NIH Data Management and Sharing Plan (2023)

GET READY! New NIH Policy on Data Management and Sharing – NOT-OD-21-013

The National Institute of Health (NIH) has implemented a new Policy for Data Management and Sharing (DMS Policy), which will take effect January 25, 2023. The policy requires ALL new and competing proposals/renewals that will generate scientific data to submit a detailed plan outlining how data will be stored, protected, and ultimately shared.

“NIH requires researchers to prospectively plan for how scientific data will be preserved and shared through submission of a Data Management and Sharing Plan (Plan). Upon NIH approval of a Plan, NIH expects researchers and institutions to implement data management and sharing practices as described.”

The DMSP policy will have two main requirements:

  1. Submission of a two-page data management and sharing plan. Research proposals without a Plan will not be considered for funding.
  2. Compliance with the approved plan. Failure to provide updates in grant reporting may result in enforcement actions, including the addition of special terms and conditions or award termination. Failure to deposit data after the end of the funding period may negatively influence future opportunities.

Prospective grant applicants will need to submit their DMSP along with their application. The DMSP will be assessed by NIH Program Staff (peer reviewers will also have the opportunity to comment on the proposed data management budget). The Institute, Center, or Office (ICO)-approved plan becomes a Term and Condition of the Notice of Award. However, researchers will have the ability to update and amend their DMSP as their research plan changes and evolves.

We'll be hosting a series of Town Halls to go over the new NIH Policy and to answer all your questions!

Fall 2022 Town Halls scheduled:

  • Session 1: Thursday, October 27, 2022; 12:00pm – 1:00pm EST | Overview of the Policy (Slides now available)
  • Session 2: Friday, November 18, 2022; 2:00pm – 3:00pm EST | Budgeting for the DMS Plan (Slides now available)
  • Session 3: Thursday, December 1, 2022; 12:30pm – 1:30pm EST | TBD


Note: This page is intended to inform the Columbia University research community about the new NIH policy and to highlight appropriate information and resources, as they become available.

The effective date of the DMS Policy is January 25, 2023, and applies to:

  • Competing grant applications and proposals that are submitted to the NIH for the January 25, 2023 deadline, and subsequent receipt dates
  • Proposals for contracts that are submitted to NIH on or after January 25, 2023;
  • Other funding agreements (e.g., Other Transactions) that are executed on or after January 25, 2023, unless otherwise stipulated by the NIH

DMSPs should be no more than two pages long and must address the following elements:

  • Data Type: Description of the data that will be generated, managed, preserved, and ultimately shared.
  • Related Tools, Software and Code: Explanation of any specialized or custom tools and software needed to access or manipulate shared data.
  • Standards: Detailed description of data standards applied to shared data and associated metadata, if applicable.
  • Data Preservation, Access, and Timelines: List of repositories, data lakes/warehouses where data will be archived, as well as documentation on how data will be discoverable and accessed, and when and how long it will remain available.
  • Data Access, Distribution, and Reusage Considerations: Explanation of any potential issues and restrictions affecting access, distribution and reusage of data.

Oversight of Data Management and Sharing --Explanation of how compliance and adherence will be monitored and managed. During the funding period, compliance with the Plan will be determined by the NIH ICO. Compliance with the Plan, including any Plan updates, may be reviewed during regular reporting intervals (e.g., at the time of annual Research Performance Progress Reports (RPPRs)).

The DMS Policy does not currently mandate any particular repository for data, but some individual NIH institutes have specified required repositories. In general, researchers are encouraged to deposit their data into repositories that support effective data discovery and reuse. The NIH does provide guidance for selecting a repository and provides a list of recommended domain-specific and generalist data repositories. Researchers are expected to discuss their plan for preservation of access to data resulting from the project.

Data management and sharing costs are allowable costs that can be included in grant budgets. These can include personnel costs for data management and sharing activities, curation costs, data deposit fees, and long-term data preservation costs. Costs for data storage beyond the period of the grant may be paid but they must be paid during the award period. Costing approaches continue to be the subject of discussion and more information may become available in the future.

Budgeting for Data Management and Sharing

Investigators may request funds towards data management and sharing in the budget justification section of their application.

Allowable Costs

  • 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).

NOTE: 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.

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
  • Scientific Data: 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.
  • Data Management: The process of validating, organizing, protecting, maintaining, and processing scientific data to ensure the accessibility, reliability, and quality of the scientific data for its users.
  • Data Sharing: The act of making scientific data available for use by others (e.g., the larger research community, institutions, the broader public), for example, via an established repository.
  • Metadata: Data that provide additional information intended to make scientific data interpretable and reusable (e.g., date, independent sample and variable construction and description, methodology, data provenance, data transformations, any intermediate or descriptive observational variables).

NIH Resources


Columbia University Resources

Other Resources