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Research Data Management: NIH Data Management and Sharing Policy

What's in the new policy?

NIH grants submitted on or after January 25, 2023 must adhere to the new Data Management and Sharing (DMS) Policy. The policy applies to all UAB grant submissions to the NIH that will generate scientific data. Applicants will be required to submit a two-page data management and sharing plan.

There are notable differences from earlier NIH policies:

  • Changes in format and broader in scope
  • Required for all NIH grant submissions if the grant will generate scientific data
  • Defines what is and is not data (see below)
  • Asks PI to maximize appropriate data sharing
  • Data must be made available at the time of publication or at the conclusion of the granting period, whichever comes first



The final DMS Policy defines Scientific Data 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.”  


Watch our latest training webinar on the new NIH DMSP 


Click here to access the video

Click here to download the slides from the presentation (pdf)

How does the DMS policy affect grant submissions? 

  • You can request funds for DMS costs
  • DMSP is reviewed by NIH staff
  • the DMSP does not impact scoring
  • The DMSP may be updated as the project evolves
  • Non-compliance may impact future funding decisions for the recipient institution

What data should be shared?

  • Appropriate data to validate and replicate findings from published studies
  • Data from a study even if not directly linked to a publication
  • Null findings that do not result in publication

What doesn't fall under the policy?

  • Laboratory notebooks
  • Preliminary analysis/optimizations
  • Case report forms
  • Physical objects or specimens
  • Manuscript drafts or correspondence

What are acceptable reasons to not share?


Explicit federal, state, local, or Tribal law, regulation, or policy prohibits disclosure


Concerns around privacy or safety of research participants

Pre-existing consent policies or agreements prohibit sharing of participant-derived material


Digitization of datasets is impractical


The 6 elements of a DMSP

(Draft) Template DMSP

Fill out the template below to craft you DMS plan following the 2023 NIH guidelines


Example DMSPs following the 2023 NIH format

Example 1 -omics and sensitive clinical data 


DMPTool provides templates that can be used in developing Data Management Plans that meet the requirements for grant applications sent to US federal funding agencies. They offer templates for both the current guidelines and the forthcoming 2023 requirements.

Additional Resources

  • OSF Working Group on DMSP Guidance includes separate policy readiness checklist for librarians and researchers, example DMSPs, glossaries of policy and grant related terms and a repository finder (coming soon!)
  • provides information about all the NIH sharing policies. The FAQ page is especially helpful for specific questions.
  • Links to supplemental information detailing aspects of the new policy:
    • NOT-OD-21-014 – Elements of an NIH Data Management and Sharing Plan
    • NOT-OD-21-015 – Allowable Costs for Data Management and Sharing
    • NOT-OD-21-016 – Selecting a Repository for Data Resulting from NIH-Supported Research
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