Overview of the New DMS Policy
Starting January 25, 2023 NIH will require all researchers seeking grant funds that result in the generation of scientific data to:
- Submit a Data Management and Sharing plan outlining how scientific data and any accompanying metadata will be managed and shared, taking into account any potential restrictions or limitations.
- Comply with the Data Management and Sharing plan approved by the funding Institute or Center (IC).
The requirement emphasizes the importance of good data management practices and establishes the expectation for maximizing the appropriate sharing of scientific data generated from NIH-funded or conducted research, with justified limitations or exceptions. Once a grant has been awarded, the Plan becomes part of the award's terms and conditions and compliance may be reviewed during regular reporting intervals. Note that this policy represents the minimum requirements, individual NIH Institutes and Centers may have more specific requirements.
FAQs about the new DMS Policy
The final NIH 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.” Even those scientific data not used to support a publication are considered scientific data and within the final DMS Policy’s scope.
In these max two-page documents, researchers will describe their:
- Data type
- Related tools, software, and/or code
- Data preservation, access, and associated timelines
- Access, distribution, or reuse considerations
- Oversight of data management and sharing
No. NIH prefers that scientific data be shared and preserved through repositories rather than kept by a researcher and provided upon request.
NIH program staff will assess the DMS plans but peer reviewers may comment on the proposed budget for data management and sharing.
NIH encourages the use of established repositories. To select a repository relevant to your data consider:
- Is there a specific NIH repository named in the funding announcement?
- Is there a data repository specific to your discipline?
- If not, is there a general data repository you can use?
- For UCSF researchers, consider Dryad data repository
A standard specifies how exactly data and related materials should be stored, organized, and described. In the context of research data, the term typically refers to the use of specific and well-defined formats, schemas, vocabularies, and ontologies in the description and organization of data. However, for researchers within a community where more formal standards have not been well established, it can also be interpreted more broadly to refer to the adoption of the same (or similar) data management-related activities, conventions, or strategies by different researchers and across different projects.
Learn more about standards on this guide from the UCSF Library.
NIH encourages scientific data be shared as soon as possible, and no later than time of an associated publication or end of the performance period, whichever comes first.
Allowable costs can include:
- data curation and developing documentation (formatting data, de-identifying data, preparing metadata, curating data for a data repository)
- data management considerations (unique and specialized information infrastructure necessary to provide local management and preservation before depositing in a repository)
- preserving data in data repositories (data deposit fees)
NIH Program Staff will be monitoring compliance with the policy during the funding period. “Noncompliance with Plans may result in the NIH ICO adding special Terms and Conditions of Award or terminating the award. If award recipients are not compliant with Plans at the end of the award, noncompliance may be factored into future funding decisions.”
UCSF researchers should follow the guidance for sharing de-identified data to incorporate data sharing into their research process.
NIH strongly encourages researchers who work with sensitive topics and/or populations to address data sharing in the Informed Consent process. UCSF consent form templates include appropriate sample language.
Researchers should pay special attention to their de-identification process to ensure that all identifying information has been fully removed. CTSI’s data de-identification service can provide advice on de-identification and connect you with third party de-identification validation services.
Finally, researchers should consider depositing their data in restricted access repositories that require data use agreements and research plans in order to access the data.
While sharing data can lead to scooping, this is very rare. If you are worried about scooping you may want to hold off publishing your data until your associated publication is ready to be published. Some repositories also have a "private for peer review" option which allows you to make your data available to peer reviewers but not fully publish your data until the article has been accepted.
- NIH DMS Policy Homepage
- NIH Institutes and Centers Data Sharing Policies
- NIH DMS Template language from DMPTool
- De-identified data sharing guidance from UCSF
- UCSF Library guide to data management
How to get help
Questions about the new policy or need help selecting an appropriate data repository or metadata standard? Want someone to present on the policy to your team or department? Contact the UCSF Library's data management team.