DMS Policy Guidance
New NIH Data Management and Sharing Policy Guidance
The new NIH DMS policy will apply to all research grant proposals (and the resulting funded projects) submitted starting January 25, 2023. Existing NIH grants (as of late 2022) will not require DMS plans or compliance with the new policy until they come up for competitive renewal on or after January 25. Then DMS plans will need to be included in both new and competitive renewal proposals and complied with if the proposal after funded. This policy applies only to research grants, not training, fellowships, infrastructure, or instrument grants.
The policy dictates how data generated using support from these grants must be managed and shared. “Data” is defined in the new policy 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.” The NIH definition excludes “data not necessary (or of sufficient quality) to validate and replicate research findings,” laboratory notebooks, preliminary analyses, and physical objects.
The critical points of this policy that are likely to impact scientists working in the School of Medicine Basic Sciences are:
- All new and competing grant proposals must include a plan based on the NIH DMS form template. You can access the current version here.
- Compliance with the plan will need to be reported by the PI in the annual required progress reports to NIH (RPPRs).
- PIs must deposit all data and associated metadata into a paper and/or one or more publicly accessible repositories that comply with the “F.A.I.R.” principle (findable, accessible, interoperable, and reusable). NIH provides examples of repositories on its website.
- At the end of a grant cycle (two to five years for most NIH research grants), the PI must deposit all unpublished scientific data generated during that cycle in a publicly-accessible repository.
- Revising an existing DMS plan during competitive renewal or mid-way through an active award is possible.
- You can request funds to cover the cost of executing your DMS plan in your grant application. Your budget may cover the costs of curating data, developing supporting documentation, handling metadata, formatting for a repository, and preserving/sharing data through repositories.
You can find additional information regarding DMS policies on the NIH DMS website, including special guidance regarding handling clinical and proprietary research data.
VBS DMS Policy Guidance Webinar

Other Resources
Vanderbilt Office of Research Integrity and Compliance – recommendations for the new NIH Data Management and Sharing Policy
DMPTool – A free, open-source, online resource to help create data management plans.
NIH Sample Data Management Plans – Example DMPs including clinical, human, and non-human genetics and secondary use plans.
Data Management and Sharing Plan Checklist for Researchers – The NIH DMSP Guidance Working Group created a checklist to help researchers with the six required elements in the NIH policy.
NIH-supported Scientific Data Repositories – A NIH-provided list of repositories and guidance on selecting a data repository.
NIH Allowable Costs for Data Management and Sharing – Details on the types of data-related budgeting you can include in the budget justification of grant applications.
NNLM Research Data Management On-Demand Classes – Learn research data management in classes you can take at your own pace. Explore open science, data curation and documentation, data sharing and publishing, and more.
NIH DMS Plan and Policy Data Terms – A Guide created by the NIH DMSP Guidance Working Group to the terminology used in the NIH DMSP.
Creative Data Solutions (CDS) – CDS, a Vanderbilt Shared Resource Core, can assist with data annotation, structured and unstructured data deposition, open source code, FAIR, and more.
BioVU NIH Repository Data Sharing Guide – A guide with instructions and sample language to include in Data Management in Sharing plans.