticompetitive preferential treatment of legacy/subscription publishers through transformative agreements and Read & Publish agreements. Such agreements change researcher behavior.
Experiment with novel platforms and ideas such as Plan P (http://planp.science).
Option 1: Disallow all publication costs
JMIR Publications strongly opposes this option at this point in time unless there is a broad adoption of an alternative “preprint first” model with dedicated funds to peer-review and ultimately disseminate peer-reviewed preprints (Plan P). Disallowing APCs would make it difficult for access pioneers such as JMIR Publications to operate, or would force us to change to a subscription model. In the absence of broad library support of pure open access models, APCs (or institutional memberships) are essential to cover the critical, costly editorial services essential for ensuring the quality and integrity of published research. Disallowing these costs would undermine the ability of independent OA publishers (including medical societies, which depend on journal profits), who rely on APCs, to deliver high-impact, rigorously peer-reviewed research, ultimately harming the dissemination of high-quality federally funded research. As a small independent OA publisher, and one where our mission is to publish good science: we are mindful of fair pricing that is commensurate with the value of the work we do and consider these factors when we set fair prices. It is also not clear what exactly is meant by publication costs or APCs; does this include editing, copyediting, social media marketing? What about other knowledge translation and dissemination activities such as conference costs (conference proceedings are often part of registration fees)? Publishers are ultimately service providers just like airlines, hotels, biotech companies that produce reagents or monoclonal antibodies etc., and the publishing industry is by no means the only industry that “profits” from the research endeavor.
In summary, Option 1 would undermine NIH’s own public access goals by pushing researchers back into the arms of subscription publishers, reducing the reach and impact of taxpayer-funded research, and weakening the financial viability of independent, fully OA journals that embody the values of transparency, equity, and accessibility.
Option 2: Set a limit on allowable costs per publication of $2,000.00
While understanding NIH's aim for reasonable thresholds, JMIR Publications is concerned that a hard limit of $2,000.00 may be insufficient to cover the full costs of producing high-quality, rigorously peer-reviewed, and widely disseminated open access research. NIH's own analysis indicates average requested costs by applicants range from $2,565.07 to $3,104.06 per publication, suggesting that $2,000.00 is below the real costs anticipated by researchers. This limit could force publishers to compromise on crucial services or hinder researchers from publishing in journals that uphold the highest standards of research integrity and rigor. Journals indexed in DOAJ are not necessarily representative of biomedical journals and many are produced in the Global South which have lower costs than journals produced in North America.
Option 3: Set a limit on allowable costs per publication of $2,000.00, and allow a higher amount of $3,000.00 when peer reviewers are compensated and reviews are publicly provided
JMIR Publications recognizes the NIH's intent to incentivize peer reviewer compensation and transparency. The feasibility and impact of direct cash compensation for peer reviewers, who are typically volunteers, present significant considerations. Direct cash payments can create substantial administrative burdens for publishers. JMIR Publications had previously experimented with small cash payments (USD $90) to reviewers as an incentive for timely peer-review for fast-tracked papers and made the following observations: 1) We were unable to pay any employees (mainly federal employees from the US) who had restrictive employment contracts requiring permission for additional paid work. 2) While USD $90 is a nominal amount for North American researchers, it is a substantial amount in the Global South which also invites fraud and misconduct. In particular in the era of AI, where chatbots can easily generate peer-review reports, considerable resources would have to be spent to prevent misconduct, and to define and detect “low quality” peer-review reports. We ultimately have learned that even small financial incentives are the wrong incentives.
Since then, we have pivoted to provide more recognition to reviewers and we think this should also be mirrored in NIH policy, e.g., collecting peer-review activities as reported in ORCID to reward researchers. Our organization has implemented an innovative point-based program to compensate reviewers, editors, and authors. Reviewers earn “karma” points for completing reviews, with bonus points for highly-rated contributions. These points do not expire and can be used for professional recognition or converted into monetary-equivalent credits to reduce or waive publication-related fees for their own work. This system creates a powerful incentive for community engagement and fosters a virtuous cycle of loyalty and participation, addressing compensation in a sustainable and administratively efficient manner that direct cash payments may not. We believe such models align with the spirit of compensation without the complexities of direct payments and help retain valuable peer reviewers. Regarding the public provision of reviews, we support transparency as it fosters inclusivity and collaboration. However, implementing public reviews requires additional infrastructure, management, and editorial oversight to ensure appropriate presentation and context, adding to the costs beyond peer review management.
Option 4: Set a limit on the total amount of an award that can be spent on publication costs to 0.8% of the award’s direct costs or $20,000.00, whichever is greater
This option offers more flexibility to grantees compared to strict per-publication limits, allowing institutions to allocate funds based on project needs. However, even with this flexibility, it is important that the cap does not disproportionately impact awards that produce a high volume of high-impact publications, which may cumulatively exceed the cap if consistently published in journals that fully cover the costs of quality and rigor.
Option 5: Set a limit on both the per publication cost ($6,000.00) and the total amount of an award (0.8% of direct costs or $20,000.00, whichever is greater)
Evidence from other groups shows that APCs greater than $6000 are ironically often exceeded by hybrid journals, which also have revenue streams from subscriptions. We believe that a cap of $6000 (or lower for hybrid journals) is a reasonable policy as it limits hyper selective journals which spend most of their funds in rejecting submissions without peer-review. However, there are potential inadvertent side effects of such a policy, such as giving publishers like Springer Nature, which would be most affected from such policies (https://blogs.lse.ac.uk/impactofsocialsciences/2025/09/11/shaking-up-the-scholarly-publishing-market-why-caps-on-apcs-could-backfire/) additional leverage to “bundle” APCs with access to subscription content (read & publish agreements), which would increase costs for libraries. Any policy that would cap APCs would also have to limit or outlaw the ability of publishers to use subscription content as leverage to extort more funds from institutions.
