Research Data Management: New 2023 NIH Data Sharing Policy

Request a consultation  for NIH data policy and data management-related questions, or email Data Curation Librarian Wasila Dahdul (wdahdul@uci.edu) for assistance. A template with guidance and sample language is also available to help researchers write NIH-compliant plans (see Box to right)

NIH strongly encourages researchers who work with sensitive topics and/or populations to address data sharing in the Informed Consent process. Researchers should also pay special attention to their de-identification process to ensure that all identifying information has been fully removed. Finally, researchers should consider depositing their data in restricted access repositories that require data use agreements and research plans in order to access the data.

While sharing data can lead to scooping, this is very rare. If you are worried about scooping you may want to hold off publishing your data until your associated publication is ready to be published. Some repositories have a "private for peer review" option which allows you to make your data available to peer reviewers but not fully publish your data until the article has been accepted.

The final NIH Policy defines Scientific Data as: “The 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. Scientific data do not include laboratory notebooks, preliminary analyses, completed case report forms, drafts of scientific papers, plans for future research, peer reviews, communications with colleagues, or physical objects, such as laboratory specimens.” Even those scientific data not used to support a publication are considered scientific data and within the final DMS Policy’s scope.

No. NIH prefers that scientific data be shared and preserved through repositories rather than kept by a researcher and provided upon request.

NIH program staff will assess the DMS plans but peer reviewers may comment on the proposed budget for data management and sharing.

NIH encourages the use of established repositories. To select a repository relevant to your data consider:

1. Is there a specific NIH repository named in the funding announcement?
2. Is there a data repository specific to your discipline?
3. If not, is there a general data repository you can use? Consider using the Dryad digital repository 

A standard specifies how exactly data and related materials should be stored, organized, and described. In the context of research data, the term typically refers to the use of specific and well-defined formats, schemas, vocabularies, and ontologies in the description and organization of data. However, for researchers within a community where more formal standards have not been well established, it can also be interpreted more broadly to refer to the adoption of the same (or similar) data management-related activities, conventions, or strategies by different researchers and across different projects.

NIH encourages scientific data be shared as soon as possible, and no later than time of an associated publication or end of the performance period, whichever comes first.

Allowable costs can include:

1. data curation and developing documentation (formatting data, de-identifying data, preparing metadata, curating data for a data repository)
2. data management considerations (unique and specialized information infrastructure necessary to provide local management and preservation before depositing in a repository)
3. preserving data in data repositories (data deposit fees)

The NIH has said that NIH Program Staff will be monitoring compliance with the policy during the funding period. “Noncompliance with Plans may result in the NIH ICO adding special Terms and Conditions of Award or terminating the award. If award recipients are not compliant with Plans at the end of the award, noncompliance may be factored into future funding decisions.” See full NIH FAQ for more details