Understand the NIH Data Management & Sharing Policy
When is a DMSP required?
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 by 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."
Read the full policy announcement here: NOT-OD-21-013
A DMSP is required for research projects (most R- and U-series), most K-series career development awards, SBIR/STTR, and research centers (P-series).
The DMSP requirement does not apply to applications for training and fellowship awards (T and F-series), or construction (C06), conference (R13), education (R25), resource (G-series) or research-related infrastructure grants (S06, S10).
A complete list of NIH application types that require a DMSP can be found here: NIH Activity Codes Requiring a DMSP
In addition to the NIH-wide policy, many NIH Institutes, Centers and programs have specific data sharing requirements, including stipulations for the use of NIH-supported data repositories. Be sure to check the application instructions for specific funding opportunities, or see specific initiatives here: Institute and Center-Specific DMS Policies
Data sharing is not a requirement, but NIH expects this to be maximized and implemented responsibly. Data management is a requirement for all applicable awards.
Allowable costs for DMS
The following costs associated with DMS may be included in the application budget:
- Costs associated with curating data and developing supporting documentation.
- Specialized infrastructure and other costs associated with local data management.
- Costs associated with preservation and sharing of data through established repositories.
Costs incurred during the course of data acquisition, or that are already supported by institutional overhead, are not applicable for additional funds. All DMS costs included in the application budget must be incurred during the award performance period.
Read the policy notice for DMS costs here: NOT-OD-21-015
During the application and award process
- The full DMSP is uploaded as a separate attachment with the application.
- A brief description of the DMSP is included in the Budget Justification, along with associated costs. If no costs for DMS are requested, state this.
- On the R&R Budget Form: include DMS costs under “F. Other Direct Costs” as a line item until October 5, 2023. After this date, the single DMS cost line item is no longer required according to a recent Notice released by NIH. DMS costs must be requested in the appropriate cost category, e.g., personnel, equipment, supplies and other expenses in the R&R Budget Form. Within the Budget Justification, NIH will require detailed estimated DMS costs.
- On the PHS 398 Modular Budget: use the Additional Narrative Justification attachment and clearly indicate “Data Management and Sharing Justification” with the cost amount. PHS 398 Modular Budget Instructions
- Instructions for routing the DMSP document and DMS budget costs in Kuali Research can be found at the UMB SPA website: SPA Kuali User Resources-NIH DMSP
- Study section reviewers will not see the application DMSP.
- Reviewers will see and comment on the appropriateness of the DMSP budget as included in the Budget Justification. However, this is not scored.
- DMS plans will be assessed by NIH program staff.
- Insufficient plans can be revised at the instruction of NIH program staff during the JIT phase.
- Read the policy notice for DMSP assessment and implementation here: NOT-OD-22-189: Implementation Details for the NIH Data Management and Sharing Policy
- Compliance with the approved DMSP will be incorporated into the Terms and Conditions of an award. Changes to the DMSP must be approved by the funding IC.
- DMSP compliance will be monitored at regular reporting intervals. DMSP activities and updates must be reported in the award RPPRs.
- NIH is developing mechanisms and tools to support oversight.
- Compliance with the approved DMSP may factor into future funding decisions.