Data Management and Sharing Implementation for Contracts

Funding News Edition: September 21, 2022
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In our May 4, 2022 article “A Deep Dive Into Data Management and Sharing,” we covered several grant-related aspects of the Final NIH Policy for Data Management and Sharing. We now focus on what the Policy means for contracts.

First, be aware that the effective date of the Data Management and Sharing (DMS) Policy applies to proposals submitted on or after January 25, 2023.

Contract solicitations likely to generate scientific data will include proposal instructions that direct offerors to submit a DMS Plan to the funding institute or center (e.g., NIAID) as part of the technical proposal. Plans should explain how scientific data generated by research projects will be managed, which of these scientific data and accompanying metadata will be shared, and where and how these data will be shared. For example, the Plan should indicate what repositories will be used to share the data, what standards will be used, and if any technical, legal, or ethical constraints are expected to limit data sharing. Note: the DMS Plan must be deemed acceptable prior to contract award.

Compliance with the Plan will become a contractual requirement and enforcement will be consistent with the contract award and the Federal Acquisition Regulations, as applicable.

Questions and Answers

Go to Frequently Asked Questions (FAQ) for Contracts: NIH Policy for Data Management and Sharing (DMS) - NOT-OD-21-013 for more information.


Before contract award, submit questions or comments about a solicitation or award, including the DMS Plan, to the contracting officer referenced in the solicitation.

Additional Resources

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