NIH Data Management and Sharing Policy

Frequently asked questions about the DMS Policy and DMS Plans:

• What proposals are affected?
  • All grant proposals submitted to the NIH for submission deadlines on or after January 25th, 2023, where the proposal produces scientific data.
• Will I have to include this for progress reports in 2023 and beyond for existing awards?
  • No. Existing awards are not affected.
• Where should my Data Management and Sharing Plan be included in my application for funding?
  • Data Management and Sharing (DMS) Plans will be collected in a new field called “Other Plans” on the PHS 398 Research Plan and Career Development Award forms.
  • Costs to support data management and sharing should be accounted for in either the R&R Detailed Budget Form or the PHS 398 Modular Budget Form along with a brief justification of those costs
• What is the actual policy?
  • The official policy can be found towards the bottom of the policy notice NOT-OD-21-013: The Final NIH Policy for Data Management and Sharing
  • There are also several official supplements, particularly the Elements of an NIH Data Management and Sharing Plan; the guidance on Selecting a Repository for Data Resulting from NIH-Supported Research; and Changes to harmonize and combine genomic data sharing plans with the DMS Plan
• Where should I share my data?
  1. Top priority goes to any repository named in the FOA or required by the Institute or Center 
  2. In the absence of requirements, prioritize a domain-specific repository if one is suited to your Institute, discipline, or data type
  3. If no domain repositories fit, consider an approved generalist repository. We recommend OSF as a favorite generalist repository, but any data repository on the approved generalist list will do a great job
  • For more ideas, see the repositories tab to the left
• How do I make post-award changes?
  • Updates can be requested using the eRA Commons Prior Approval module using these directions. You may be familiar with the Prior Approval module if you've ever requested a No Cost Extension.
• What other frequently asked/answered questions?
  • An NIH FAQ addressing common concerns is available and being regularly updated.
• What if we work with human subjects data? Is it still affected?
  • Yes! At least, yes a DMS Plan will be required for studies producing scientific data even if the data is from human subjects
    • Part of the DMS Plan includes explaining why and how you may limit sharing, either through aggregation or not sharing at all. If sharing is not anticipated at all, that should be explained when you write and submit the Plan document
  • If the consent forbids sharing, that should be addressed in the Plan. In the future, consider updating your consent forms with this NIH resource on informed consent for Future Use and/or Sharing. Always prioritize restricting your sharing to the terms of your consent forms.
  • For clinical trials, consider naming clinicaltrials.gov as your repository and describing the sharing you do there as your DMS Plan sharing approach.
  •  For human subjects data under a Data Use Agreement, always prioritize following the DUA over any sharing! Describe the terms of the DUA, and what (if anything) remains to be shared. For example, summary or aggregate findings might still be appropriate, depending on the terms of your DUA.
• How is this different than a Data Sharing Plan from before 2023?
  • See the policy comparison chart for some key differences
  • Visit this annotated DSP to DMSP conversion example for more insights
• Where can I get more training or discussions?
  • Official webinars and slides are available at https://sharing.nih.gov/about/learning 
  • And in June 2022: the VCUL's videos were updated to add Module 2 on the Data Management and Sharing Plan, with detailed discussion of the 6 elements in the DMS Plan. Visit the Learning Modules tab on the left for the new video playlist.