NIH Data Management and Sharing Policy

Policy update: As of October 5, 2023, NIH will no longer require the use of a single DMS cost line-item for costs associated with data management and data sharing (NOT-OD-23-161); instead, NIH will allow DMS costs to be requested in the appropriate cost category (i.e., personnel, equipment, supplies), in line with R&R Budget Form or PHS 398 Modular Budget Form instructions. Learn more here.

Overview of the 2023 NIH Data Management & Sharing (DMS) Policy

NIH’s new data management and sharing policy aims to promote the sharing of scientific data. Sharing scientific data accelerates biomedical research discovery by enabling the validation of research results, providing accessibility to high-value datasets, and promoting data reuse for future research studies. Upon policy implementation, NIH expects the following from investigators and institutions: 

  • To plan and budget for the management and sharing of data
  • To submit a DMS plan (via the new ‘Other Plans’ field on PHS 398 Research Plan and Career Development Award forms) for review when applying for funding
  • To comply with the approved DMS plan

Find more resources below that explore the plan and its impact on NIH-funded research. Additionally, learn how the new NIH policy will complement existing VUMC data policies and procedures.

The Who, What, Where and When of the NIH DMS Policy keychanges


WHEN does the DMS Policy go into effect?

The effective date of the DMS Policy is January 25, 2023, specifically:

  • Competing grant applications that are submitted to NIH for the January 25, 2023 and subsequent receipt dates
  • Proposals for contracts that are submitted to NIH on or after January 25, 2023
  • NIH Intramural Research Projects conducted on or after January 25, 2023
  • Other funding agreements (e.g., Other Transactions) that are executed on or after January 25, 2023, unless otherwise stipulated by NIH.

WHAT does the policy require? 

  • Investigators must develop a Plan for managing and sharing scientific data as part of a funding application or proposal, addressing the 6 recommended elements.
    • For applications also subject to the Genomic Data Sharing (GDS) Policy, DMS Plans should address genomic data sharing considerations.
  • NIH program staff will review the plan for completeness and acceptability and must be approved prior to award
  • Recipients must follow through with the approved Plan and report on progress

WHO needs to comply? 

  • Anyone receiving NIH funds to generate scientific data
    • Scientific Data is defined as “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.”
    • Be sure to check out the complete list of NIH activity codes subject to the DMS Policy as well as the specific Funding Opportunity Announcement to determine if the DMS Policy applies to an application.

WHERE can data be shared?

  • NIH strongly encourages investigators to use an established repository to maximize the sharing of scientific data. Note that some funding opportunities or programs may require the use of a specific repository.
  • Need help identifying an appropriate repository for your data?

NIH Resources

Vanderbilt Resources

Additional Resources & Recommended Reading