National Institute of
Data Management and Sharing Plan Expectations for NIGMS Grantees
Effective January 25, 2023, NIH implemented a new policy to promote the sharing of scientific data. Sharing scientific data accelerates biomedical research discovery, in part, by enabling validation of research results, providing accessibility to high-value datasets, and promoting data reuse for future research studies.
NIGMS believes that, in general, most of its grantees are already meeting the NIH policy requirements and submitting a Data Management and Sharing plan with a grant application will formalize what PIs already do and make explicit the expectations of their scientific community for sharing of data. Most plans are expected to be concise (no more than 2 pages) and in many cases, they could be much shorter.
NIH has updated the Data Management and Sharing (DMS) plan policy (NOT-OD-26-046). Effective for applications submitted for due dates on or after May 25, 2026, applicants are required to use a new, simpler format for the DMS plan (example plan). Additional information is available on the grants.gov website.
NIGMS Data Management and Sharing Plan FAQs
What will my lab have to do differently in order to comply with the Data Management and Sharing (DMS) Policy?
Applicants will be required to submit a short DMS plan that describes how their lab will manage and share scientific data. We expect that most NIGMS grantees will not have to change their data management and sharing practices significantly from what they have already been doing. For example, most biomedical research publishers have had data sharing requirements in place for some time and applicants are already complying with them.
What are NIGMS' expectations for data sharing?
In general, NIGMS expects that its grantees will make data underlying peer-reviewed publications findable and accessible (within the legal constraints of human subjects data privacy and consent). In some cases, grantees might generate valuable, high-quality data that will not be published in a timely manner or at all, and in such instances these data sets should also be made findable and accessible. Expectations for the sharing of proprietary data may depend on the funding mechanism or source. You should discuss issues with the sharing of proprietary data with a Program Officer, or in the case of an SBIR/STTR application, the NIH SEED Office.
Where should I put my data?
In general, the repositories grantees are already using, e.g., to comply with journal data sharing policies, will also be appropriate for complying with the NIH DMS policy. In addition, NIH maintains a list of some possible repositories that may be useful. This list is not exhaustive and applicants should also consult NIH’s guidelines for selecting a data repository.
How much extra will it cost to comply with the DMS policy? Where will the funds come from?
We expect that most NIGMS grantees will not have to significantly change their data management and sharing practices and thus incur additional costs, if any, will be modest. If you feel that complying with NIGMS' expectations for meeting the DMS policy will require significant additional expenditures, you may request these funds in your grant application and explain the need in the Budget Justification section. However, we advise you to discuss your plan with your program officer prior to submitting your application to ensure that you understand the Institute's expectations.
To aid applicants and grantees in navigating the changes to the policy, NIGMS has developed case examples of acceptable plans for different types of applications below.
Plan for due dates on or before May 24, 2026
Data used in publications will be deposited directly in PubMed Central and, when available, the publisher's repository as supplementary data at the time of publication. We will deposit any additional data and associated experimental information generated in the published studies in a public database identified in the associated publication (for example Dryad Digital Repository: datadryad.org). Any sequence data will be shared through the SRA data repository or similar repository. Raw sequence data will be findable and identifiable through accession numbers corresponding with the project, study, and experiment. All methods and codes used or created will be discoverable through GitHub or similar repository. There are no restrictions on subsequent access, distribution, or reuse of the scientific data from this project. The PI and institutional official in charge of overseeing compliance will ensure submission of data occurs in a manner compliant with this DMS plan.
Plan for due dates on or after May 25, 2026
- Will there be maximum appropriate sharing of scientific data underlying peer-reviewed publications and other findings resulting from the work supported by this award (including preprints, refereed papers reported at conferences, and other findings)? [YES/NO] YES
- Will the scientific data underlying peer-reviewed publications be shared by the time of publication or, for other findings, by the end of the period of performance, which includes no-cost extensions? [YES/NO] YES
- Will shared scientific data be made available for at least as long as required by applicable data repository policies and/or journal policies? [YES/NO] YES
- If you answered “no” to elements 1, 2, or 3, or if you anticipate that sharing will be limited in some other way, please describe these limitations and the ethical, legal, or technical factors for them (see for example FAQ B.5 and other relevant FAQs). Your response should specify a particular reason(s) for limiting sharing. [300 words maximum]
- If scientific data derived from human research participants will be shared, will privacy, rights, and confidentiality of participants be protected as outlined in NOT-OD-22-213, including whether any scientific data will be shared using access controls? [YES/NO] YES
- In the table below, please list [100 words maximum]:
- Key types of scientific data anticipated to be generated during the project, including the species and modality, if known (e.g., “human genomic data,” “rat functional magnetic resonance imaging data”). NIH recognizes that not all data types expected to be generated in the study will meet the definition of scientific data or can be anticipated in advance. If a data type does not appear on the list; it does not imply that that data type will not be shared if it is generated in the study.
