Data Management and Sharing Plans

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National Science Foundation (NSF)

Starting April 27, 2026, NSF requires grant proposals to include a Data Management Plan uploaded into the Research.gov using their DMSP tool. The details of this plan are updated in Policy Notice: Implementation of Policy Changes to Proposal and Award Policies and Procedures Guide (PAPPG) 24-1, Supplement 2. Some NSF units may have specific requirements for their data management plans. To help determine if this is true for the grant you're applying for, visit NSF's Data Management web page.

What should my NSF Data Management and Sharing Plan include?

The following information applies generally to NSF grants. Remember, your specific directorate, office, division, or program might have more specific requirements, and you should always check those as well.

Starting April 27, 2026, your NSF DMSP will be uploaded using the NSF tool in Research.gov. One plan should be submitted for each project (regardless of collaborations or subawards), and the data plan should discuss data issues relevant to the context of such collaborations.

It is possible your NSF project may not require a DMSP. A statement that no detailed plan is needed is permitted only if:

  • No data, samples, physical collections, software, curriculum materials or other materials are to be produced during the project.
  • The statement is accompanied by a clear justification.

DMSPs should conform to the NSF Policy on Dissemination and Sharing of Research Results. This policy is summarized by the following:

Publication of findings

Investigators should quickly prepare and submit all important research results for publication, with authorship accurately reflects contributions. Organizations must allow and support those who did the work to publish their findings unless the organization plans to publish them first.

Sharing data, samples, and materials

Investigators should share primary data and materials with other researchers at low cost and within a reasonable time, and organizations should help make this sharing possible. Sensitive information must be protected, and recipients may allow exceptions when needed to protect people, research validity, or collections; they can also request exceptions from the NSF Program Officer.

Sharing software and inventions

Investigators and organizations are encouraged to share software and inventions created under the award or otherwise make them widely available and usable.

Intellectual property rights

The right to maintain intellectual property rights does not reduce the responsibility to make research results, data, and collections available to the research community.

NSF’s role in implementing sharing policies

NSF program staff will apply these sharing and dissemination policies through proposal reviews, award negotiations, award conditions, and support that helps with data cleanup, documentation, and storage.

Award terms and conditions

Every NSF award includes a required article that puts these dissemination and sharing expectations into effect.

NSF continuation

Once again, it is important to note that different directorates, offices, divisions, programs, and other NSF units may have requirements specific to their individual programs. You should always check your specific program requirements.

NSF Resources

National Institutes of Health (NIH)

The Final NIH Policy for Data Management and Sharing (NOT-OD-21-013) requires researchers to include a data management and sharing (DMS) plan in funding applications. NIH's Scientific Data Sharing Website guides PIs in understanding NIH data sharing and data access policies.

The Final DMS Policy applies to all research, funded in whole or in part by NIH, that results in the generation of scientific data.

NIH defines scientific data as, "...data 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 includes any data needed to validate and replicate research findings.
  • Scientific data does 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."

What Does the Policy Apply To?

 The policy applies, but is not limited, to:

  • Research Projects
  • Some Career Development Awards (Ks)
  • Research Centers
  • SBIR/STTR*

The policy does not apply to research and other activities which do not generate scientific data or fall under alternative sharing policies, including but not limited to:

  • Training (T)
  • Fellowships (Fs)
  • Construction (C06)
  • Conference Grants (R13)
  • Resource (Gs)

These may be subject to additional sharing policies. See NIH's list of Institute and Center Data Sharing Policies or try their decision tool Which Policies Apply to My Research? As always, be sure to check the funding opportunity notice for DMS policy requirements.

* Of note, SBIR/STTR projects may have special considerations, on which NIH elaborates in its FAQ, "Do SBIR/STTR projects have to share scientific data under the DMS Policy?" 

Once a grant has been awarded, the DMS Plan becomes part of the award's terms and conditions. NIH expects researchers and institutions to implement data management and sharing practices as described in their approved Plan. Compliance with the DMS Plan, including any updates, may be reviewed during regular reporting intervals.

