NIH applicants routinely confuse two differently-scoped, differently-triggered plan requirements that both live under the “Other Plan(s)” attachment section of an application: the Resource Sharing Plan and the Data Management and Sharing (DMS) Plan. They are not two names for the same thing, they are not interchangeable, and a single award can require both at once. This guide draws the distinction directly.
The short answer
The Resource Sharing Plan is the older requirement. It applies only when a project will generate specific, named categories of unique research resources — genetically modified model organisms, genome-wide association study (GWAS) data, and certain other unique resources — and it addresses how those specific resources will be made available to other investigators. The DMS Plan is the newer, much broader requirement, effective for all NIH grant applications with due dates on or after January 25, 2023 under the 2023 NIH Policy for Data Management and Sharing (NOT-OD-21-013). It applies to essentially all NIH-funded research that generates scientific data, regardless of whether that research produces a “unique resource” in the Resource Sharing Plan sense. A project can trigger a Resource Sharing Plan requirement, a DMS Plan requirement, both, or (rarely, for awards that generate no scientific data at all) neither.
What the Resource Sharing Plan is
The Resource Sharing Plan requirement predates the DMS Policy by roughly two decades and grew out of several separate, topic-specific NIH sharing policies rather than one unified policy document. It is not a single monolithic requirement so much as a family of related sharing-plan obligations that NIH’s application forms consolidated under one attachment label. The main components applicants encounter:
- Sharing of Model Organisms. Under the NIH Policy on Sharing of Model Organisms for Biomedical Research (NOT-OD-04-042), R, P, K, STTR, and SBIR applications expected to produce new, genetically modified model organisms and related resources (mutant strains, embryos, sperm, mutagenesis protocols, and associated genetic/phenotypic data) must include a plan describing how those resources will be distributed to non-profit and for-profit requesters in a timely manner, or must justify why sharing is restricted or not possible.
- Genome-wide association study (GWAS) data sharing. NIH’s original GWAS-specific data-sharing policy (2007) required a sharing plan for genome-wide association data; this was later folded into the broader NIH Genomic Data Sharing (GDS) Policy, effective January 25, 2015, which extended the submission requirement to a wider range of large-scale human and non-human genomic data (GWAS, SNP arrays, whole-genome/exome sequencing, transcriptomic, epigenomic, and metagenomic data), typically deposited to dbGaP or another NIH-designated repository. See CASRAI’s own NIH Genomic Data Sharing (GDS) Policy and dbGaP entries for the mechanics of that submission and access-request process.
- Other unique research resources. NIH’s Grants Policy Statement (and individual funding opportunity announcements) can extend the same “share the unique thing this award will produce” logic to other resource types — cell lines, antibodies, biospecimen collections, software, or other reagents an application identifies as a unique output — on a case-by-case basis, often specified in the FOA rather than in a single standing policy.
The unifying thread is scope: a Resource Sharing Plan is about a specific, discrete output a project is expected to generate, not about the project’s data as a whole. If a study won’t create a new model organism, won’t generate the kinds of large-scale genomic data covered by the GDS Policy, and isn’t flagged by its FOA as producing another named unique resource, there is typically nothing to write for this section (and NIH allows applicants to state that no sharing plan is needed, with a brief statement why).
What the Data Management and Sharing (DMS) Plan is
The DMS Plan comes from a single, unified, comparatively recent policy: the 2023 NIH Policy for Data Management and Sharing, which replaced the narrower 2003 NIH Data Sharing Policy (that older policy applied only to applications with direct costs over $500,000 in any year). The 2023 policy applies to essentially every NIH-funded or -conducted research project that generates scientific data, with no funding-level threshold, for applications due on or after January 25, 2023.
The plan itself must address six elements: data type, related tools/software/code, standards used, data preservation/access/timelines, access/distribution/reuse considerations, and oversight of data management and sharing. NIH recommends keeping it to two pages, and any associated costs are itemized separately in the budget justification. NIH further updated the required format (not the underlying policy) for applications due on or after May 25, 2026, per NOT-OD-26-046: a structured, largely yes/no/not-applicable questionnaire replaces the earlier free-form narrative. For a full worked walkthrough of completing the current DMS Plan, see CASRAI’s NIH Data Management and Sharing Plan Template guide, and for the policy’s requirements, timeline, and compliance mechanics in depth, see NIH Data Management and Sharing (DMS) Policy: Requirements, Timeline, and Compliance.