The repository or an example of a repository where the scientific data may be managed and shared, if the scientific data is known at time of application. NIH expects the use of established repositories for preserving and sharing scientific data when they are available.
Expected Data Type Established Repository or Example Methods and code
Data used in publicationsGitHub
PubMed Central; publisher’s repository as suppl. dataAdditional data and Metadata
Sequence DataDryad Digital Repository
SRA data repository
- For studies subject to the NIH Genomic Data Sharing Policy (GDS) (e.g., using NIH funds to generate large-scale human genomic data):
- Will you share all large-scale human genomic and associated data in a NIH-designated repository according to the accelerated timelines expected in the GDS Policy? If “no,” address in element 4. [YES/NO/Not Applicable]. If “no,” address in element 4. YES
- Do you anticipate that when sharing large-scale human genomic data that you will be able to meet the expectations of the Institutional Certification in the GDS Policy (https://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-124.html; IV.C.5)? [YES/NO/Not Applicable] If “no,” address in element 4. YES
Plan for due dates on or before May 24, 2026
Data used in publications produced by pilot projects will be deposited directly in PubMed Central and, when available, the publisher's repository as supplementary data at the time of publication. Though we cannot predict the specific types of data that will be generated by pilot projects, each project will deposit data and associated experimental information generated in the published studies in appropriate repositories that may include specific NIH-supported repositories (e.g., GEO), or generalist repositories (e.g., Dryad Digital Repository: datadryad.org) as well as other subject- or disease-specific repositories (e.g., NIDDK Central Repository). The DMS plan will be updated at the time of RPPR if needed. The PI and institutional official in charge of overseeing compliance will ensure submission of data occurs in a manner compliant with this DMS plan.
Plan for due dates on or after May 25, 2026
- Will there be maximum appropriate sharing of scientific data underlying peer-reviewed publications and other findings resulting from the work supported by this award (including preprints, refereed papers reported at conferences, and other findings)? [YES/NO] YES
- Will the scientific data underlying peer-reviewed publications be shared by the time of publication or, for other findings, by the end of the period of performance, which includes no-cost extensions? [YES/NO] YES
- Will shared scientific data be made available for at least as long as required by applicable data repository policies and/or journal policies? [YES/NO] YES
- If you answered “no” to elements 1, 2, or 3, or if you anticipate that sharing will be limited in some other way, please describe these limitations and the ethical, legal, or technical factors for them (see for example FAQ B.5 and other relevant FAQs). Your response should specify a particular reason(s) for limiting sharing. [300 words maximum]
- If scientific data derived from human research participants will be shared, will privacy, rights, and confidentiality of participants be protected as outlined in NOT-OD-22-213, including whether any scientific data will be shared using access controls? [YES/NO] YES
- In the table below, please list [100 words maximum]:
- Key types of scientific data anticipated to be generated during the project, including the species and modality, if known (e.g., “human genomic data,” “rat functional magnetic resonance imaging data”). NIH recognizes that not all data types expected to be generated in the study will meet the definition of scientific data or can be anticipated in advance. If a data type does not appear on the list; it does not imply that that data type will not be shared if it is generated in the study.
The repository or an example of a repository where the scientific data may be managed and shared, if the scientific data is known at time of application. NIH expects the use of established repositories for preserving and sharing scientific data when they are available.
