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Publish: NIH Data Management and Sharing Policy

NIH Data Management and Sharing Policy

NIH Policy for Data Management and Sharing

The new NIH Policy for Data Management and Sharing (NOT-OD-21-013) goes into effect on 2023-01-25. The policy requires that:

  • All NIH grants submit a 2-page data management and sharing plan
  • Researchers "maximize the appropriate sharing of scientific data"

There are several specific details to note about the new NIH policy:

  • Data should be shared in a repository.
  • Sharing will happen sooner: "shared scientific data should be made accessible as soon as possible, and no later than the time of an associated publication, or the end of performance period, whichever comes first.”
  • Researchers can ask for money to pre-pay long-term storage costs and for data management activities. More information on allowable costs is available here: 
  • If a DMP needs to be revised, it should be updated and reviewed during regular progress reports.
  • The new policy takes a more nuanced approach with respect to the sharing of data on human subjects. The policy outlines specific considerations for this data:
    • "Researchers proposing to generate scientific data derived from human participants should outline in their Plans how privacy, rights, and confidentiality of human research participants will be protected"
    • "NIH strongly encourages researchers to plan for how data management and sharing will be addressed in the informed consent process"
    • "Researchers should consider whether access to scientific data derived from humans, even if de-identified and lacking explicit limitations on subsequent use, should be controlled."

NIH has a dedicated webpage,, containing information about the policy and a list of NIH-supported data repositories. If you have questions about the policy or where to share your research data, please contact

Data Management and Sharing Plans (DMS Plans)

Plan Format and Contents

NIH will provide an optional template for creating a DMS Plan. The draft template is available here and is not final.

The Library is developing an example NIH DMS Plan which will be available soon.

Reviewing DMS Plans

Initially, grant reviewers will NOT review DMS Plans except where sharing is "integral to the funding opportunity". Reviewers will review budget justifications for data management and sharing costs. Program officers will review DMS Plans and can ask for revisions to be made to Plans through the Just-in-Time process.

Data Management Costs

Where data management costs will be included in the grant, be sure to include them in both the budget and budget justification. Allowable costs include:

  • Curating data and developing supporting documentation
  • Local data management considerations
  • Preserving and sharing data through established repositories

More information on allowable costs is available in NIH Notice NOT-OD-21-015.

Sharing Human Subject Data

Guidance on the controlled sharing of human subject data is being developed and will be available soon. Questions about the handling of human subject data should be directed to IRB (