How Do I Write and Submit My DMS Plan

Researchers will be required to submit a DMS plan at the time of application to the funding NIH Institute, Center, or Office (ICO) that outlines how scientific data and related metadata will be managed and shared, including any potential restrictions or limitations. For applicants with due dates after May 25, 2026, PIs must use NIH's 2026 Pilot DMS Plan Format Page to prepare their DMS plan. This page should be submitted as part of your grant application. NIH details how to write and submit your DMS plan on their Writing a Data Management and Sharing Plan webpage.

Things to Consider When Developing an NIH DMS Plan

  1. Consider what factors might limit data sharing

    For example: (1) informed consent that will not permit or limits scope of sharing or use. Projects are expected to include data sharing requirements in consent forms to the extent possible. (2) Privacy or safety of research participants would be compromised and available protections are insufficient. (3) Explicit federal, state, local, or Tribal law, regulation or policy prohibits disclosure. (4) Restrictions imposed by existing or anticipated agreements with other parties.

  2. Consider how research participant data will be shared.

    Secondary data may need a DMS plan if it is “new, derived data as a result of their research” with exemptions for primary data that has sharing limitations. See FAQ B.7 under Managing and Sharing Scientific Data for more information.

  3. Consider how research participants will be informed their data will be shared

    For example, will the data be de-identified using HIPAA de-identification standard or identifiable. How will this be addressed in the informed consent form and the IRB application? You can find sample NIH/DMSP informed consent language on the IRB website in the Example Informed Consent Language document.

  4. Submit your DMSP to the IRB for review along with your IRB application

    When submitting an NIH funded proposal to the UCCS IRB include your DMS plan to the IRB for general awareness. Please note the IRB may ask some follow-up questions or make requests to ensure the DMS plan follow federal regulations and campus policies.

  5. Consider whether your are using Genomic Data

    The NIH maintains a separate policy with additional considerations for research using Genomic Data. If using Genomic Data, review NIH Genomic Data Sharing Policy.

NIH Data Management and Sharing Plan FAQs

If you have specific questions about budgeting for the DMSP, please reach out to osp@uccs.edu

Allowable Costs:

  • Curating data
  • Developing supporting documentation
  • Formatting data according to accepted community standards, or for transmission to and storage at a selected repository for long-term preservation and access
  • De-identifying data
  • Preparing metadata to foster discoverability, interpretation, and reuse
  • Local data management considerations, such as unique and specialized information infrastructure necessary to provide local management and preservation
  • Preserving and sharing data through established repositories (ex: data deposit fees). If proposing multiple repositories, costs associated with each may be included
  • Note: Personnel (salary and fringe) effort specific to DMS must be included as part of the DMS Costs line item in the detailed R&R budget. (If a modular budget, it must be detailed in the Additional Narrative Justification).

Unallowable Costs:

  • Infrastructure costs that are included in institutional overhead (for instance, Facilities and Administrative costs)
  • Costs associated with the routine conduct of research, including costs associated with collecting or gaining access to research data.
  • Costs that are double charged or inconsistently charged as both direct and indirect costs 

Scientific data should be shared as soon as possible, but no later than the time of a publication of findings in a peer-reviewed journal OR at the end of the award, whichever comes first. The publication date is considered to the be when the article is first available via print or electronic format. NIH also notes that some preprint servers may require sharing of data upon preprint posting, and repositories storing data may also require public release of data upon preprint posting.

If an award is made, the approved DMS Plan will become a term and condition of the award and the PI is responsible for managing and sharing data as described in the DMS Plan. During the funding period, compliance with the Plan will be determined by the NIH Institute or Center.

Effective October 12, 2023, prior approval requests must be submitted through eRA Commons by a UCCS approved signing/authorized official (NOT-OD-23-185). These requests must be submitted at least 30 days in advance of the requested change. Please contact osp@uccs.edu as soon as possible if you believe you need to make changes to your DMS Plan. To learn more, see NIH's announcement for DMS Plan Prior Approval Capability.

Prior approval from the NIH Program Officer along with the revised DMS Plan are required when the following changes occur to the plan:

  • New Scientific Direction
  • Change in Data Repository
  • Timeline Revision

Compliance with the Plan, including any Plan updates, may be reviewed during regular reporting intervals (e.g., at the time of the annual RPPR). Please contact osp@uccs.edu when submitting a NIH RPPR.

NIH Resources

NIH Resources