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Data Sharing for Grants: Genome-Wide Association Studies (GWAS) SOP

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

Note: For information on NIH's genomic data sharing policy, go to NIH's Genomic Data Sharing (GDS) site.


To require NIH-supported investigators to share data from genome-wide association studies (GWAS) with the scientific community and enable investigators to access GWAS data.


Regardless of the proposed budget amount, all GWAS applications must include a plan to send data to NIH’s Database of Genotype and Phenotype (dbGaP) housed at the National Center for Biotechnology Information in the National Library of Medicine.

NIH expects funded investigators who conduct genome-wide analyses of genetic variation to make their data available for secondary research through dbGaP.

GWAS are studies of the variation across the human genome to identify genetic associations with observable traits (such as blood pressure or weight), or the presence or absence of a disease or condition.

In addition to the GWAS data sharing requirement, applicants must share other final research data for applications that seek $500,000 or more in direct costs in any year of the grant as well as for some program announcements (PAs) and requests for applications (RFAs). Read more in the Data Sharing for Grants: Final Research Data SOP.

Investigators Who Plan to Conduct a GWAS

If your research qualifies as a genome-wide association study as defined above, follow these steps.

  • Create a plan in your application to send your data to dbGaP.
    • If sharing is not possible, your plan must explain the reasons.
    • We strongly advise that you contact your program officer to assess the viability of your plan.
  • Ways to share data include publishing, making presentations, putting in an archive or online, or responding to requests individually.
  • Describe your plan—or justify its absence—in the Resource Sharing Plans section of the PHS 398 Research Plan form (electronic application) or the PHS 398 Resource Sharing Section (paper application).
  • For more information on writing a plan, see the following resources:
  • In your cover letter, state that you are proposing to conduct GWAS research or planning to access GWAS data in the NIH repository.
  • Before you submit your application, your institutional review board will need to review your plan.
  • When you submit the data, your institution will certify that your submissions meet NIH's and its own policies. For details, read NIH's Points to Consider for IRBs and Institutions.

Investigators Who Plan to Use GWAS Data

If you plan to access GWAS in the controlled-access portions of the database, take the following actions:

  • Use the online dbGaP system to apply for access.
  • Provide information, such as a description of how the requested data will be used in your research, a data security plan, and a Data Use Certification, which has the terms for using the dataset.
  • If approved by NIAID's data access committee, you will have access to the data for one year. After that, you must submit a project renewal request annually, or complete a project closeout process if you'll no longer use the data.

Funded Investigators Conducting a GWAS

  • Submit your GWAS data to dbGaP.
    • Provide basic study information, such as:
      • The type of data that you'll be submitting.
      • A description of the study.
      • Certification that includes any limitations on the secondary use of the data, as determined by the informed consent.
        • Examples of limitations: data cannot be shared with for-profit companies, data can be used only for research of particular diseases.
  • Register studies in dbGaP.
    • Make sure to contact your program officer and NIAID's Genomic Program Administrators (GPAs) to discuss the project, data sharing plan, and certification process.
    • Be aware of next steps:
      • The GPAs initiate the registration process in the online dbGaP registration system by providing the grant number and your name as well as that of your program officer and study.
      • You will receive an email from the online system with instructions to complete the study registration.
      • After the GPAs verify your information, you will receive an accession number for the study, at which point you should preview the data before it is released.
      • Upon your approval, dbGaP publishes the study on its website.

Scientific Review Officers

  • Remind reviewers to check that applicants provided a GWAS data sharing plan.
  • Ask reviewers to check the acceptability of the plan.
  • Ensure that reviewers do not factor the plan into their overall impact scores unless the funding opportunity announcement states that GWAS data sharing plans should be a factor.
  • Describe the reviewers' assessment of plans in the summary statement.
  • If the plan is unacceptable or missing, flag it as a header in the summary statement.
  • If you plan to access data:

Program Officers

  • Work with PIs to develop an acceptable GWAS data sharing plan for their application.
  • After review, assess the appropriateness and adequacy of investigators' proposed data sharing plan. Complete Program Officer Checklists for competing applications released for funding.
  • Make sure PIs comply with policy both on data sharing and HIPAA.
  • Use sharing language in the boilerplate for RFAs, PAs, and solicitations (see link below).
  • If you plan to access data:

Grants Management Specialists

  • Issue a restricted award if the program officer finds the sharing plan unacceptable (done at the end of the fiscal year only).
  • Remove a restriction after receiving a revised sharing plan that is acceptable to program staff.


Applicants or grantees with questions should read Communicating With NIAID—How to Get Help.

Genomic Program Administrators

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If you have knowledge to share or want more information on this topic, email with the title of this page or its URL and your question or comment. Thanks for helping us clarify and expand our knowledge base.



Applying for a Grant portal

Sharing Data Questions and Answers


Trans NIAID Clinical Research Toolkit

What Resources Do You Need to Share? in the Strategy for NIH Funding


Health Information Privacy​​

NIH Data Access Committees (DACs) and Chairs Roster

Lock icon: This link will not work for public visitors.NIH Guide Publishing SystemFOA and Notice Templates

SF 424 Application Guide for your grant application package (for electronic application)

Last Updated August 13, 2015

Last Reviewed August 15, 2014