Expected Data Type Established Repository or Example Data used in publications from Pilot Projects
Because data from Pilot Projects is unknown, appropriate repositories will be used.PubMed Central; publisher’s repository as suppl. data
NIH-supported repositories (e.g., GEO)
Generalist repositories (e.g., Dryad Digital Repository)
Subject specific repositories (e.g., NIDDK Central Repository)
Sequence Data repositories (e.g., SRA data repository)
- For studies subject to the NIH Genomic Data Sharing Policy (GDS) (e.g., using NIH funds to generate large-scale human genomic data):
- Will you share all large-scale human genomic and associated data in a NIH-designated repository according to the accelerated timelines expected in the GDS Policy? If “no,” address in element 4. [YES/NO/Not Applicable]. If “no,” address in element 4. YES
- Do you anticipate that when sharing large-scale human genomic data that you will be able to meet the expectations of the Institutional Certification in the GDS Policy (https://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-124.html; IV.C.5)? [YES/NO/Not Applicable] If “no,” address in element 4. YES
Plan for due dates on or before May 24, 2026
Proprietary data generated from this award will not be shared for 20 years. For data that is shareable, we intend to publish data generated in these studies in a peer reviewed journal. If the datasets exceed what can be submitted to the journal and/or PubMed Central, we will store data in Dataverse, or another similar repository. If use of an additional repository becomes necessary, the unique accession number will be referenced in the associated publication. We anticipate data becoming available no later than 12 months after the end of the project period and remaining available indefinitely. We do not foresee a need to restrict access and intend to share all applicable, non-proprietary published data. Oversight and execution of this plan will be managed by the PI.
Plan for due dates on or after May 25, 2026
- Will there be maximum appropriate sharing of scientific data underlying peer-reviewed publications and other findings resulting from the work supported by this award (including preprints, refereed papers reported at conferences, and other findings)? [YES/NO] YES
- Will the scientific data underlying peer-reviewed publications be shared by the time of publication or, for other findings, by the end of the period of performance, which includes no-cost extensions? [YES/NO] YES
- Will shared scientific data be made available for at least as long as required by applicable data repository policies and/or journal policies? [YES/NO] YES
- If you answered “no” to elements 1, 2, or 3, or if you anticipate that sharing will be limited in some other way, please describe these limitations and the ethical, legal, or technical factors for them (see for example FAQ B.5 and other relevant FAQs). Your response should specify a particular reason(s) for limiting sharing. [300 words maximum] Proprietary data generated from this award will not be shared for 20 years.
- If scientific data derived from human research participants will be shared, will privacy, rights, and confidentiality of participants be protected as outlined in NOT-OD-22-213, including whether any scientific data will be shared using access controls? [YES/NO] Not Applicable
- In the table below, please list [100 words maximum]:
- Key types of scientific data anticipated to be generated during the project, including the species and modality, if known (e.g., “human genomic data,” “rat functional magnetic resonance imaging data”). NIH recognizes that not all data types expected to be generated in the study will meet the definition of scientific data or can be anticipated in advance. If a data type does not appear on the list; it does not imply that that data type will not be shared if it is generated in the study.
The repository or an example of a repository where the scientific data may be managed and shared, if the scientific data is known at time of application. NIH expects the use of established repositories for preserving and sharing scientific data when they are available.
Expected Data Type Established Repository or Example Data used in publications from Pilot Projects
Data beyond publication limitsPubMed Central; publisher’s repository as suppl. data
Dataverse
- For studies subject to the NIH Genomic Data Sharing Policy (GDS) (e.g., using NIH funds to generate large-scale human genomic data):
- Will you share all large-scale human genomic and associated data in a NIH-designated repository according to the accelerated timelines expected in the GDS Policy? If “no,” address in element 4. [YES/NO/Not Applicable]. If “no,” address in element 4. Not Applicable
- Do you anticipate that when sharing large-scale human genomic data that you will be able to meet the expectations of the Institutional Certification in the GDS Policy (https://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-124.html; IV.C.5)? [YES/NO/Not Applicable] If “no,” address in element 4. Not Applicable
Plan for due dates on or before May 24, 2026
Data used in publications will be deposited directly in PubMed Central and, when available, the publisher’s repository as supplementary data at the time of publication.
- Additional data and associated experimental information generated in the published studies will be deposited in a public database identified in the associated publication (for example Dryad Digital Repository: datadryad.org).
Clinical data/clinical trial data will be shared for general research use, as allowed by the participant's informed consents and our Institutional Review Board (IRB) requirements.
