NIH publication cost review draws sharp criticism of APCs and commercial publishing
The NIH’s 2025 request for information on whether grant funds should be used for publication costs triggered a forceful and unusually detailed public response. Across 914 submissions spanning more than 1,300 pages, the central complaint was not about open access itself, but about how the current publishing system shifts costs, labor, and market power onto researchers and institutions while leaving scientific dissemination dependent on expensive commercial infrastructure.
The clearest flashpoint was article processing charges. Critical comments on APCs appeared in 445 of 914 responses, or 48.7%, far more often than any other topic. That reaction points to a system in which publication fees are increasingly viewed as a barrier rather than a neutral administrative expense. When authors must pay to make work openly available, the burden falls unevenly across disciplines, institutions, and career stages. For investigators with limited funding, the fee structure can shape what gets published, where it appears, and how quickly it reaches readers.
Support for APCs was almost nonexistent. Only 0.2% of responses were supportive on that topic. In policy terms, that is a severe warning sign for any approach that relies on fee-based access as the default mechanism for scientific visibility. A model that depends on grant dollars to cover publication charges can preserve access on paper while intensifying inequality in practice, especially when publication fees rise faster than research budgets.
Peer review remained broadly protected as criticism centered elsewhere
Peer review occupied a different moral and practical space in the comments. It drew more support than any other topic, with 84 of 914 responses, or 9.2%, expressing approval. Only 5.5% of responses raised criticism of peer review. The pattern matters because it separates the editorial function of quality control from the commercial architecture surrounding it.
Researchers appear willing to defend peer review as a scientific safeguard even while rejecting the pricing structures wrapped around it. That distinction suggests broad support for scrutiny, revision, and editorial filtering, but little appetite for a publishing market that monetizes access while relying on free academic labor to perform much of the work. In modern scholarly publishing, reviewers and editors often contribute expertise without direct compensation, and respondents clearly recognized that imbalance.
Comments on unpaid academic labor were critical in 96 responses, or 10.5%, while supportive remarks were rare at 1.2%. The concern is easy to understand. Universities and funders already pay for the research, then ask scholars to evaluate, revise, and package it for publication with limited financial recognition. The system depends on a hidden subsidy of time, especially from faculty and scientists whose promotion and tenure depend on keeping pace with publication demands.
Commercial publishing and market concentration drew structural objections
Commercial publishing itself became a major target. Critical comments on commercial publishing appeared in 210 responses, or 23.0%, while supportive comments reached only 2.1%. The problem raised here is not simply price. It is concentration. A small number of large publishers shape access, pricing, and distribution across much of biomedical science, creating a market in which institutions often pay repeatedly for the same content through subscriptions, licensing, and publication fees.
That model has important downstream consequences. As APCs rise, journals may selectively favor authors with stronger funding support, and institutions with fewer resources may struggle to place work in high-visibility outlets. The result is a publishing ecosystem that can amplify existing academic hierarchies rather than correct them. In the context of biomedical research, where rapid dissemination affects practice, guideline development, and policy, the financial architecture of publication is no longer a peripheral administrative issue. It is part of the infrastructure of evidence generation.
The comment analysis also suggests that respondents do not see the problem as one-dimensional. Many objections were aimed at the broader economics of scholarly communication rather than at a single fee or policy lever. That includes concern over corporate profit, the outsourcing of editorial labor, and the way fee-for-access systems can distort incentives for authors, journals, and funders alike.
Individual and organizational responses pointed in different directions
Differences between individual and organizational submissions revealed competing incentives inside the research enterprise. Individuals and institutions do not experience publishing costs in the same way. A single investigator may view APCs as an immediate obstacle to dissemination, while a university or publisher may weigh them against budget planning, journal sustainability, or portfolio strategy.
Those differing positions help explain why a policy focused narrowly on cost containment may fall short. An APC cap sounds straightforward, but capping fees does not by itself resolve market concentration, unpaid labor, or the incentive structure that pushes authors toward fee-based prestige journals. If the cap is set too low, journals may shift costs elsewhere or restrict access in other ways. If it is set too high, the policy may function mainly as a subsidy for a business model that remains structurally unchanged.
The public comments therefore point toward a deeper question about what NIH policy is actually trying to regulate. Is the goal to reduce wasted spending, protect taxpayer-supported research from excessive publication charges, or reshape the publishing system itself? Those goals overlap, but they are not identical. A policy designed only around trimming fees could leave the core structure intact: commercial consolidation, unpaid editorial work, and uneven access to publication opportunities.
APC caps may be too narrow for the problem being debated
The clearest policy implication is that narrow fee controls are unlikely to solve a structural problem. APC caps may lower some immediate costs, but they do not address who controls journal platforms, how labor is compensated, or why scientific dissemination remains tethered to a high-cost commercial model in the first place. The public response favors peer review as a scientific practice while resisting the economics built around it.
For NIH, that creates a difficult choice. Restricting the use of grant funds for publication costs might reduce direct spending, but it could also shift burdens to investigators and institutions without improving the publishing system’s transparency or fairness. A policy that aims to protect research dollars must also contend with the fact that publication is not a passive endpoint. It is part of how evidence enters clinical and scientific circulation.
The comment dataset leaves little doubt about where the strongest discontent sits: APCs, commercial publishing, and unpaid academic labor. Peer review, by contrast, remains protected as a scientific norm. Any NIH policy that treats those issues as interchangeable risks solving the easiest problem first and leaving the hardest one untouched.