NIH Data Management and Sharing Policy

NIH has issued a new policy effective for all grant applications and renewals submitted that generate scientific data starting January 25, 2023.  NIH announced in NOT-OD-26-046 the plan format has been streamlined and the 2026 Pilot DMS Plan format is required for due dates on or after May 25th, 2026.  This form may be submitted in grant applications before this date

Scientific Data is defined in the policy as "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."

Scientific data should be made accessible as soon as possible, and no later than the time of an associated publication or the end of the performance period of the extramural award that generated the data. 

Your plan may be subject to additional NIH Institute and Center Data Sharing policies. Please check the web site of the Institute you are applying to for specifics regarding repositories, etc. 

 

Updated Data Management and Sharing Plan format

NIH Links:

Writing a Data Management and Sharing Plan

2026 DMS Plan format template

The new format consists of the following questions, a list of key types of data and repository(ies), and incudes a text box to describe any limitations or exclusions to the policy. 

    1. Will there be maximum appropriate sharing of scientific data underlying peer-reviewed publications and other findings resulting from the work supported by this award (including preprints, refereed papers reported at conferences, and other findings)?
    2. Will the scientific data underlying peer-reviewed publications be shared by the time of publication, or for other findings, by the end of the period of performance, which includes no-cost extensions?
    3. Will shared scientific data be made available for at least as long as required by applicable data repository policies and/or journal policies?
    4. If scientific data derived from human research participants will be shared, will privacy, rights, and confidentiality of participants be protected as outlined in NOT-OD-22-213?
    5. List key types of scientific data and repository or example of repository
    6. For studies subject to the NIH Genomic Data Sharing Policy (GDS) (e.g., using NIH funds to generate large-scale human genomic data):
      1.  Will you share all large-scale human genomic and associated data in a NIH-designated repository according to the accelerated timelines expected in the GDS Policy?
      2. Do you anticipate that when sharing you will be able to meet the expectations of the Institutional Certification in the GDS Policy? 

 

Repositories

Selecting a Data Repository

NIH information on Repositories

 

Budget  

NIH Link: Budgeting for NIH Data Sharing and Management Plan

Data Management and Sharing costs per NIH guidelines are for preparing research data for sharing and sharing data/repository costs.  Costs associated with the routine conduct of research, including costs associated with collecting or gaining access to research data are not allowed per NIH guidelines in the DMS cost section of the budget.

Although DMS Plans will not be seen by peer reviewers, the justification provides details about the plan for reviewers to assess reasonableness of DMS costs. This is the only place in the application the reviewers will see any details of the DMS Plan.

Data Management and Sharing costs must be incurred during the performance period of the project, even though scientific data and metadata shared beyond the award period.

  1. Budget
    1. Allowable costs include:
      1. Repository fees (e.g., data deposition, storage)
      2. Labor for de-identification, data curation (e.g., structuring, indexing, etc.), formatting data, developing supporting documentation and metadata, de-identification,  etc.
    2. Unallowable costs include:
      1. Infrastructure costs
      2. Dartmouth data storage fees
      3. Research data access fees
    3. Costs must be paid upfront before the end of the performance period (i.e. repository fees)
    4.  Budget Format
      1.  DMS costs are required to be listed in their respective cost categories such as Personnel (e.g., data curation), or Other Costs (e.g., repository fees).
      2. Personnel costs associated with data management and sharing activities are included in the overall budgeted personnel effort which now includes both the effort to conduct the science of the project and the effort to share the data.
      3. DMS Costs in detailed and modular budgets guide
  2. Justification:
    1. Detailed budget justifications require a section labeled: “Data Management and Sharing Justification”.
    2. Modular budget justifications require a section labeled, “Data Management and Sharing Justification” in the “Additional Narrative Justification” document.
    3. If not requesting costs, include a statement that no costs are being requested for data management and sharing.
    4. If requesting costs:
      1. Include total direct cost requested for Data Management and Sharing.
      2. Name of the established repository(ies) to be used and include summary of type and amount of scientific data to be preserved and shared.
      3. Describe the specific costs (e.g., personnel, repository fees) and an amount assigned for each cost that are embedded in detailed budget line items or are components of modular requests, For personnel, list only the total cost.
      4. Length no more than ½ page.
    5. DMS Justification checklist and examples

Resource Sharing Plan

The Resource Sharing plan is only required for projects that develop research tools and/or model organisms.  For more specific information (and suggested language if applicable) please see Dartmouth OSP NIH Resource Sharing Plans. 

NIH Review of the DMS Plan

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 before award. Scientific reviewers will not see the plan but they will see the budget and budget justification.  The approved plan becomes part of the terms and conditions of the award. 

Updating the DMS Plan

The process for submitting requests to update your plan depends on where you are in the grant award cycle:

  1. Pre-award: Just in time: There is a new Data Management and Sharing Plan Revision section in the JIT screen to upload the revised plan.
  2. Post-Award: RPPR: Within 30 day of RPPR submission, upload the revised plan to section C.5.c  
  3. Post-Award: Off Cycle requests: select “submit a Prior Approval – DMS Request” in the Prior Approval Module in ERA Commons to submit a revised plan

DMS Plan Reporting

Section 5C of the RPPR has been updated to report data sharing activities.  Please see the NIH RPPR instruction guide for specific instructions.

  1. Question C.5.c automatically indicates if the award is applicable to the 2023 NIH DMS policy
  2. For each data type in the plan, report on Data Type, has the data been generated, Has the data been shared, if not, what is the sharing status, repository, and Unique Identifiers/DOI.
  3. Describe any deviations from the plan
  4. Report any prospective changes to the plan and if changes, upload the revised plan

Institutional Resources

Storage/Computing

 

Dartmouth Library Data Management assistance:

 

Questions about sharing human subject data

 

Who do I contact with questions?

 

Helpful Links

 

 

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