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NIH Data Management and Sharing Policy

March 23, 2022

Possible “Seismic Shift” in Data Management and Sharing 

 A new NIH policy has the potential to significantly impact the worldwide sponsored research community 

Beginning in January 2023, the Final NIH Policy for Data Management and Sharing (NOT-OD-21-013) will require researchers to include a data management and sharing (DMS) plan in funding applications. A recent Nature article calls the DMS policy a “seismic mandate” and discusses investigator concerns about administrative burden. These concerns center around the policy’s potential to “exacerbate existing inequities in the science-funding landscape” by unduly burdening early-career scientists who do the bulk of data collection and underfunded labs and institutions which lack data management resources. In preparation for the policy implementation NIH has launched a Scientific Data Sharing Website.

Policy Applicability and Effective Date  

The Final DMS Policy applies to all research, funded in whole or in part by NIH, that results in the generation of scientific data. This includes competing grant applications and proposals for contracts that are submitted to NIH on or after the January 25, 2023, submission deadline. The DMS Policy does not apply to research and other activities that do not generate scientific data, including training, infrastructure development, and non-research activities. 

DMS Plan Requirements 

Researchers will be required to submit a DMS plan at the time of application to the funding NIH Institute, Center, or Office (ICO) that outlines how scientific data and related metadata will be managed and shared, including any potential restrictions or limitations.  

 Specific plan elements include: 

  • Data type to be managed, preserved, and shared
  • Tools, software and/or code required to access or manipulate shared scientific data
  • Standards (if applicable) that will be applied to the scientific data and associated metadata
  • Timelines for data preservation and access
  • Access, distribution, or reuse considerations

In addition, researchers proposing to generate scientific data derived from human participants will need to describe how privacy, rights, and confidentiality of human research participants will be protected.  

Plan Compliance 

Plans must address oversight of data management and sharing, describing how compliance with the plan will be monitored and managed. During the funding period, compliance with the DMS plan will be reviewed and determined by the NIH ICO. After the end of the funding period, non-compliance with the NIH ICO-approved Plan may be considered by NIH for future funding decisions for the recipient institution. 

Supplemental Information to the NIH Policy for Data Management and Sharing