Marcus had a good point in his comment from my last post - many publishers allow authors to self-archive.
Many publishers do allow self-archiving, and it is a fact that many of us don't fully utilize. The giant in STM publishing, Elsevier has a self-archiving policy that allows for authors to use and distribute their articles for a variety of uses. Peter Suber posted an excerpt on Open Access News on July 14th.
With the right to post a manuscript version of an article (with peer-review changes) on the author's website or author's institutional website, it wouldn't be such a great leap to allow the manuscripts to be posted on PubMed Central (the funding institution's website). Hmmm....maybe we are all closer than we realize to agreeing on this NIH policy.