National Institutes of Health: Proposal Requirement Changes

The National Institutes of Health (NIH) will implement a new Data Management and Sharing (DMS) Policy for all applications submitted for due dates on or after January 25, 2023:

Data Management and Sharing Policy

NIH values the sharing of scientific data because it accelerates and enhances biomedical research and ultimately helps improve human health. Under the 2023 Data Management & Sharing Policy, NIH “requires researchers to prospectively plan for how scientific data will be preserved and shared through submission of a data management plan”. The policy “applies to all research, funded or conducted in whole or in part by NIH, that results in the generation of scientific data”, which is defined by NIH as “data 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.”

Proposal requirements will change in two ways:

1. Data Management and Sharing Plan

Proposals for research that generates scientific data must include a DMS plan. The DMS plan is limited to two (2) pages and should include the following elements:

  • Data Type
  • Related Tools, Software and/or Code
  • Standards
  • Data Preservation, Access, and Associated Timelines
  • Access, Distribution, or Reuse Considerations
  • Oversight of Data Management and Sharing

The DMS plan will be attached to a new field on the PHS 398 Research Plan form.

See https://sharing.nih.gov/data-management-and-sharing-policy/planning-and-budgeting-DMS/writing-a-data-management-and-sharing-plan for more information.

2. Data Management and Sharing Costs

Under the 2023 DMS policy, NIH will allow for budgeting of some data management and sharing costs, as long as they are incurred during the performance period.

Allowable costs include:

  • Curating data/developing supporting documentation
  • Preserving/sharing data through repositories, including data deposit fees
  • Local data management considerations

Unallowable costs include:

  • Infrastructure costs typically included in indirect costs
  • Costs associated with the routine conduct of research (e.g., costs of gaining access to research data)
  • Costs incurred outside of the project period

In detailed budgets, data management and sharing costs will be included on a separate line on the R&R Budget Form in section F. Other Direct Costs and must be described in the budget justification.

In modular budgets, data management and sharing costs must be described in the Additional Narrative Justification document.

See https://sharing.nih.gov/data-management-and-sharing-policy/planning-and-budgeting-DMS/budgeting-for-data-management-sharing for more information.

Compliance

The submitted DMS plan will become part of the Terms and Conditions of an award, should the proposal be funded. Compliance with the DMS plan will be determined by the awarding NIH Institute or Center. Failure to comply may result in an enforcement action, which may include additional terms and conditions or termination of an award. It may also affect future funding decisions.

Resources

NIH Data Management and Sharing Policy website

2022 NIH Data Management and Sharing Policy Webinar Series:

Part 1: Understanding the New NIH Data Management and Sharing Policy (08/11/2022; recording available)

Part 2: Diving Deeper into the New NIH Data Management and Sharing Policy (09/22/2022)

NIH DMS Frequently Asked Questions (FAQs)

Kent State University Libraries Data Management Resource Page

Data Management Plan (DMP) Tool