Resource Sharing Plan vs. DMS Plan: the practical differences
| Dimension | Resource Sharing Plan | DMS Plan |
|---|---|---|
| Governing policy | Multiple topic-specific policies (model organisms, GWAS/GDS, FOA-specific unique resources) | Single unified 2023 Policy for Data Management and Sharing (NOT-OD-21-013) |
| What it covers | A specific unique resource the project will produce (organism, large-scale genomic dataset, or FOA-named resource) | The scientific data generated by the project generally |
| When required | Only when the project will generate one of the specific covered resource types | Essentially all NIH-funded research generating scientific data, for applications due on/after Jan 25, 2023 |
| Application attachment | “Other Plan(s)” attachment, separate PDF from the DMS Plan | “Other Plan(s)” attachment, separate PDF from the Resource Sharing Plan |
| Repository expectation | Resource-specific (e.g., dbGaP for GDS-covered genomic data; a model-organism repository for organisms) | Any repository meeting the desirable characteristics NIH lays out, chosen based on the data type |
| Can apply to the same award? | Yes — a genomics-generating award is routinely subject to both a GDS-based Resource Sharing Plan and a DMS Plan | Yes — same award, different scope for each document |
Can a single award need both?
Yes, and this is the single most common point of confusion. A grant that will generate genome-wide association data, for example, is subject to the Genomic Data Sharing Policy’s Resource Sharing Plan requirement and the DMS Plan requirement — they are not alternatives to each other, and completing one does not satisfy the other. The Resource Sharing Plan addresses the specific expectation that the GWAS dataset itself gets deposited to dbGaP (or another NIH-designated genomic repository) under GDS Policy terms; the DMS Plan addresses the project’s data management and sharing practices more broadly, potentially covering additional data types the GWAS-specific policy doesn’t reach. Applicants sometimes submit one plan and assume it covers both requirements, or merge the two into a single document; NIH’s application instructions treat them as separate attachments, and reviewers and program staff check for both where applicable.
Common points of confusion
- “I already wrote a DMS Plan, so I don’t need a Resource Sharing Plan.” Not necessarily true — if the project produces a model organism or GDS-covered genomic data, the Resource Sharing Plan is still a separate, required attachment.
- “My study doesn’t generate a unique resource, so I don’t need a DMS Plan either.” Also not necessarily true — the DMS Plan’s trigger is generating scientific data at all, a much lower bar than producing a named unique resource. Nearly every funded research project needs a DMS Plan even when it needs no Resource Sharing Plan.
- “These go in the same attachment.” They’re both filed under “Other Plan(s)” in the application, but as separate documents/PDFs, not one combined narrative.
- Genomic data specifically is the area most likely to trigger both plans on the same award — if a project involves GWAS or other large-scale genomic data covered by the GDS Policy, budget for writing both.
Related CASRAI resources
- Research Data Management — the cluster hub for data management planning, sharing policy, and repository selection.
- NIH Data Management and Sharing Plan Template — worked example of a full DMS Plan.
- NIH Data Management and Sharing (DMS) Policy: Requirements, Timeline, and Compliance — the policy in depth.
- NIH vs. NSF Data Management Plans — how the DMS Plan compares to NSF’s separate DMP requirement.
- DMP Review Criteria Used by Funding Agencies.
- NIH Genomic Data Sharing (GDS) Policy and dbGaP — the repository and policy underlying most Resource Sharing Plan obligations for genomic data.
- Data Management Plan (DMP) — the general dictionary definition.
Frequently asked questions
Is the Resource Sharing Plan the same as a Data Sharing Plan?
No. “Data Sharing Plan” is sometimes used loosely to mean either the pre-2023 NIH Data Sharing Policy document (for awards over $500,000/year in direct costs, now superseded by the DMS Policy) or, informally, the DMS Plan itself. The Resource Sharing Plan is a distinct, narrower attachment focused on specific unique resources (model organisms, GDS-covered genomic data, FOA-named resources), not the project’s data generally.
Do all NIH grants require a Resource Sharing Plan?
No. It’s only required when the project will generate one of the specific covered resource types. Many awards — a clinical trial that produces no model organism and no GDS-covered genomic data, for instance — have nothing to report here and can state that no sharing plan applies, with a brief justification.
Do all NIH grants require a DMS Plan?
Nearly all. For applications due on or after January 25, 2023, essentially any NIH-funded project that generates scientific data needs a DMS Plan, regardless of budget size — a much broader trigger than the Resource Sharing Plan’s.
Where do these plans go in the application?
Both are filed under the “Other Plan(s)” attachment section of the NIH application, but as separate PDF documents — not combined into one narrative.
Does a Resource Sharing Plan replace the requirement to deposit data in dbGaP?
No, they work together. The Genomic Data Sharing Policy is what actually requires deposit of GDS-covered genomic data into dbGaP (or another NIH-designated repository); the Resource Sharing Plan is the application-stage document describing that data-sharing intent, consistent with the GDS Policy’s requirements.
