By Shannon Farrell, Alicia Hofelich Mohr, Shanda Hunt

A new policy from the National Institutes of Health (NIH) that takes effect Jan. 25, 2023 will require investigators to submit a data management plan. The policy will apply to all research funded in whole or in part by NIH that results in the generation of scientific data. 

The Data Management and Sharing (DMS) Policy is intended to advance the NIH’s long-standing prioritization of providing public access to NIH funded research.

What you need to know

Under the DMS Policy, NIH requires investigators to prospectively plan for how scientific data will be managed and shared through submission of a Data Management and Sharing Plan.

After Jan. 25, 2023, investigators are required to:

• Submit a Data Management and Sharing Plan outlining how scientific data and any accompanying metadata will be managed and shared, taking into account any potential restrictions or limitations.
• Comply with the Data Management and Sharing Plan approved by the NIH funding Institute, Center, or Office.

Compliance requirements and impact of noncompliance

Compliance with the DMS Policy is mandatory and progress towards DMS Plans are required in quarterly reports.

Failure to comply may result in an enforcement action, including additional special terms and conditions or termination of the award, and may affect future funding decisions.

Elements of a Data Management and Sharing Plan

Data Management and Sharing plans will be required as part of grant proposals.  They will be assessed as part of the grant review process and must include the following details:

• Description of the data plus metadata and documentation.
• Related tools, software, code
• Standards for the data/metadata.
• Data preservation, access, and associated timelines,
• Access, distribution, and reuse considerations.
• Oversight of data management and sharing.

Get started with Libraries’ expertise

The Libraries has a well-established and long-standing Research Data Services team, which assists researchers in complying with Federal data management and sharing policies similar to the NIH DMS Policy, such as those required by the National Science Foundation.

In keeping with their portfolio and subject expertise, the Research Data Services team is prepared to advance initiatives to support compliance with the NIH DMS Policy at the University of Minnesota by providing:

• review of data management plans and data management and sharing plans;
• training around data management and sharing (i.e., research teams, courses, large events);
• consultation around data sharing practices, such as developing consent forms and IRB protocols that align with sharing, selecting an appropriate repository, and curating data for repository submission; and
• templates for creating data management and sharing plans, participant handouts about data sharing, and readme files.

To request training or support for departments or units, contact the Research Data Services team at data@umn.edu.

Other compliance support

The NIH has a website dedicated to tools and resources to help researchers comply with the new policy.

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About the authors

Shannon Farrell, M.S., MLIS is the Natural Resources Librarian at the University of Minnesota Twin Cities. She leads the Libraries’ Research Data Services Team. Her work involves instructing students, faculty and staff on best practices with regards to data management, writing data management plans, and sharing data. She is a curator of scientific data for the Data Repository for the University of Minnesota (DRUM).

Alicia Hofelich Mohr, Ph.D., is the Research Support Coordinator in the Liberal Arts Technologies and Innovation Services (LATIS) at the University of Minnesota Twin Cities. She works with researchers on writing data management plans, designing reproducible research workflows, handling human participant data, and ethically sharing data. She has received training in De-Identification Methodology from the Health Information Trust Alliance (HITRUST) and Data Management & Curation from the Inter-University Consortium for Political and Social Research (ICPSR). She serves as a curator for social science data and statistical code in the Data Repository for the University of Minnesota (DRUM) and is a member of the Libraries’ Research Data Services Team.

Shanda Hunt, M.P.H., is the Public Health Librarian at the University of Minnesota Twin Cities. She is also the health sciences curator and one of two human participant curators for the Data Repository for the University of Minnesota (DRUM) and a member of the Libraries’ Research Data Services Team. She works closely with researchers on best practices for consenting participants for sharing data, data management plans, data curation, and repository selection. She also does campus-wide education around data management and data sharing ethics.