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.
JMIR Publications’ longevity and pioneering spirit in open access demonstrate a unique understanding of the challenges and opportunities in this space. Our commitment to open access has translated into significant impact and quality: The Journal of Medical Internet Research (JMIR) was ranked within the top 100 (#89) of all journals globally across all disciplines by h-index, and it remains the #1 journal in the Medical Informatics discipline according to Google Scholar metrics. Five JMIR Publications journals are listed in the top 20 within Medical Informatics. This quality is achieved through rigorous peer review and widespread accessibility, not exclusivity, requiring significant investment in the various services outlined above.
Our experience shows that high-quality publishing, including comprehensive peer review management, research integrity checks, and robust professional production services, incurs substantial costs. NIH's own analysis indicates that the average requested costs by applicants range from $2,565.07 to $3,104.06 per publication. This data supports our assertion that a $2,000.00 limit (Option 2 and baseline for Option 3) is often insufficient to cover these essential services for high-quality journals.
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.
JMIR Publications recognizes the immense value of peer reviewers, who largely volunteer their time, and the NIH's interest in their compensation. As detailed in our response to Option 3, direct cash payments, while seemingly straightforward, can introduce significant administrative burdens for publishers.
We propose that NIH consider alternative incentive models, such as our point-based incentive system, as an appropriate and effective method of recognizing peer reviewer contributions. Factors NIH should consider include:
Administrative Feasibility: Systems that minimize administrative overhead for publishers, allowing more funds to directly benefit reviewers or enhance the review process.
Sustainability and Scalability: Models that can be sustained long-term and scaled to accommodate a large, diverse reviewer pool.
Incentive Alignment: Compensation that encourages high-quality, timely reviews and fosters a sense of community and loyalty among reviewers. Our point-based system directly aligns with this by offering non-expiring points for professional recognition and monetary-equivalent credits for publication-related fees, which fosters a virtuous cycle of loyalty and participation.
Flexibility: Allowing publishers to implement compensation strategies that best fit their operational models, rather than strictly mandating direct cash payments.
Transparency: Any compensation model should be clearly communicated to reviewers and, if applicable, to authors and the broader community.
Publication records provide non-financial incentives for reviewers, and NIH/NLM could consider indexing peer-review reports with names in PubMed. Our overlay journal JMIRx-Med publishes all peer reviews of preprints with DOIs, but PubMed has decided against indexing these peer-review reports.
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.
In addition to compensating peer reviewers, other publishing best practices contribute to higher publishing costs but are crucial for maintaining the integrity and quality of the scientific record. JMIR Publications adheres to and advocates for these practices:
Robust Research Integrity Checks: This includes screening for plagiarism, image manipulation, authorship conflicts, and data integrity issues. The NIH specifically mentioned automated fraud detection capabilities, which are indeed critical and incur costs for software, personnel training, and ongoing management. These checks are fundamental in maintaining the trustworthiness of published research.
Expert Assessment of Quality and Methodological Rigor: Beyond basic peer review, this involves specialized editorial oversight, statistical review, and domain-specific expertise to ensure the scientific soundness of published work.
Comprehensive Peer Review Management: Our system includes robust submission tracking, workflow configuration, task automation, and integrated communication tools, ensuring adherence to rigorous quality standards and ethical guidelines. This involves many hours of work by scientific editors, statistical experts, manuscript editors, and journal staff.
Professional Production Services: This encompasses high-quality copyediting, typesetting, layout, reference checks, XML data production, and generating various article file formats. These services ensure readability, accessibility, and compatibility across platforms.
Content Delivery, Indexing, and Archiving: Assigning DOIs and distributing metadata to various services ensures persistent access, discoverability, and long-term archiving of published content.
Ethical Guidelines and Author/Reader Support: Maintaining high ethical standards throughout the publication process and providing continuous support to authors and readers are essential but resource-intensive activities.
These best practices ensure that research outputs are not only disseminated but are also reliable, credible, and impactful, maximizing the value of federally funded research. Any policy on allowable publication costs should fully recognize and support the costs associated with these indispensable practices. Preregistration of research by creating a public record of the planned research and analyses should become a standard and hallmark of good research.
NIH welcomes input on any aspect of the RFI.
JMIR Publications' mission is to help leaders in the health technology space to collaborate and disseminate their ideas and research results. Through our pioneering work and consistent high impact as an independent open access publisher, we demonstrate the viability and transformative potential of genuinely open scholarly communication. We disseminate innovations, ideas, protocols, grant proposals (including NIH-funded grant proposals), and research results to the widest possible audience, including researchers, patients, policymakers, and consumers, in a timely manner while adhering to the highest ethical and quality standards. This approach fosters inclusivity, collaboration, and interdisciplinary research. Our publications benefit from an open access citation advantage, receiving more citations from a wider range of disciplines and geographical locations, indicating broader relevance and greater societal impact.
We urge NIH to support financial models that foster a diverse, equitable, and sustainable scholarly publishing ecosystem. We believe that direct support for independent open access publishers, rather than reinforcing legacy models or disproportionately channeling resources to a few large commercial entities through "transformative agreements," is the clearest path to maximize the reach and impact of federally funded research for the benefit of all. This approach can provide financial stability without relying solely on APCs for authors or perpetuating entrenched legacy business models.
We reiterate our commitment to transparency and quality and encourage NIH to carefully consider the full spectrum of services and costs involved in producing high-quality, rigorously peer-reviewed, and widely accessible research.
We also ask NIH to support transparency by allowing investigators to publish the peer-review reports of their grant proposals, which could be published as appendices in journals like JMIR Research Protocols, which publishes protocols and grant proposals.