“NIH policies” covers a wide range of distinct instruments – grants administration rules in the NIH Grants Policy Statement, salary limits under the NIH Salary Cap, manuscript deposit rules under the NIH Public Access Policy, and more. This guide covers one specific instrument with the most direct bearing on research data management: the NIH Data Management and Sharing (DMS) Policy (NOT-OD-21-013), which took effect January 25, 2023 and requires a Data Management and Sharing Plan for essentially all NIH-funded research that generates scientific data.
What the DMS Policy requires
The DMS Policy applies to research, funded or conducted in whole or in part by NIH, that results in the generation of scientific data. NIH defines scientific data broadly as the recorded factual material commonly accepted in the scientific community as necessary to validate and replicate research findings, whether or not the data are ultimately included in a publication. The policy applies regardless of funding mechanism – it covers most NIH grants, cooperative agreements, and R&D contracts, including career development (K) awards and, since it is applied at the notice-of-award level, most large research and training mechanisms as well. A small set of exceptions exists, mainly certain training, fellowship, construction, and infrastructure awards that are not expected to generate scientific data as defined by the policy.
The DMS Plan: what it must contain and when
Applicants submit a DMS Plan at the time of application, as an attachment rather than as part of the scored research strategy. NIH’s plan template asks for six elements:
- Data type – what scientific data will be generated and which of it will be preserved and shared.
- Related tools, software, and/or code – whether specialized tools are needed to access or manipulate the shared data.
- Standards – what data and metadata standards will be applied.
- Data preservation, access, and associated timelines – where data will be archived, and when it will become available (NIH expects sharing no later than the associated publication or the end of the performance period, whichever comes first).
- Access, distribution, or reuse considerations – factors affecting subsequent access, such as informed consent constraints or intellectual property.
- Oversight of data management and sharing – how the plan’s execution will be monitored.
Unlike a scored NSF DMP, the DMS Plan is assessed by NIH Institute/Center program staff for feasibility and appropriateness, not scored competitively by peer reviewers as part of the overall impact score – though reviewers may comment on scientific and technical merit-relevant elements (e.g., budgeted resources) as part of the application. Institutes and Centers can request just-in-time submission of the final plan and can consider non-compliance in future funding decisions.
Repository selection
NIH expects data to be deposited in an established data repository, in this priority order: (1) a repository required by the specific NIH Institute, Center, or funding opportunity; (2) a discipline-specific/community repository recognized as a scientific standard; or (3), where neither exists, a generalist repository. NIH points investigators toward repositories that meet the “Desirable Characteristics of Data Repositories for Federally Funded Research”, a May 2022 framework published by the National Science and Technology Council under OSTP – covering unique identifiers, long-term sustainability, metadata, curation, security, and free/low-cost access. See CASRAI’s guide on NIH vs. NSF Data Management Plans for how repository expectations compare across the two agencies, and the Data Repository dictionary entry for the general concept.
Allowable costs
Reasonable, allowable costs of data management and sharing under the policy – curation, formatting, repository deposit fees – may be requested in the budget, generally as a line item rather than buried in indirect costs, provided they are well justified and consistent with the institution’s usual cost-accounting practices.
How the DMS Policy differs from other NIH policies that also touch data or publications
Because so many NIH policies intersect around what a grantee must deposit and when, they are frequently confused with one another:
- NIH Public Access Policy governs deposit of peer-reviewed manuscripts (not underlying data) into PubMed Central, and moved to a zero-embargo requirement for manuscripts accepted on or after July 1, 2025. It is a separate, independent obligation from the DMS Policy – complying with one does not satisfy the other. See the NIH Public Access Policy entry.
- NIH Genomic Data Sharing (GDS) Policy (effective January 25, 2015) requires NIH-funded investigators generating large-scale human or non-human genomic data – GWAS, whole-genome/exome sequencing, transcriptomic, and related data – to submit it to an NIH-designated repository, most often dbGaP. A genomics-generating award is typically subject to both the GDS Policy and the DMS Policy at once; the GDS Policy adds genomics-specific consent and controlled-access requirements the general DMS Policy does not itself impose.
- NIH Rigor and Reproducibility policy addresses how rigor is described and reviewed in an application (e.g., addressing biological variables, authentication of key resources), which is related to, but distinct from, the data-sharing obligations in the DMS Policy.
What the DMS Policy does not decide
The DMS Policy governs planning for and sharing of data; it does not itself adjudicate who owns the underlying research data. That question is left to institutional policy and the specific award’s terms and conditions – typically also shaped by 2 CFR § 200.315 of the OMB Uniform Guidance, which addresses the federal government’s reserved rights in data developed under an award without assigning default ownership to either party. See Data Ownership for how CASRAI frames this distinction.
Making a DMS Plan machine-actionable
A DMS Plan is a static document by default, but the Research Data Alliance’s DMP Common Standard Working Group has developed a structured, machine-actionable format that lets specific commitments – repository, license, timeline – be validated and tracked by systems rather than just filed as prose. Institutions increasingly want this at closeout, to verify plan commitments were actually met rather than only checked for completeness at submission.
Frequently asked questions
Does every NIH grant need a DMS Plan?
Nearly every NIH grant, cooperative agreement, and R&D contract that is expected to generate scientific data needs one, submitted at application. A limited set of award types not expected to generate scientific data – some training, fellowship, and infrastructure mechanisms – are exceptions; check the specific Funding Opportunity Announcement and NIH’s own DMS Policy guidance for the current exception list.
Is the DMS Plan scored by peer reviewers?
No. It is submitted as an attachment and assessed for feasibility and appropriateness by NIH Institute/Center program staff, not scored as part of the overall impact/priority score, though budgeted resources tied to the plan may be commented on.
When must data be shared under the policy?
NIH’s general expectation is that data be made available no later than the time of an associated publication, or by the end of the award’s performance period if never published – the exact timeline should be stated in the plan itself and can vary with the applicable repository’s practices.
How is the DMS Policy different from a data sharing agreement?
The DMS Policy is a funder mandate covering planning and public sharing of data; a data sharing agreement or data use agreement is a separate legal instrument used when data cannot be openly shared and access must instead be controlled and negotiated case by case, commonly for identifiable human-subjects or genomic data.
This guide reflects the DMS Policy as implemented under NOT-OD-21-013, effective January 25, 2023. NIH periodically issues supplemental guidance and FAQ updates through the Office of Extramural Research (OER); verify current requirements against grants.nih.gov before relying on this page for an active application.