- Informed consent documents used for the proposed clinical research will include explicit language informing the participant or legally authorized representative of broad data sharing under controlled access with general research use restrictions.
- Privacy and confidentiality protections consistent with applicable federal, tribal, state, and local laws, regulations, and policies will be followed.
- Data will be deidentified by removing all HIPAA identifiers prior to sharing, and the study will be covered by a Certificate of Confidentiality from the NIH.
- Certain data or materials with privacy implications may be transferred to other researchers as limited by the informed consent document, and institutional IRB policies.
- Clinical data/clinical trial data will conform to industry standard formats to enable further analyses of this study.
- Additional metadata, protocols, and code will be included at the time of data release in an appropriate repository.
- For studies including a clinical trial, NIH clinical trials policies regarding clinical trial registration, results reporting, and informed consent posting will be followed.
The PI and institutional official in charge of overseeing compliance will ensure submission of data occurs in a manner compliant with this DMS plan.
Additionally - for studies with Clinical Trials
- Recruitment progress and final results will be documented at clinicaltrials.gov.
- One IRB-approved version of a blank consent form used to enroll participants will be posted on a public federal website designated for this purpose (clinicaltrials.gov or regulations.gov) after recruitment closes.
- Protocols, informed consent forms to participate in the trial and for biological sample collection, data dictionary, and code book will be shared with the data through the repositories.
- After the study is complete and unblinded, the study team will submit all remaining scientific data to the appropriate data repositories and will update the RCT status to "complete" in clinicaltrials.gov.
- According to the proposed project timeline, the release of the remaining scientific data will approximately coincide with the submission of final results to clinicaltrials.gov, as mandated by NIH Policy on the Dissemination of NIH-Funded Clinical Trial Information and will occur by the end of award or publication, whichever comes sooner.
Plan for due dates on or after May 25, 2026
- Will there be maximum appropriate sharing of scientific data underlying peer-reviewed publications and other findings resulting from the work supported by this award (including preprints, refereed papers reported at conferences, and other findings)? [YES/NO] YES
- Will the scientific data underlying peer-reviewed publications be shared by the time of publication or, for other findings, by the end of the period of performance, which includes no-cost extensions? [YES/NO] YES
- Will shared scientific data be made available for at least as long as required by applicable data repository policies and/or journal policies? [YES/NO] YES
- If you answered “no” to elements 1, 2, or 3, or if you anticipate that sharing will be limited in some other way, please describe these limitations and the ethical, legal, or technical factors for them (see for example FAQ B.5 and other relevant FAQs). Your response should specify a particular reason(s) for limiting sharing. [300 words maximum]
- If scientific data derived from human research participants will be shared, will privacy, rights, and confidentiality of participants be protected as outlined in NOT-OD-22-213, including whether any scientific data will be shared using access controls? [YES/NO] YES
- In the table below, please list [100 words maximum]:
- Key types of scientific data anticipated to be generated during the project, including the species and modality, if known (e.g., “human genomic data,” “rat functional magnetic resonance imaging data”). NIH recognizes that not all data types expected to be generated in the study will meet the definition of scientific data or can be anticipated in advance. If a data type does not appear on the list; it does not imply that that data type will not be shared if it is generated in the study.
The repository or an example of a repository where the scientific data may be managed and shared, if the scientific data is known at time of application. NIH expects the use of established repositories for preserving and sharing scientific data when they are available.
Expected Data Type Established Repository or Example Data used in publications
Additional data and associated experimental information generated in the published studiesPubMed Central; publisher’s repository as suppl. data
Generalist repositories (e.g., Dryad Digital Repository)
- For studies subject to the NIH Genomic Data Sharing Policy (GDS) (e.g., using NIH funds to generate large-scale human genomic data):
- Will you share all large-scale human genomic and associated data in a NIH-designated repository according to the accelerated timelines expected in the GDS Policy? If “no,” address in element 4. [YES/NO/Not Applicable]. If “no,” address in element 4. Not Applicable
- Do you anticipate that when sharing large-scale human genomic data that you will be able to meet the expectations of the Institutional Certification in the GDS Policy (https://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-124.html; IV.C.5)? [YES/NO/Not Applicable] If “no,” address in element 4. Not Applicable