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Sharing Data Questions and Answers

Table of Contents

Where can I find basic information on data sharing?

See the following documents:



What is the data sharing policy?

NIH requires researchers requesting $500,000 or more in direct costs in any year to include a plan to share final research data in their applications or proposals or explain why data sharing is not possible.

NIH's genome-wide association studies (GWAS) policy is part of this requirement; however for GWAS, you need to share the data regardless of the proposed budget.

Must all applicants and offerors include a plan for sharing data?

No. You need a data sharing plan only if you're requesting $500,000 or more in direct costs in any year of a grant or contract or if you are proposing a genome-wide association study.

What data am I required to share?

You must share final research and genome-wide association study data. Read more in our SOPs linked above.

In addition, NIH emphasizes the importance of sharing what it refers to as "unique" data—data that cannot be readily replicated, e.g., studies of rare diseases or large or unique populations.

What does "final research data" mean?

Final research data means recorded, factual material commonly accepted by the scientific community as necessary to validate research findings. It does not include lab notebooks, preliminary analyses, drafts of scientific papers, or objects such as gels or lab specimens.

When must I start sharing data?

Start sharing your data by the time the main findings from the final data set have been accepted for publication.

What are some ways to share data?

These include publishing, making presentations, putting in an archive or online, or sending individual responses.

Must I share data even if I don't plan to publish it?

Yes, but you still must protect privacy.

What should I include in my plan?

Use the resources listed in our SOPs:

Can I place any conditions on the use of my data?

Yes. Put that information in your plan.

Can I get feedback on the acceptability of my sharing plan?

Yes. Before you apply, discuss your proposed plan with an NIAID program officer. Go to When to Contact an NIAID Program Officer.

Where do I put the plan in my application or proposal?

For grant applications, put the plan in the Resource Sharing Plans section of the PHS 398 Research Plan form. It does not count toward the the Research Strategy page limit. If your research involves genome-wide association studies (GWAS), you need to state that in your cover letter too.

For contract proposals, follow the instructions in the solicitation.

Who assesses my data sharing plan?

Peer reviewers assess the plan during review, and your program officer assesses its adequacy after review. You may want to discuss the plan with your program officer before you submit the application.

Though not factored into your overall impact score, the review assessment is recorded in the summary statement for follow-up. While an inadequate plan would not create a bar to award, it flags the program officer to make sure an acceptable plan is in place before we make an award.

For a noncompeting application, your program officer will consider your willingness to share as one criterion for continued funding. He or she may also be able to help you develop your plan.

Does my data sharing plan affect my review outcome?

No. See Who assesses my data sharing plan? above.

Does the requirement affect my grant's progress report?

Yes. For noncompeting applications, document your sharing of data in your progress report. Go to Send Us an Annual Progress Report in the Strategy for NIH Funding.

How does my data sharing plan relate to HIPAA?

Data sharing plans must comply with the Health Insurance Portability and Accountability Act.

How can I protect the privacy of my subjects?

Strip identifiers and take other appropriate measures, such as withholding part of the data, statistically altering the data without compromising secondary analyses, requiring researchers who seek data to protect privacy, and providing data access in a controlled site.

Are there special requirements for proposing a genome-wide association study or accessing the data repository?

Yes. Read the Data Sharing for Grants: Genome-Wide Association Studies SOP and What Resources Do You Need to Share? in the Strategy for NIH Funding.

What should I do if I think a researcher is supposed to share his or her reagents, model organisms, or data, but isn’t?

In general, NIH policy requires that results and accomplishments be shared as a term of award.

However, sharing is not required for every award or every resource. If a grant has a data sharing or model organism sharing plan, the PI should follow the NIH-approved sharing plan. That plan may or may not require sharing, or may only require sharing in certain ways, for example, providing the reagent or resource to a repository.

Be sure to check our repositories for the resources you seek at NIAID Resources for Researchers. These repositories are public, though most have requirements you’ll have to meet before you can request materials.

You can also read What can I do if I believe an investigator is refusing my request for strains or other resources? on NIH's Frequently Asked Questions.

If I have more data sharing questions, where can I get help?

If this policy applies to you, contact an NIAID program officer before applying. Go to When to Contact an NIAID Program Officer.

See When to Contact an NIAID Program Officer for contact information. Contractors and offers should ask the contracts staff member listed in the solicitation. See the Extramural R&D Solicitations list or Office of Acquisitions staff listing.

What if my question wasn't answered here, or I'd like to suggest a question?

Email with the title of this page or its URL and your question or comment. We answer questions by email and post them here. Thanks for helping us clarify and expand our knowledge base.

Last Updated April 04, 2016

Last Reviewed March 06, 2015