Major Update to the NIH Data Management and Sharing Policy

On January 25, 2023, the National Institutes of Health's (NIH) Data Management and Sharing Policy (DMS Policy) went into effect. This policy requires all projects funded by the NIH, in whole or in part, to submit a data management and sharing (DMS) plan with their funding applications. This DMS Policy was implemented to build on and fulfill earlier commitments made by federal funders to increase the public's access to both scientific publications and research data that was funded by federal institutes such as the NIH.

In February 2026, it was announced that as of May 25, 2026, an updated DMS Policy format will be required. This streamlined format asks researchers to answer yes or no to the questions 1) will project data sharing be maximized; 2) will data underlying peer-reviewed publications be made available by the time of publication; 3) will data be made available for at least as long as required by repository and/or journal policies; 4) provide explanations if “no” was answered to any of the previous questions; and 5) if data derived from humans will be shared, will their privacy, rights and confidentiality be protected? Question 6 asks researchers to provide a brief (fewer than 100 words) list of the data types that will be produced by the project and the anticipated repository where data will be shared. Two additional brief questions are included for studies subject to the NIH Genomic Data Sharing Policy.  

While the changes increase streamlining of the plans, they also mean that key data management planning information required in the previous version will now be up to researchers and teams to document for themselves. When the time comes to deposit data in the chosen repository, it will be helpful if research teams have on hand the kind of information required in the original NIH DMS Policy, such as information on data formats and metadata standards that apply to the research in question, information on the specific software programs used to process and analyze the data, and documented procedures for protecting research participant privacy, such as ensuring full informed consent for data sharing, making sure plans are in place for de-identification of any human-based data to be shared and anticipated need for data use agreements for secondary researchers.  

Galter Library is poised to assist with all aspects of the transition to the new NIH DMS Policy format. The Library’s data-focused class offerings include an updated class on Creating Compliant Plans for the NIH Data Management and Sharing Policy, as well as an accompanying, updated GalterGuide which provides further pointers towards DMS Policy compliance. We also offer one-hour data management consultations through the Galter DataLab, during which we can assist with DMS Policy creation and with the data management planning efforts that can address the ongoing needs described above. 

Compliance with the NIH DMS Policy, on a practical level, requires well-managed data, which requires proper storage, computing environments and associated resources. Data support needs outside of the data management focus of Galter Library are met through collaboration with other campus units to maximize local expertise. For example, we partnered with Northwestern University IT (NUIT) to publish a special website on Research Data Management and Sharing. This website is intended as a one-stop-shop for information on local requirements and resources for compliance with the NIH DMS Policy.   

In addition, Galter Library, Northwestern University Libraries (NUL), and NUIT Research Computing Services host the shared email Inbox researchdata@northwestern.edu. All requests for support on data management and sharing, high performance computing, long-term preservation options and much more, can be sent to this single inbox. Requests are then routed to the people or departments at the university who are best equipped to help. Requests can be made from any campus and related to any data question. 

For consultations on data management and sharing plans, please reach out to me at sara.gonzales2@northwestern.edu, or to researchdata@northwestern.edu.