IMLS Public Access Policy Guidance Explained

The Institute of Museum and Library Services (IMLS) has released its Public Access Policy Guidance, and while it follows the same requirements as all agencies, it may look a bit different from some of the large-scale scientific research agencies. IMLS’s implementation is practitioner-oriented, reflecting the agency’s focus on strengthening the capacity of library and museum services, staff, and the communities they serve. The guidance also emphasizes flexibility in how research deliverables and other types of award outputs are shared. To better understand the implications of this policy implementation at IMLS, we spoke with Ashley Sands, PhD, senior program officer at IMLS. Our discussion explored the scope of the guidance, its alignment with IMLS’s longstanding commitment to public access, and what the updates mean for awardees.

Building on Existing IMLS Practices

Since 2014, IMLS grant recipients have been encouraged to share award outputs and deliverables under the agency’s General Terms and Conditions. If an awardee produces any printed or physical distributable products, such as a white paper, curriculum, toolkit, or other resources, then those products must be made available to IMLS (unless otherwise specified in the award documents). This expectation has applied to all IMLS grants, not just those covered by the new Public Access Policy Guidance. As Sands explained, “the ethos of open science, sharing these deliverables, is something that’s already ingrained in…all IMLS awards.”

IMLS’s Public Access Policy Guidance formalizes these requirements for research grants, specifically those projects that are designated as research and funded through the National Leadership Grants programs and the Laura Bush 21st Century Librarian Program. For these awards, the policy implementation requires both a variety of publications and research data to be openly shared in the following ways:

• Peer-reviewed scholarly publications must be shared openly. Researchers need to deposit a machine-readable copy of their published work in the IMLS-designated repository upon publication, with no embargoes or delays.
• Which version is deposited depends on publisher agreements. IMLS prefers that the version of record be shared; however, if this is not possible, the author’s accepted manuscript must be shared instead.
• Scientific research data should be made publicly available. Any data underlying findings in a peer-reviewed scholarly publication needs to be deposited in a researcher-chosen repository (albeit, one that aligns with the features outlined in the “Desirable Characteristics of Data Repositories for Federally Funded Research”), while also following legal, ethical, and privacy requirements. This includes, but is not limited to, considerations for sensitive data, Indigenous rights, personally identifiable information, and intellectual property.

This is meant to make IMLS-funded research more accessible while giving researchers some flexibility in how to best share their work.

Establishing Community Norms

Sands explained that the IMLS Public Access Policy Guidance is not just about driving compliance, but also about embedding open science into everyday research practices. “I think the end goal here is to develop open science norms in the academic fields we’re serving,” she explained, describing the policy’s implementation as a learning process for all stakeholders of the library, museum, and archival communities. While these practices have been gaining traction as standardized community norms independent of policies and mandates are taking shape, nuances around some of these practices are still evolving. For instance, when sharing research data, determining the appropriate levels of sharing or forms of access for sensitive materials will become more concrete as best practices are established. The long-term vision is that practices like depositing research data in a repository, ensuring public access to publications, and using persistent identifiers (PIDs) become part of researchers’ workflows, especially for early-career researchers. Sands noted that IMLS has not yet formalized its approach to monitoring compliance, but the expectation is that these practices will become standard rather than an added burden.

Developing an IMLS Repository

IMLS is piloting an internal repository to meet the White House Office of Science and Technology (OSTP) public access memorandum requirements. IMLS views this as an opportunity to create a centralized infrastructure for peer-reviewed journal articles from research grants, especially those that otherwise lack a clear repository home. While the IMLS repository’s future scope is being developed, complying with the memorandum will allow IMLS to assess its functionality, streamline the deposit process, and explore how the repository may look in the future. Beyond meeting compliance requirements, the repository could add new value for grantees by increasing the visibility and credibility of their work. For the library, museum, and archival communities, an IMLS repository has the potential to become a valuable resource for finding publicly funded research results.

Insights for Grant Applicants

Peer reviewers play a key role in funding decisions at IMLS, and Sands underscored that applicants should be prepared to demonstrate how their work fits into the broader research or project landscape. A well-developed literature review or gap analysis is essential for showing that a project is not simply repeating past work—unless a replication study is the aim—but is building on or complementing existing research in a meaningful way. During counseling calls with applicants, Sands reported that she frequently speaks to the importance of knowing what others are doing across the country. The peer reviewers “want you to stand on the shoulders of giants,” she explained, “and they want to enhance and build upon previous federal investments.” Funded projects should therefore be targeted and additive, clearly articulating how they advance prior efforts.

Researchers should also consider how their data can be shared, even when working with sensitive or qualitative materials. Sands observed that the field has moved past the idea that qualitative data is automatically exempt from sharing. Instead, applicants should assess whether their data has potential for reuse or could be used to reproduce/verify the reported results—and if so, determine what aspects can be made publicly available. This could mean depositing metadata, summaries, or documentation rather than the full dataset, or using a controlled-access repository when appropriate. Applicants are encouraged to work with their program officer to determine the best approach for their specific project.

IMLS has also stated that certain public access costs—such as data curation, repository deposit fees, and article processing charges (APCs)—are generally allowable grant expenses. Sands emphasized that ensuring access to research outputs, whether through publications, data sharing, and even software/code sharing, are likely eligible award expenses. Applicants can and should factor these costs into their budgets. Another practical step for applicants is securing persistent identifiers (PIDs), such as ORCID for researchers. While not yet required at the time of application, this could change in the future. Sands recommended that applicants consult with scholarly communications librarians at their institutions for guidance on selecting appropriate identifiers (such as institutions, people, and project outputs). Ideally, repositories will provide resolvable PIDs, ensuring long-term access and discoverability of deposited materials.

Expanding Expertise to Meet Public Access Expectations

As the IMLS Public Access Policy Guidance takes effect, library, museum, and archival researchers subject to the policy may want to consider enhancing their data curation skills and furthering their understanding of copyright and license conditions applicable to their awards. In terms of data curation, researchers should consider how to curate their own data for sharing, and when needed, seek expertise from data curation professionals at their organizations or from relevant data repositories.

Additionally, professionals in these fields will need to become more attuned to copyright and licensing requirements, ensuring they are not relinquishing rights to their work. A key part of this shift involves understanding the federal-purpose license, which allows agencies to use federally funded work for federal purposes without restrictions, including requiring recipients to make their work available through publicly accessible repositories, further supporting the goal of open science and public access.

Conclusion

Today, IMLS is focused on guidance and implementation, ensuring that award recipients and applicants have the resources they need to meet public access requirements. Detailed instructions will be included in notices of funding opportunities, updated terms and conditions, and webinars and FAQs as needed to help applicants and grantees comply with the policy. IMLS will continue to support the library, museum, and archives community as these requirements take effect and welcomes feedback on the Public Access Policy Guidance. For researchers receiving IMLS funding on or after October 1, 2025, these public access requirements will apply.

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