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NIH Policy for Data Management and Sharing: Implementation Details

Provides information on the NIH policy updates for data management plans and sharing, effective January 25, 2023. Lack of compliance can lead to a delay in receipt of funds.


First Steps

For the data management and sharing plan, you must list ALL the data that you will produce for your project.  However, the NIH recognizes that not all of that data will be preserved and shared.  Before starting your plan try thinking through the following steps:

1. Consider ALL the data that will be produced during the course of your project.  Write these down and include details such as the type of data, level of aggregation, and number of samples/participants.  Think about what associated metadata would be needed in order to easily interpret the data.

2. Decide what data will be shared. Keep in mind ethical, legal, and technical limitations that will prevent sharing specific data sets (e.g. did not get consent to share, patent application, etc.)   The NIH has outlined what are justifiable reasons for not sharing data.

3. Determine where you would like to share your data.  Depending on your data, NIH has set repositories for sharing.  See what meets your needs here.

Steps in Detail

  • Data sharing plans and genomic data sharing plans will no longer be submitted to the “Resource Sharing Plan(s)” field, and instead will be submitted to a new "Other Plan(s) field in the appropriate FORMS-H forms.


  • There will be no requirement to submit a separate Genomic Data Sharing plan.  One plan will be expected.


  • The requested direct costs to support the activities proposed in the DMS Plan must be indicated as “Data Management and Sharing Costs” 


  • A brief summary of the DMS Plan and a description of the requested Data Management and Sharing Costs must be included within the budget justification attachment.


  • The appropriate documentation will be updated on the NIH website by the Fall of 2022.
  • Data management and sharing plans will be reviewed and assessed by NIH program staff, not by peer reviewers.


  • Data management and sharing plans will not factor into the overall impact score of the applications.


  • Peer reviewers can comment on the reasonableness of costs.


  • NIH staff at the proposed NIH Institute or Center will decide if the Plan is acceptable. They may request revisions in the Just-in-Time process.
  • If application is approved but the Data Management and Sharing Plan is not approved, applicants will be notified.


  • Must revise and resolve any issues with the plan.


  • The revised plan must be submitted for approval.  This will be for the Just-in-Time process before funds can be released.
  • You are required to comply with the plan that was approved.


  • DMS Plans may be updated during regular reporting intervals as part of the annual Research Performance Progress Report (RPPR) process. Changes to the DMS Plan must be approved by the funding NIH Institute or Center.