NIH proposals submitted after January 25, 2023 will be subject to the funder’s new “Data Management and Sharing” (DMS) policy. According to the NIH, “Sharing scientific data accelerates biomedical research discovery, in part, by enabling validation of research results, providing accessibility to high-value datasets, and promoting data reuse for future research studies.” The new policy seeks to further those aims.
NIH has prepared many resources to help PI’s and research administrators understand this transition. This post draws on NIH’s Data Management & Sharing Policy Overview, which leads readers through a step-by-step consideration of the new policy, its implications, and its implementation.
Key Aspects of DMS:
- The new DMS policy applies to all NIH proposals submitted on/after January 25, 2023 that will generate scientific data. That means the vast majority of NIH proposals will be affected.
- Only a few types of NIH proposals are not subject to the policy: Training (T), Fellowships (Fs), Construction (C06), Conference (R13), Resource (Gs), and Research-Related Infrastructure Programs. You can check whether the DMS policy applies to a particular grant program by viewing the “Applicable Activity Codes” table.
- The DMS policy will impose important requirements on PIs and institutions for both the pre-award (proposal development) and post-award (implementation) phases, including: planning & budgeting for managing and sharing data, submitting a DMS plan (2 pages max) as a required part of most proposals, and complying with the plan.
- Particular Institutes, Centers, or Offices within NIH may impose additional or specific DMS requirements beyond those set forth in the DMS policy. Such requirements can be found in particular funding annoucements.
- Projects that deal with genomic data will no longer be required to submit a separate Genomic Data Sharing plan. Instead, genomic data sharing considerations should be addressed in the DMS plan.
Planning & Budgeting for DMS
- According to NIH, “Under the DMS Policy, researchers are expected to maximize the appropriate sharing of scientific data, which is defined as data commonly accepted in the scientific community as being of sufficient quality to validate and replicate the research findings. Not all data generated during NIH-supported research will constitute scientific data under the DMS Policy.” Examples of data NIH does not expect researchers to share include: lab notebooks, preliminary analyses not necessary or of sufficient quality to validate findings, drafts of scientific papers, peer reviews, and communications with colleagues. (Source: FAQs)
- Investigators may request DMS funds in the proposal budget / budget justification, including funds to cover costs associated with curating and de-identifying data, data formatting and transition, preparing metadata, and preserving and sharing data through established repositories. Importantly, though the DMS policy requires data to be preserved and shared after the project ends, allowable costs must be incurred during the performace period. So DMS funds should be budgeted for the entire duration of the sharing period and be paid before the project performance period ends. More info.
- DMS budgets should not include indirect costs or costs associated with the routine conduct of research, including costs associated with collecting or gaining access to data.
- NIH has information on Selecting a Data Repository, including lists of Repositories for Sharing Scientific Data.
- Grantee institutions should retain data for at least 3 years following grant closeout.
Writing a DMS Plan
- NIH has developed several resources to help PIs write a DMS plan/ See: Writing a Data Management & Sharing Plan.
- The DMP Tool is a free online tool developed by the University of California which can generate data management plans that align with requirements of various funders, including the new NIH DMS policy. UNCG is a participating organization and users can use their SSO credentials to log into the tool.
- NIH’s Optional DMS Plan format page (pdf) shows what questions should be addressed in a model, 2 page DMS plan document. A fillable version is expected soon. Several sample plans are also available (follow the link, then scroll down).
- For most funding opportunities, peer reviewers don’t review the DMS plan and do not score it. Peer reviewers do consider the reasonableness of DMS costs as described in the budget justification.
More info and resources are available at https://sharing.nih.gov/.
The full policy is here: Final NIH Policy for Data Management and Sharing (NOT-OD-21-013)
