NIH Data Management & Sharing

NIH Data Management & Sharing

The NIH recently released implementation details for their Data Management and Sharing Policy that will go into effect for proposals submitted on or after January 25, 2023.

The policy applies to NIH-funded projects that will generate scientific data, which excludes training grants, fellowships, construction, infrastructure, and non-research activities. SBIR/STTR grants are subject to the NIH policy.


In summary, a Data Management and Sharing Plan (DMSP) will be required in grant proposals and uploaded separately as follows:

  • PHS 398 Research Plan under the new field titled, “11. Other Plan(s).”
  • PHS 398 Career Development Award Supplemental Form under the new field titled, “17. Other Plan(s).”

A draft plan is available here and NIH guidance is available to for writing the DMSP.

UTSA’s Research Data Services Coordinator, Matt Hayward, is available for direct assistance. More information is available at the Research Data Management Library Guide that includes a toolkit for the DMP tool, storage, preservation, sharing, and more.

Allowable Costs

NIH allows you to budget for data management, curation, and sharing for the period of performance. More information is available here.

Data Sharing

Researchers have some discretion in how to share their data, depending on the instructions provided by the NIH Center or Institute and the Funding Opportunity Announcement. NIH provides details about data repository options here, including NIH Repositories, Generalist Repositories, Nature’s Repository Guidance, and a full Registry of Repositories. UTSA is part of the UT System Research Cyberinfrastructure (UTRC) and this is another option for you. The UTRC Getting Started Guide provides details about access and usage.

Privacy for Human Research Participants

NIH has shared excellent guidance here. Notable sections of this guidance include, “Operational Principles for Protecting Participant Privacy When Sharing Scientific Data” and “Best Practices for Protecting Participant Privacy When Sharing Scientific Data.” This guidance is also helpful for you to decide whether or not to control access to shared datasets.

DMSP updates will also be part of the annual RPPR. Compliance with this element will affect grant proposal eligibility and can affect future funding for PIs and institutions.


What Scientific Data Will be Shared?  

Scientific data necessary for or of sufficient quality to validate and replicate research findings will be made publicly available. This would include, for example, single-cell RNA sequencing, step activity from a wearable device, or electrophysiological recordings and fMRI images. Scientific data that will be publicly available does not include lab notebooks, drafts, preliminary analyses, and physical objects.

What Factors Might Limit Data Sharing?  
Why Has NIH Implemented this Policy?  
What Elements Should I Include in My DMSP?  
When and For How Long Will I Share My Data?  
Where Do I Budget Allowable Costs to Support Data Management and Sharing?  
How Does NIH Review the DMSP in My Grant Proposal?  
Citing My Data