NIH 2023 Data Management and Sharing Policy (DMS Policy)

Previously, the NIH only required grants with $500,000 per year or more in direct costs to provide a brief explanation of how and when data resulting from the grant would be shared.

The 2023 NIH policy is entirely new. Beginning January 25, 2023, ALL grant applications or renewals that generate Scientific Data must include a robust and detailed plan for managing and sharing data during the entire funded period. This includes information on data storage, access policies/procedures, preservation, metadata standards, distribution approaches, and more. You must provide this information in a data management and sharing plan (DMSP). The DMSP is similar to what other funders call a data management plan (DMP).

The DMSP will be assessed by NIH Program Staff (though peer reviewers will be able 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.

A Data Management & Sharing Plan (DMSP) must be submitted as part of the funding application for all new and competing proposals/renewals that generate Scientific Data for January 25, 2023, and subsequent receipt dates. The term 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."

High-level first steps

1. Determine whether the NIH policy applies to you. If you are unsure whether NIH's new policy will apply to your research, check NIH's page about Research Covered Under the Data Management & Sharing Policy. Remember, all NIH-funded or partially funded research generating Scientific Data will be subject to this policy beginning on January 25, 2023.
2. Figure out your personal timeline. If you have an active NIH award going up for renewal with a receipt date of January 2023, or if you are planning to submit an NIH proposal this year, then developing a DMSP should be a high priority, especially if you are working with external collaborators as it may take time to set up appropriate data procedures/agreements. 
3. Read through this website to familiarize yourself with the changes and with the policy itself (including the supplements)
4. Familiarize yourself with the FAIR principles (Wilkinson et. al, 2016). The FAIR (findable, accessible, interoperable, reusable) data principles are the guiding principles the NIH has used in creating the new policy. 
5. Assess your project and data management practices relative to the policy (see the NIH-provided supplements below), especially around documenting existing practices and developing new ones to address the increased emphasis on data sharing and administrative oversight.
6. Review data services at ASU (e.g., computing, storage, consulting) and assess whether they will meet your needs. Also, consider costs you may need to budget for, such as labor for data cleaning and documentation (see the NIH-provided supplement on allowable costs).

If your research requires ASU’s Institutional Review Board (IRB) approval, IRB may ask for the information in your DMSP. Therefore, drafting your DMSP before seeking IRB approval is strongly recommended.

If you plan to generate scientific data, you must submit a Data Management and Sharing Plan (DMSP) to the funding NIH ICO as part of the Budget Justification section of your application for extramural awards. 

Your plan should be two pages or fewer and must include:

• Data Type

• Related Tools, Software and/or Code

• Standards

• Data Preservation, Access, and Associated Timelines

• Access, Distribution, or Reuse Considerations

• Oversight of Data Management and Sharing.

To draft the plan itself, we recommend the DMPTool (log in with your ASURITE ID) using the NIH 2023 template. Additional guidance for completing each section of the template will be added to the DMPTool on a rolling basis. Check out our self-guided tutorial to learn how to use the DMPTool to and get updated guidance on writing your data management and sharing plan.

If you are including institutional services and tools in the DMSP, be sure to budget for any associated costs. See the following section for what kinds of services and tools are available. 

Any costs related to complying with the policy must be paid for up-front during the performance period. For example, costs for long-term data preservation must be budgeted for in the proposal and paid before the end of the grant. You may find the NIHM Data Archive (NDA) cost estimation worksheet useful.

Unlike NIH's prior policies, the new policy requires a plan for maximizing the sharing of Scientific Data while acknowledging factors (legal, ethical, or technical) that may affect the extent to which it can be shared. The new NIH definition of 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.”

If you are conducting research with human subjects, you must incorporate consent during the data management and sharing process, even if data will be de-identified.

If you are conducting research with American Indian, Alaska Native, or Indigenous populations, you must secure appropriate agreements with tribal authorities before using and sharing that information.

NIH recommends sharing datasets through established data repositories to improve the FAIRness (Findable, Accessible, Interoperable, and Re-usable) of the data.

While NIH supports many data repositories, your data may or may not be appropriate for an NIH repository. You should also consider data repositories supported by other organizations, both public and private.  

For more information, see:

You will need to share your data when you publish your work or before your performance period ends, whichever comes first.

In general, you should make your data accessible as soon as possible. You can also use relevant requirements and expectations such as data repository policies, award record retention requirements, or journal policies, to decide when to share your data sets.

The policy does not state specific requirements for how you share your data.  When you share your data, you should address the NIH’s goal of making data as accessible as possible. The NIH expects all shareable data to be made available, whether or not it is associated with a publication.

All data used or generated as part of a grant must be managed, but not all data should be shared. You should not share data if doing so would violate privacy protections or applicable laws. 

You may share data related to human subjects, but your plan should address how data sharing will be communicated in the informed consent process (e.g., consent forms, waivers of consent). 

Before submitting your data to your chosen repository, you will need to:

• Bundle your data together in logical "chunks" for citation and reuse. Appropriate bundling makes it easy to assign a persistent identifier(s) (e.g., DOI) to the dataset.  NIH strongly encourages the use of persistent identifiers for datasets. These identifiers, usually assigned by data repositories, make it easier for others to cite your data and for the NIH to track compliance.

• De-identify your data, if appropriate

• Convert your data to an open, machine-readable file format such as .csv when possible

• Use data and metadata standards appropriate to your field (if any). Refer to fairsharing.org for a searchable database of standards.

• Document the dataset thoroughly in a separate readme.txt file, and/or create metadata according to the format required by your chosen repository or discipline

Refer to the Research Data Sharing and Management library guide for help on storing and publishing your research data.

You must comply with the ICO-approved plan and document that compliance in reports such as the annual Research Performance Progress Report (RPPR). Non-compliance may result in enforcement action from the NIH such as

• Addition of special terms and conditions to the award

• Termination of the award

Non-compliance may also affect future funding decisions. To avoid possible issues when reporting progress, ensure that your submitted plan contains enough detail for the program officer to be able to evaluate compliance.

If you make changes to your submitted plan, your new plan must be re-approved. We will provide guidance from the NIH on the process for making changes soon.

Research Data Management and Sharing

Research Integrity and Assurance

General Support

Below are examples of data management and sharing plans that are helpful as guides for your own data management and sharing plan.

When developing your own plan or choosing an existing template, consider your own project needs. 

from: https://data.library.arizona.edu/data-management/nih-data-management-sharing-policy-2023 CC By-NC 4.0

This guide was adapted from the University of Arizona's NIH Data Management and Sharing Policy (2023) page. ASU Library recognizes their expertise and authorship.