On this page, you will find responses to frequently asked questions about the NIH Data Management and Sharing Policy. The information on this page is not meant to be exhaustive. In many cases, answers will depend on what type of research data being created, the policies of the specific NIH ICO, and other factors.
If you have questions about the responses displayed below or if there are questions you would like added, please contact John Borghi.
What is the NIH Data Management and Sharing Policy?
The Data Management and Sharing (DMS) Policy is a set of requirements and guidelines related to the management and sharing of research data generated by work funded wholly or partially by the National Institutes of Health.
This policy applies to all proposals received after January 25th, 2023 that result in the generation of scientific data.
At its core, the policy requires two things:
This policy is foundational. Other policies, such as those of individual institutes and centers, may be built upon it.
What is a Data Management and Sharing Plan (DMSP)?
A DMSP is a two-page document included in applicable NIH proposals that prospectively outlines how a research team intends to manage, preserve, and share the scientific data associated with the proposed work.
What should be included in a DMSP?
The following six elements must be addressed in a data management and sharing plan.
Please note that individual centers, offices, and calls for proposals may have specific requirements about how these elements should be addressed (e.g. the use of specific repositories.
While researchers are, at present, not required to follow any specific format when creating their DMSP, the Stanford DMP Service recommends describing each of the elements above in discrete sections if possible.
What data needs to be shared under the DMS Policy?
In writing their data management and sharing plans, NIH expects researchers to “maximize the appropriate sharing of scientific data generated from NIH-funded or conducted research, consistent with privacy, security, informed consent, and proprietary issues.” Please refer to the definitions of “scientific data” and “data sharing” on the Key Terms and Definitions tab for more information.
The policy does not state that all data needs to be shared openly, meaning without restriction on who can reuse the data and for what purpose. However, restrictions on data sharing need to be outlined in the data management and sharing plan.
What costs can be included/not included?
Budget caps have not been increased but, under the DMS policy, NIH will allow researchers to add reasonable costs related to data management and sharing in their proposals as direct costs. Costs that have explicitly been called out as being allowed include the following:
What help is available?
A constellation of expert service providers is available to help researchers at Stanford navigate the data-related policies and expectations that apply to them and their data, including the NIH Data Management and Sharing Policy.
The Stanford DMP Service provides a single point of entry for getting assistance writing data management and sharing plans and, when necessary, referring questions to other services available on campus, such as those within the libraries, the Quantitative Sciences Unit (QSU), and the Stanford Program on Rigor and Reproducibility (SPORR).
What is DMPTool?
DMPTool is a platform for writing effective data management plans, including NIH data management and sharing plans.
Available free of charge, DMPTool includes templates, guidance, and links that have been created by data management experts at and beyond Stanford. Researchers are not required to use DMPTool to create data management and sharing plans, however, the tool is recommended by Stanford DMP Service.
After the policy is implemented (and with the requisite permissions), the Stanford DMP service may share selected DMSPs from funded proposals with the Stanford community through the DMPTool.
Do I need to share all of my data openly?
Not necessarily. In writing their DMSPs, researchers are expected to “maximize the appropriate sharing of scientific data generated from NIH-funded or conducted research, consistent with privacy, security, informed consent, and proprietary issues.”
This is not an explicit requirement to share data openly, meaning without restriction on who it is shared with and for what purpose. Rather, it is an acknowledgment that, because of certain ethical, legal, and social issues, not all data can be shared openly or even shared at all.
Any restrictions on data sharing should be reflected in the data management and sharing plan. NIH has given the following as examples of why data may not be shared. Informed consent will not permit or will limit the scope or extent of sharing and future research use.
How does the DMS policy affect other data-related policies at NIH?
The DMS policy provides a foundation for which individual institutes, centers, and calls for proposals can develop more specific policies.
In general, the DMS policy is complementary to other data-related policies at NIH. For example, researchers doing work covered by the Genomic Data Sharing Policy do not have to complete parallel GDSPs and DMSPs. Instead, the material previously covered by the GDSP will not be included in the DMSP.
What about data policies at different funders?
As of now, the DMS policy applies to only research funded by NIH. However, as outlined in a memo in August 2022 from the Office of Science and Technology Policy (OSTP), other federal agencies will be proposing and adopting policies and requirements related to the sharing of the products of federally funded research (e.g. peer-reviewed articles, datasets) in the coming years.
Do I need to write broad or unrestricted data sharing into informed consent documentation?
Not necessarily. The DMS policy encourages researchers to plan for how data management and sharing will be reflected in informed consent documents but does not expect that informed consent given by participants will be obtained in any particular way. NIH is currently developing resources to assist in drafting consent language for the sharing of research participants’ data.
What happens in the case of a no-cost extension?
In the case of a no-cost extension, data management and sharing-related requirements are extended to the end of the extended performance period.