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NIH Data Management Plans: The New Requirements and What It May Cost You


The National Institutes of Health (NIH) has significantly expanded its Data Management and Sharing (DMS) policy to “promote the management and sharing of scientific data generated from NIH-funded or conducted research.” Historically, data management plans were required in limited circumstances such as proposals requesting $500,000 or more in direct costs in any year or the generation of large-scale genomic data. A DMS plan will now be required for all applications submitted in response to deadlines of January 25, 2023 and later. Principal Investigators are expected to budget for costs needed to implement the plan, follow the proposed plan and report on the progress.


It is important to consider the costs associated with both managing and sharing data and NIH encourages budgeting appropriately for costs associated with these activities. While data is required to be kept for three years after the end of the award, all costs must be incurred during the project period. Costs in support of the following activities are generally considered allowable:

  • Curating data
  • Developing supporting documentation
  • Formatting data
  • De-identifying data
  • Preparing metadata to foster discoverability, interpretation and reuse
  • Data deposit fees for using established repositories

All costs must be labeled as “Data Management and Sharing Costs” in the budget and on the budget justification.

Components of a Successful DMS Plan

Plans should be two pages or less and address the following:

Data Type

  • Summarize the types and amount of data to be generated and/or used in the research
  • Describe which data from the project will be preserved and shared
  • Brief listing of metadata, other relevant data and associated documentation that will be made accessible to facilitate the interpretation of the data

Related Tools, Software and/or Code

Indicate whether specialized tools are needed to access or manipulate data to support replication or reuse.


Describe what standards, if any, will be applied to the data and associated metadata (i.e., formats, dictionaries, identifiers, definitions, etc.)

Data Preservation, Access, and Associated Timelines

  • The name of the repository(ies) where data arising from the project will be archived
  • How the data will be findable and identifiable
  • When data will be made available and for how long

Access, Distribution, or Reuse Considerations

Describe any factors affecting access, distribution, or reuse related to:

  • Informed consent
  • Privacy and confidentiality protections
  • Whether access to data derived from humans will be controlled
  • Any restrictions imposed by federal, Tribal, or state laws, regulations, or policies, or existing or anticipated agreements
  • Any other considerations that may limit the extent of data sharing

Oversight of Data Management and Sharing

Indicate how compliance with the DMS plan will be monitored and managed.

DMS Plan Assessment

While not a factor during peer review (unless integral to the project design and specified in the solicitation), applications will only be funded if the DMS plan is complete and acceptable. Further, NIH Program Officers and/or Grants Management Specialists may require adjustments or additional information at Just-In-Time (JIT).

The NIH has a wealth of resources which I strongly encourage reviewing in advance of proposal preparation.

Please join me on November 17 at 12:00pm to discuss this topic further, I would love to hear from you!

Register in advance for the Zoom session here. You may also submit your question(s) and/or comment(s) in advance of the session.  


Letter from Laura

Laura Kozma
Associate Vice President, Research Administration
Lunch with Laura Overview 

Lunch with Laura is a monthly newsletter and discussion session with me (Laura Kozma, Associate Vice President for Research Administration) on a specific topic. There will be new focus each month which will include hot topics in research administration, new and significant policies, and changes in the Office of Research Administration (ORA).


The newsletter will be distributed to the University of Miami (UM) communicated and will also be available online. Each newsletter will briefly discuss key points about the monthly focus including available resources.

Lunch with Laura

The discussion session (or Lunch with Laura) will be held shortly after the newsletter is sent out. All are welcome to come and discuss the monthly focus and ask questions. I look forward to having an opportunity to discuss your concerns and questions in depth. My goal is to make this an opportunity for you and one for me as well so I can better understand your struggles and challenges. You may submit your questions or comments in advance of the session.