From the National Institutes of Health's Office of Extramural Research, November 16 posting:
When we put the [open access] policy into place in 2008 it was an adjustment for all of us. Since that time, NIH has focused much of our attention on outreach. We've helped you understand your obligations and provided reminders when we found papers that were out of compliance. This strategy, along with the research community's shared commitment to making the results of NIH-supported research public, has resulted in a high level of compliance with the policy. But our work is not done as there are still publications -- and as a consequence, NIH awards -- that are not in compliance. Thus, as of spring 2013 at the earliest, we will begin to hold processing of non-competing continuation awards if publications arising from grant awards are not in compliance with the public access policy. Once publications are in compliance, awards will go forward. For more details, see NIH Guide notice NOT-OD-12-160.Posted by stemp003 at November 30, 2012 2:15 PM
We are giving funded organizations at least five months to prepare for our new process, and we hope you use this time to assure that publications are in compliance with the policy long before this change in process begins.
The challenge is that publication occurs throughout the year, and progress reporting occurs once a year. So I encourage principal investigators to start thinking about public access compliance when papers are planned. Discuss with your co-authors how the paper will be submitted to PubMed Central, and who will do so, along with all the other tasks of paper writing. The easiest thing to do, perhaps even today, is to take a couple of minutes to enter the NIH-supported papers you have published in the last year into My NCBI to ensure you meet the requirements of the policy regardless of when your non-competing continuation is due. This will help you avoid a last minute scramble that could delay your funding.