Data Management and Sharing Policies

Many funding organizations, including the NIH, now have data management and sharing policies in place. These policies often require submitting a data management and sharing plan at the time of application and sharing of resulting data at specific points in the research process. Review the policy resources below and reach out to Becker Library with questions.

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NIH

NIH has various sharing policies in place for research that it funds. Use this tool to find out which sharing policies apply to a particular project. Many institutes, centers, and research programs have instituted specific data sharing policies in addition to the overall NIH DMS policy so please check out the NIH ICO-specific Data Sharing Policies.

2023 Data Management and Sharing Policy

The NIH’s new 2023 Data Management and Sharing (DMS) Policy went into effect on January 25, 2023, replacing the 2003 Sharing Policy.

DMS Policy Overview

Under the DMS policy, NIH expects that investigators and institutions:

• Plan and budget for the managing and sharing of data
• Submit a DMS plan for review when applying for funding
• Comply with the approved DMS plan

DMS Policy Scope

The policy applies to all research, funded or conducted in whole or in part by NIH, that will result in the generation of “scientific data”. This includes all NIH-supported research regardless of funding level, including: extramural grants, extramural contracts, intramural research projects, and other funding agreements. The NIH defines “scientific data” as the recorded factual material commonly accepted in the scientific community as of sufficient quality to validate and replicate research findings, regardless of whether the data are used to support scholarly publications. Scientific data do NOT include laboratory notebooks, preliminary analyses, completed case report forms, drafts of scientific papers, plans for future research, peer reviews, communications with colleagues, or physical objects such as laboratory specimens.

You can check out the complete list of NIH activity codes subject to the DMS Policy and the Funding Opportunity Announcement to determine if the DMS Policy applies to your application.

DMS Policy Requirements:

1. Submission of a Data Management and Sharing (DMS) Plan with all funding applications.
   
   Beginning with receipt dates on or after January 25, 2023, competing applications submitted for activities subject to the DMS Policy are required to submit a DMS plan at the time of application for NIH grants or cooperative agreements. A new “Other Plan(s)” field is added to the FORMS-H grant application forms to collect a single PDF attachment containing the Elements of a DMS Plan. The requested direct costs to support the activities proposed in the DMS Plan must be indicated as “Data Management and Sharing Costs” in the appropriate cost category, e.g., personal, equipment, supplies, and other expenses, following the instructions for the R&R Budget Form or PHS 398 Modular Budget Form, as applicable.  The budget justification attachment must also include a brief summary of the DMS Plan and a description of the requested DMS costs.
   
   To write a DMS plan, please visit the Data Management and Sharing Plans page.

2. Compliance with the DMS plan approved by the funding NIH Institute, Center, or Office.
   
   Awardees are expected to carry out data management and sharing as outlined in the approved plan, which becomes a term and condition of the award. The grantee is expected to report the progress of the approved DMS plan in the annual research performance progress report (RPPR). NIH will review compliance annually and failure to comply may result in enforcement actions, including additional special terms and conditions or termination of the award, and may affect future funding decisions.  If plans change over the course of the project, work proactively with the NIH Program Officer to obtain review and approval of modifications.

DMS Policy – Timeline for Sharing

In terms of the timeline for sharing, NIH states that shared scientific data should be made accessible as soon as possible, and no later than the time of publication of findings in a peer-reviewed journal (pre-prints do not meet this requirement), or the end of the award, whichever comes first. 

Quick Links to the NIH 2023 DMS Policy-related Notices and FAQs:

• Final NIH Policy for Data Management and Sharing (NOT-OD-21-013)
• Elements of an NIH Data Management and Sharing Plan (NOT-OD-21-014)
• Allowable Costs for Data Management and Sharing (NOT-OD-21-015)
• Selecting a Repository for Data Resulting from NIH-Supported Research (NOT-OD-21-016)
• Implementation Details for the NIH Data Management and Sharing Policy (NOT-OD-22-189)
• New NIH “FORMS-H” Grant Application Forms and Instructions Coming for Due Dates on or after January 25, 2023 (NOT-OD-22-195)
• Implementation Changes for Genomic Data Sharing Plans Included with Applications Due on or after January 25, 2023 (NOT-OD-22-198)
• Protecting Privacy When Sharing Human Research Participant Data (NOT-OD-22-213)
• Responsible Management and Sharing of American Indian/Alaska Native Participant Data (NOT-OD-22-214)
• NIH Application Instruction Updates – Data Management and Sharing (DMS) Costs (NOT-OD-23-161)
• Prior Approval Requests for Revisions to an Approved Data Management and Sharing (DMS) Plan Must be Submitted Using the Prior Approval Module (NOT-OD-23-185)
• Reporting Data Management and Sharing (DMS) Plan Activities in the Research Performance Progress Report (RPPR) (NOT-OD-24-123)
• Implementation Update for Data Management and Access Practices Under the Genomic Data Sharing Policy (NOT-OD-24-157)
• Updated Processes for Requesting Revisions to an Approved Data Management and Sharing (DMS) Plan (NOT-OD-24-176)
• FAQs for the 2023 NIH Data Management and Sharing Policy
• NIH contacts and help

