NIH Data Management and Sharing Policy Goes into Effect Soon

NIH (and many others) believe that data sharing accelerates and improves science. After several years of iterative feedback, NIH’s new Data Management and Sharing Policy goes into effect for grants submitted January 25, 2023 and thereafter. This policy means that as of January 25, 2023, investigators applying for NIH funding must:

  • Plan and budget for the managing and sharing of data
  • Submit a Data Management and Sharing Plan outlining how scientific data and any accompanying metadata will be managed and shared, taking into account any potential restrictions or limitations.
  • Comply with the Data Management and Sharing plan approved by the funding Institute or Center (IC).

What is a Data Management and Sharing Plan?

A Data Management and Sharing Plan (“Plan”) is a short document that must accompany your budget justification. There are 6 sections: 1) Data Type, 2) Related Tools, Software and/or Code, 3) Standards, 4) Data Preservation, Access, and Associated Timelines, 5) Access, Distribution, or Reuse Considerations, and 6) Oversight of Data Management and Sharing. 

What you write in this Plan is what you’ll be expected to do. NIH expects any changes or deviation from the Plan will be discussed with your Program Officer.  They have assembled FAQs here, and we’ll summarize the most common questions below.

Do I really have to share data? Which data? When? How?

NIH expects data sharing to be maximized, so it wants to see researchers share as much data as possible. However, they have made provisions for tricky situations–especially in regards to human subjects research. If you must restrict data sharing for whatever reason, openly state these issues in your Plan and include your rationale.  
  • Which data do they mean? NIH expects investigators to maximize the appropriate sharing of “scientific data”, which is defined as data commonly accepted in the scientific community as being of sufficient quality to validate and replicate the research findings. Therefore, the data that underlies research publications are the most obvious to share. However, they note that other data may also be of benefit to the scientific community, giving the example of data underlying null and negative findings. 
  • When should data be shared? NIH expects investigators to share data at the time of publication for an associated research article or at the end of the performance period, which ever is sooner.  Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) grants have different stipulations as outlined in their directive. 
  • How should data be shared? Domain repositories are preferred, and NIH provides a partial list here. Since a domain repository is not available for every type of data, we also have the Illinois Data Bank, a free resource for UIUC researchers. Can’t release the data openly? See UIUC’s Data Transfer and Use Agreement Guidance.

Templates and Examples

Your Plan must reflect the details in your proposal, so examples are provided only in order to help investigators see what a strong Plan looks like. Do not copy the text verbatim.

Note that earlier iterations of NIH’s data sharing policy (2003-2023) required a paragraph describing data sharing activities for grants >$500,000, but the new policy means the description must be more detailed and must accompany any application for research that will generate data, regardless of funding level.

Plan Review (Optional)

The Research Data Service provides fast, free, and confidential feedback on draft Plans. We work with library-based subject experts so that our feedback incorporates disciplinary and data management expertise. Send us your draft Plan, a link to the funding announcement, and the Sponsored Programs Administration (SPA) deadline by email or filling out this form.  If you’ve created your Plan in the DMPTool, then select the “Request Feedback” option on the last page of your template to contact us for a review.