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As of January 25, 2023, the new Data Management and Sharing Policy announced by the National Institutes of Health (NIH) will be in effect, replacing the 2003 NIH Data Sharing Policy. The 2023 Data Management and Sharing Policy requires all grant applications and proposals to include a data management and sharing (DMS) plan describing how scientific data generated or used in funded research will be managed and shared. Acknowledging costs associated with data management and sharing activities, the new DMS policy also establishes guidelines for including these costs in funding applications.

The DMS plan is a formal document that describes the scientific data to be generated or used in research projects and outlines specific provisions for ensuring that the data are FAIR: findable, accessible, interoperable, and reusable. Importantly, FAIR data are data that are stored properly as they are being generated and analyzed, accompanied by comprehensive documentation to support understandability, and archived in a trustworthy repository for sharing and long-term preservation. The DMS plan should reflect this standard.

The NIH DMS policy underscores the value of scientific data and the critical role of data management and sharing to sustain and maximize this value. Proper data management and sharing enables the scientific community to verify, extend, and build upon research results. The policy also presents an important opportunity for investigators to adopt data management and sharing activities as part of normative research practices, which is key to upholding scientific rigor and integrity, accelerating the pace of research discoveries, and promoting public trust in science.


2023 NIH Data Management and Sharing Policy Overview

NIH grant submission requirements:

  • Applications for all new and competing proposals/renewals with receipt dates on or after January 25, 2023 must include a plan and budget for data management and sharing.
  • Individual investigators will be held responsible for implementing DMS plans as a term and condition of award. Non-compliance will result in penalties for both investigators and UNC.
  • NIH program staff will review and approve the DMS plan and may request changes prior to award.
  • NIH grant application peer reviewers will not review the DMS plan itself, but they will take into consideration any budget items related to DMS activities.
  • Applications submitted to programs with deadlines PRIOR to January 25, 2023, are NOT required to include a DMS plan, though it is encouraged.

Post-award requirements:

  • As a term and condition of award, investigators will be responsible for data management and sharing as described in the approved DMS plan.
  • Progress reports submitted to NIH must include updates on data management and sharing activities.
  • Should the approved DMS plan require any modifications over the course of the award period, investigators will be expected to work with the program officer to review and approve those changes.
  • Failure to execute the approved DMS plan may affect continuation of the current project and/or future NIH funding.

Policy Links

Get Help with the New Data Sharing Requirements

We know that this is a big change, and we are here to help. Please contact us with questions or to set up a consultation for your data management and sharing plan.
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