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NIH Public Access Policy

Information and resources to help researchers comply with the NIH Public Access Policy.

Overview

Final NIH Policy for Data Management and Sharing Released October 29, 2020; Effective January 25, 2023
NOT-OD-21-013

Previously, the NIH only required grants with $500,000 per year or more in direct costs to provide a brief explanation of how and when data resulting from the grant would be shared.

In NIH's view, all data should be considered for data sharing. Data should be made as widely and freely available as possible while safeguarding the privacy of participants, and protecting confidential and proprietary data.

The 2023 policy is entirely new. Beginning in 2023, ALL grant applications or renewals that generate Scientific Data must now include a detailed plan for how you will manage and share data during the entire funded period. This includes information on data storage, access policies/procedures, preservation, metadata standards, distribution approaches.

The term Scientific Data is defined in the policy 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."

You must provide this information in a data management and sharing plan (DMSP).

The Data Sharing Plan follows the Research Plan Section and does not count toward the page limit.

The DMSP will be assessed by NIH Program Staff (though peer reviewers will be able to comment on the proposed data management budget). The Institute, Center, or Office (ICO)-approved plan becomes a Term and Condition of the Notice of Award.

See NIH's Data Sharing and/or our NIH Public Access Library Guide pages for full details.

First steps

  1. Determine your personal timeline. If you have an active NIH award going up for renewal with receipt date of January 2023, or if you are planning to submit an NIH proposal this year, then developing a DMSP should be a high priority, especially if you are working with external collaborators as it may take time to set up appropriate data procedures/agreements. 

  2. Read through this webpage to familiarize yourself with the changes and with the policy itself (including the supplements)

  3. Familiarize yourself with the FAIR principles (Wilkinson et. al, 2016). The FAIR (findable, accessible, interoperable, reusable) data principles are the guiding principles the NIH has used in creating the new policy. 

  4. Assess your own project and data management practices relative to the policy (see the NIH-provided supplements below), especially around documenting existing practices and developing new ones to address the increased emphasis on data sharing and administrative oversight.

  5. Review campus data services (e.g., computing, storage, consulting) and assess whether they will meet your needs. Also consider costs you may need to budget for such as labor for data cleaning and documentation (see the NIH-provided supplement on allowable costs).

Media Requirements

While not part of the Public Access Policy, note that NIH also requires grant acknowledement in the media (e.g., press releases, web stories, blog posts).

Grantees are required to include the following:

  • A reference to the National Institutes of Health
  • The name of the funding institute (e.g., National Cancer Institute)

Campus Resources

Questions about applicability to a grant-funded project? Contact your OSPA pre-award or post-award staff or call 882-7560.