Data Management and Sharing for Grants SOP

This standard operating procedure (SOP) includes the following sections: Purpose, Procedure, Contacts, and Links.

Some links will work for NIAID staff only.

Purpose

To support compliance with the Data Management and Sharing (DMS) Policy and provide guidance for all applicants and grant recipients, where required.

Procedure

The NIH Data Management and Sharing Policy applies to all research, funded or conducted in whole or in part by NIH, that results in the generation of scientific data. Check Research Covered by the 2023 DMS Policy and the full list of NIH Activity Codes Subject to the DMS Policy (PDF) for details.

Under the DMS Policy, NIH expects investigators and institutions to:

  • Prepare a DMS Plan and budget for managing and sharing data
  • Submit a DMS Plan when applying for funding
  • Comply with the approved DMS Plan

Peer reviewers will not have access to or review DMS Plans except for rare circumstances. Additional details are available in the Assessment of Data Management and Sharing Plans.

Applicants and Grant Recipients

  • Before you apply, determine if your application falls under the DMS Policy using resources available on Research Covered by the 2023 DMS Policy.
  • If your application is subject to the Genomic Data Sharing Policy, your DMS Plan should address genomic data considerations.
  • Write a DMS Plan using extensive guidance on the NIH Scientific Data Sharing website:
  • Check the notice of funding opportunity (NOFO), NIH Institute and Center Data Sharing Policies table, and NIAID Data Policy and Guidance page for additional requirements or expectations for your DMS Plan.
  • In your application, include a DMS Plan within the Other Plan(s) field. Only one DMS Plan can be submitted for an application, even when there are multiple components in the application (e.g., P01s).
  • Include a budget request to cover costs associated with the DMS activities using guidance available on Budgeting for Data Management and Sharing.
  • After peer review, your NIAID program officer will assess your DMS Plan and let you know if further information is needed during the just-in-time (JIT) process. If you are asked to submit a revised DMS Plan prior to award, use the “Data Management and Sharing Plan (DMSP) Revision” section of the Just in Time (JIT) Screen in eRA Commons to submit a revised DMS Plan. For more information, refer to the Pre-Award Plan Revisions section in Revising Data Management and Sharing Plans. Note that an unapproved DMS Plan is a bar to funding.
  • After award:
    • NIH expects grant recipients to manage and share data as described in the approved DMS Plan.
    • You may need to revise your DMS Plan over the course of a project if there are changes to how data is managed or shared. If you revise your approved DMS Plan, you will need to get prior approval. Revisions that require prior approval include but are not limited to a new scientific direction, different data repository, or timeline revision. For more information, refer to the Post-Award Plan Revisions section in Revising Data Management and Sharing Plans.
    • Discuss any potential changes with your program officer.
      • Requests for changes that occur within 30 days before or after your Research Performance Progress Report (RPPR) due date must be submitted using the RPPR Module. Use Section C.5.c to select “Upload Revised Data Management and Sharing Plan” and follow the instructions provided to complete the required entry. Recipients cannot submit retroactive requests in the RPPR.
      • Post-award revision requests outside of the RPPR must be submitted through the Prior Approval Module by the Authorized Organization Representative (signing official role in eRA Commons) at least 30 days in advance of a requested change. Recipients select “Prior Approval – DMS Request” in the Prior Approval Module to request the change.
    • NIAID staff will monitor compliance with your DMS Plan during the annual RPPR process.

Scientific Review Officers

  • DMS Plans are generally not reviewed by peer reviewers. Only the budget justification will be visible to peer reviewers. The DMS Plans will be visible in the application and peer reviewed only in highly exceptional situations.
  • Note any comments from peer reviewers related to the DMS budget so program and grants management specialists can request additional information during JIT.
  • Refocus peer reviewers if DMS discussions inappropriately go beyond budget considerations.
  • In the rare situation where the DMS Plan is visible to peer reviewers, remind reviewers to evaluate the DMS Plan according to the specific review criteria.

Program Officers

  • Field questions from applicants related to the DMS Policy and Plan. Escalate as appropriate to Division Data Sharing Points of Contact.
  • After peer review of the application, determine if the DMS Plan is acceptable or unacceptable. For assistance, us the Optional Decision Support Tool.
  • If the DMS Plan is unacceptable, work with the grants management specialist (GMS) to request a revised DMS Plan through the JIT process. If the DMS Plan is not approved, there is a bar to funding.
  • Verify the IMPAC II DMS flag. Work with the GMS and eRA Helpdesk to edit the IMPAC II DMS flag if the DMS Policy flag is incorrect.
  • If the project will generate large-scale human genomic data and falls under the Genomic Data Sharing (GDS) Policy, request Institutional Certification during JIT.
  • Complete Program Officer (PO) Checklists for competing applications released for funding.
  • Monitor compliance with the approved DMS Plan via RPPR.
  • Review recipients’ post-award revision requests of the DMS Plan made through the RPPR Module or Prior Approval Module in eRA Commons.

Grants Management Specialists

  • Complete corresponding Grants Management Checklist questions verifying program officer approval of the DMS Plan.
  • If the program officer deems the DMS Plan unacceptable, work with the program officer to request a revised DMS Plan through the standard JIT process. If the DMS Plan is not approved, there is a bar to funding.
  • Ensure the DMS costs are reasonable, allocable, and allowable.
  • Post-award, before issuing the noncompeting continuations through the RPPR, coordinate with the program officer to verify the recipient is complying with the approved DMS Plan.
    • Any concerns regarding the DMS Plan should be documented in the PO Checklist, along with proposed resolutions.
  • If the recipient makes post-award revision(s) of the DMS Plan through the Prior Approval Module, save the revised, accepted plan in the Official Grant File along with earlier approved version(s).
    • The revised DMS Plan becomes a revised term and condition in a revised Notice of Award.

Contacts

Links

NIAID

NIH

Resources on Scientific Data Sharing and Writing a Data Management and Sharing Plan:

Guidance on the NIH Genomic Data Sharing (GDS) Policy:

Other Guidance:

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