To help applicants comply with the new NIH DMS policy, the NIH has launched a scientific data sharing website, which is updated regularly to include sample DMS plans, tips for taking data sharing into consideration when developing a budget, and additional FAQs.

Genomic Data Sharing Policy

All NIH-funded research generating large-scale human or non-human genomic data and secondary research using these data fall under the NIH Genomic Data Sharing (GDS) policy. This policy applies to all funding mechanisms regardless of cost. To confirm if your research projects fall under the NIH’s GDS policy, please visit the NIH sharing site GDS policy page. For additional questions, please visit FAQs page.

The NIH GDS policy provides the basic framework for sharing genomic data generated from all NIH-funded research. However, individual NIH Institutes and Centers (IC) may have additional expectations or requirements for genomic data sharing as well. To learn more about any additional IC-specific requirements, please visit the GDS Policy Expectations by NIH Institute & Center page.  To learn more about developing GDS plans, visit our Data Management and Sharing Plans page.

Compliance and enforcement for awards subject to the GDS Policy will be handled in accordance with the compliance and enforcement terms in the DMS Policy as described in NOT-OD-21-013 Section VIII, which is not expected to result in any significant change in how noncompliance is enforced.

Genomic Data Submission & Release Expectations

NIH’s GDS policy sets forth specific expectations for the submission of data according to the type of data and level of processing. Some studies will generate multiple levels of data; each data level has a different expectation for whether and when it is to be submitted to a repository and when the data should be released for access. Genomic research data that results from NIH-supported studies is expected to be shared in an appropriate database. To learn more, visit the Data Sharing Page of this website.

Table of Data Submission and Release Expectations based on Five different Data Levels (Level 0 – 4)

Additional resources and training opportunities by NIH

To find resources and training opportunities for NIH sharing policies, please visit the Learning Page of the NIH Data Sharing Site.

• NIH Grants Conference Presentation: The NIH Final Policy for Data Management and Sharing is in Effect: Planning for Success! – February 1, 2023
  • Resource Slide Deck
  • Conference Recording (38 minutes)
• Webinar I: Understanding the New NIH Data Management and Sharing Policy – August 11, 2022
  • Resource Slide Deck 
  • Webinar Recording (88 minutes)
• Webinar II: Diving Deeper into the New NIH Data Management and Sharing Policy  – September 22, 2022
  • Resource Slide Deck 
  • Webinar Recording (81 minutes)
• NIH Grants Conference Presentation: Genomic Data Sharing, Other Sharing Policies, and Open Q&A – February 2, 2023
  • Resource Slide Deck
  • Conference Recording (39 minutes)
• Slide Sets: Data Management & Sharing Policy Overview – August 2023
• Presentations and Videos: Update on Implementation of New NIH Data Management and Sharing Policy – November 2021

Becker Library’s presentations on the NIH DMS Policy

• How to prepare for the new NIH DMS Policy Webinar-Slides (12/14/2022)
• How to prepare for the new NIH DMS Policy Webinar – Video Recording (12/14/2022)
• NIH Data Management and Sharing Policy Information Session 12/8/2021
• 2022 OVCR Researcher Forum Session (closed captions) 1/12/2022

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Other federal agencies

Many other United States federal agencies have policies related to the management and sharing of data resulting from funded research. Refer to SPARC’s community resource list of U.S. federal funder policies for information on specific federal funders including the CDC, DOD, FDA, NSF and more.

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Foundations, charities and organizations

Similar to federal funders, some foundations and charitable organizations have policies focused on the management and sharing of research data. Some examples follow below. Research out to Becker Library for assistance determining whether your funder has a policy in place.

• American Heart Association
• Gates foundation
• Howard Hughes Medical Institute