NIH Data Management and Sharing Policy | Office of Sponsored Projects Administration | SIU

Prospectively planning for how scientific data will be managed and ultimately shared is a crucial first step in optimizing the reach of data generated from NIH-funded research. Investigators and institutions are encouraged to consider these crucial elements early in research planning.

1. Determine if your proposed research is subject to the DMS policy.
   • NIH requires ALL applicants planning to generate scientific data to prepare a DMS plan that describes how the scientific data will be managed and shared. 
   • This policy does not apply to awards for Training Programs and Fellowship Programs. Please see the complete list of NIH activity codes subject to the DMS policy.
2. Identify appropriate methods/approaches and repositories for managing and sharing scientific data.
3. Develop a plan for managing and sharing scientific data.
   • DMS plans are recommended to be two pages or less in length.  
   • NIH has developed an optional DMS plan format page that aligns with the recommended elements of a DMS plan. Important: Do not include hypertext (e.g., hyperlinks and URLs) in the DMS plan attachment.
   • Sample Plans: NIH has also developed sample plans to get you started. 
     • The sample DMS plans available for educational purposes only. Note that these samples are not intended to be used as templates and their use does not guarantee approval by NIH.
     • The various sample DMS plans may reflect additional expectations established by NIH or specific NIH Institutes, Centers or Offices that go beyond the DMS Policy. Applicants will need to ensure that their plan reflects any additional, applicable expectations (including from NIH policies and any ICO- or program-specific expectations as stated in the funding opportunity announcement).
       
       • In some cases the NIH sample plans reference the sponsored programs office as the office responsible for oversight. OSPA will not be engaging in any oversight activities other than ensuring the plan is included in both the proposal and if awarded, annual and final progress reports. The PI should work with their school directors to determine how the plan will be monitored and managed, frequency of the oversight and by whom at the institution (e.g. titles, roles).
   • Elements to include in a plan:
     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
     6. Oversight of Data Management and Sharing

NIH recognizes that making data accessible and reusable for other researchers may incur costs. For that reason, investigators may request funds toward data management and sharing in the budget and budget justification sections of their applications.

Allowable Costs*

Reasonable, allowable costs may be included in NIH budget requests for:

• Curating data
• Developing supporting documentation
• Formatting data according to accepted community standards or for transmission to and storage at a selected repository for long-term preservation and access
• De-identifying data
• Preparing metadata to foster discoverability, interpretation and reuse
• Local data management considerations, such as unique and specialized information infrastructure necessary to provide local management and preservation (for example, before deposit into an established repository)
• Preserving and sharing data through established repositories, such as data deposit fees
  • If the Data Management & Sharing (DMS) plan proposes deposition to multiple repositories, costs associated with each proposed repository may be included

Unallowable Costs

Budget requests must NOT include:

• Infrastructure costs that are included in institutional overhead (for instance, Facilities and Administrative costs). 
• Costs associated with the routine conduct of research, including costs associated with collecting or gaining access to research data. 
• Costs that are double charged or inconsistently charged as both direct and indirect costs.

To request funds toward DMS costs:

1. For applications submitted for due dates before October 5, 2023: Include a line item in the budget form for “Data Management and Sharing Costs.” Include a brief summary of the DMS Plan and a description of the requested DMS costs in the budget justification, labeled as “Data Management and Sharing Justification.”
2. For applications submitted for due dates on or after October 5, 2023: Include costs in the appropriate cost category of the budget form, e.g., personnel, equipment, supplies and other expenses (following the instructions for the R&R Budget Form or PHS 398 Modular Budget Form, as applicable). While the single cost line item is no longer required, NIH will require applicants to specify estimated DMS cost details within the “Budget Justification” attachment of the R&R Budget Form or “Additional Narrative Justification” attachment of the PHS 398 Modular Budget Form, pursuant to the instructions.

Find more details regarding budgeting DMS costs here.

*Note that all allowable costs submitted in budget requests must be incurred during the performance period, even for scientific data and metadata preserved and shared beyond the award period. 

For instance, if a DMS 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 before the end of the period of performance.

Applicants planning to generate scientific data will submit DMS plans to NIH as part of the funding application or proposal. Note that plans are NOT part of scored peer review criteria unless specifically noted in the Funding Opportunity Announcement. NIH program staff oversee reviewing and approving plans prior to award.

Submitting the Plan:

• DMS plans should be included within the “other plan(s)” field on the PHS 398 Research Plan or PHS 398 Career Development Award Supplemental Form as indicated in the Application Instructions.
• A brief summary and associated costs should be submitted as part of the budget and budget justification (see Budgeting for Data Management and Sharing and the Application Instructions for details).

Peer review will not see or review DMS plans, but will consider any related budget items.

• Program staff at the proposed NIH Institute or Center (IC) will assess DMS plans. During peer review, reviewers will not be asked to comment on the DMS plan nor will they factor the DMS plan into the overall impact score, unless sharing data is integral to the project design and specified in the Funding Opportunity Announcement (see NOT-OD-22-189). 

NIH program staff will review the DMS plan for acceptability and may request modifications prior to award as appropriate.

Plans must be approved by the funding institute prior to award.

Awardees are expected to carry out data management and sharing as outlined in approved plans and as a term and condition of award. 

1. Manage and share data as described in the approved DMS plan.
2. Provide updates on data management and sharing activities in annual progress reports.
3. If plans change over the course of the project, work proactively with a NIH program officer to obtain review and approval of modifications.