Comment from Claire Garfield

Re: Proposed Revision to [200.461] — Publication and Printing Costs I am graduate student at the University of Georgia. I am writing to oppose the proposed revision to § 200.461 of 2 CFR Part 200, which would make article processing charges (APCs) and other publication costs unallowable under Federal awards by default. This provision creates a direct conflict with the 2024 NIH Public Access Policy, which has been in effect since July 1, 2025 and requires all NIH-funded manuscripts to be published open access without embargo. For most journals, complying with that requirement means paying an APC. The proposed rule states that a "general requirement to make results publicly available must not be construed as authorizing publication costs." Researchers cannot comply with both requirements at the same time. OMB does not address this conflict anywhere in the proposed rule, and it should be resolved before any restriction on publication costs is finalized. I conduct federally funded research in biogeochemistry. Publishing findings in peer-reviewed journals is not a discretionary activity. It is how research fulfills its public purpose. Under the proposed rule, I would have no reliable way to fund that publication, because the case-by-case approval process provides no standard, no timeline, and no appeal. I also want to note that this rule does not solve the underlying problem. APC costs are set by publishers, not by researchers or institutions. Disallowing the cost does not lower the price, but rather shifts the burden onto researchers who have no leverage over publisher pricing. The 914 comments submitted in response to NIH's 2025 Request for Information (NOT-OD-25-138) documented this in detail. Congress has tools available to address publisher pricing directly, including price negotiation authority, transparency requirements, and procurement standards that would address the problem without putting researchers in the middle. I urge OMB to withdraw § 200.461 as proposed and to resolve the conflict with the NIH Public Access Policy before finalizing any restriction on publication costs. I further urge Congress to pursue tiered publisher-side remedies rather than cost disallowance as the mechanism for addressing APC inflation.