NIH Data Management and Sharing Policy Requirements and Resources

As proper data management and sharing are critical research practices to accelerate scientific advancement and support scientific integrity, the NIH issued a Data Management and Sharing Policy (DMS Policy) that has significant impacts for NIH proposals. Its effective date is for proposals submitted with due dates on or after January 25^th, 2023.

Does this Policy Apply to My Proposed Research?

Determine if the proposed research is subject to the DMS policy. Carefully review the Funding Opportunity Announcement (FOA) for any specific institute or center requirements.

This DMS Policy applies to all NIH funded research which results in the generation of scientific data, including:

Research Projects (R)
Some Career Development Awards (K)
Small Business SBIR/STTR
Research Centers

The DMS Policy does not apply to research and other activities that do not generate scientific data, including:

Training (T)
Fellowships (F)
Construction (C06)
Conference Grants (R13)
Resource (G)
Research-Related Infrastructure Programs (e.g., S06)

Faculty Resources

UF Research Education and Training Programs list a number of resources to assist with creation of a data management plan and selection of a repository.

The UF Libraries host a variety of Research Data Management resources that may help with developing a data management plan. We urge you to review UF Libraries information for relevant resources that may help with this policy:

Data Management and Sharing

Allowable costs must be incurred during the period of performance even for scientific data and metadata preserved and shared beyond the award period. For example, if a Data Management and Sharing Plan proposes preserving and sharing scientific data for 10 years in an established repository with a deposition fee, the cost for the entire 10-year period must be paid prior to the end of the period of performance. Infrastructure costs that are included in institutional overhead or costs associated with the routine conduct of research are not allowable.

Curating data and developing supporting documentation, including formatting data according to accepted community standards; de-identifying data; preparing metadata to foster discoverability, interpretation, and reuse; and formatting data for transmission to and storage at a selected repository for long-term preservation and access.
Local data management considerations,such as unique and specialized information infrastructure necessary to provide local management and preservation (e.g., before deposit into an established repository)
Preserving and sharing data through established repositories, Costs associated with deposit of data into an established repository(s)

Develop a Plan for managing and sharing scientific data. Attach the DMS plan in the Other Plans section within FORMS-H as part of your NIH applications. FORMS-H must be used for application packages for due dates on or after January 25, 2023. DMS Plans will be collected in a NEW field called “Other Plans” on the PHS 398 Research Plan and Career Development Award forms. See Writing a DMS Plan for the details on what to include in a Plan.

DMS Plans are recommended to be two pages or less in length.
The Plan should cover six recommended elements
NIH has developed an options DMS Plan format page that aligns with recommended elements of a DMS Plan.
- A preview of this format page is available now, with a final fillable format version available by fall 2022.
Considerations for specialized datasets, data privacy, and human subjects protections:
- Applications subject to both the DMS Policy and the Genomic Data Sharing (GDS) Policy will submit a single Plan. See NOT-OD-22-198 for details and other considerations
- Human subjects participant data protections: Informed Consent, De-identification, Certificate of Confidentiality
- Any restrictions on sharing: Regulatory restrictions (e.g. HIPAA, GDPR), Tribal laws, policies and Tribal sovereignty, ethical considerations

Identify Methods/Approaches and Repositories

Identify appropriate methods/approaches and repositories for managing and sharing scientific data.
Some FOAs may specify repository requirements which must be followed.
NIH maintains a list of Repositories for Sharing Scientific Data

Proposal Budget Costs

Proposal budgets should include estimated funds needed for data management and sharing activities. These should include all allowable costs for DMS for all data types.

These costs should be budgeted under Other Direct Costs and best practice is to plan on full storage costs being incurred during the period of performance.

For assistance with the proposal budgeting process, please review the DMS section of DSP’s Other Direct Costs webpage, or by contacting the DSP Proposal Team at ufproposals@ufl.edu.

Changes to the DMS Plan

The NIH encourages data management and sharing practices to be consistent with the FAIR (Findable, Accessible, Interoperable, and Reusable) data principles and reflective of practices within specific research communities. The DMS Plan should reflect the proposed approach to data management and sharing at the time it is prepared and be updated during the award/ support period to reflect any changes in the management and sharing of scientific data.

Pre-Award Changes to DMS Plans

If NIH requires changes, applicants will be notified by the NIH GMS during the Just-in-Time (JIT) process
Revisions should be submitted as part of the JIT response (e.g. via DSP to Grants Management Specialist (GMS) or in eRA Commons)
DSP strongly suggests any changes required be compared against the original budget and if additional funds are needed to accomplish the revised plan, a revised budget is also submitted.

Post-Award Changes to DMS Plans

When PIs identify a need to change their DMS Plan, updates should be submitted to DSP as a formal request through UFIRST as a Term and Conditions Award Modification. DSP will review and facilitate the submission process to the NIH to request approval for changing the plan. NIH also expects DMS Plan changes to be addressed in the Research Performance Progress Reports (RPPR). For assistance with your RPPR, see the Progress Report section of DSP’s website.

When are Data Expected to be Shared?

Data are expected to be shared no later than time of publication of findings or the end of an award whichever is earlier.