Skip to Main Content

NIH Data Management and Sharing Policy

Guidance on how to comply with the NIH Data Management and Sharing Policy (effective January 25, 2023)

Policy Overview

Gears and Cogs Turning

The NIH Data Management and Sharing (DMS) Policy requires the following as of January 25, 2023:

  • Investigators plan and budget for the managing and sharing of data.
  • Investigators submit a Data Management and Sharing (DMS) Plan for review when applying for funding.
  • Investigators comply with the approved DMS plan.

Learn more about what the NIH are expecting of investigators and institutions under the 2023 NIH Data Management & Sharing Policy on the NIH Scientific Data Sharing website.

NIH’s Public Access Policy and Supplemental Guidance

On June 18, NIH released its draft Public Access Policy and Supplemental Guidance for implementation of the 2022 OSTP Nelson Memorandum.  And please note: NIH indicates that the Policy and Guidance documents specifically focus on scholarly publications (and not data) as the NIH’s policy for Data Management and Sharing (DMS) was already issued and has been in effect since January 25, 2023.


Overall Requirements and Scope

  • The Policy requires immediate public access to articles - embargos are no longer allowed.
  • NIH reiterates authors do not have to pay a fee to comply with the Policy.
  • The Policy applies to manuscripts accepted for publication on or after October 1, 2025. This means the Policy will apply to existing grants if the article is published on or after that date.
  • The Policy requires that final peer-reviewed manuscripts be submitted to PubMed Central (PMC) to be made publicly available immediately upon publication.
  • The Policy requires that grantees explicitly grant the NIH the right to make the manuscript available in PMC without an embargo.
  • The Policy does not explicitly grant full reuse rights of the manuscript to the public.



  • NIH will maintain its two existing submission pathways: submission of the final peer-reviewed manuscript to PMC directly or submission of the final published article to PMC from a journal that has a formal agreement with the National Library of Medicine (NLM).


Publication Costs

  • Submission of the manuscript to PMC remains free under the Policy.
    • NIH notes that any fee requested during the publication process for submission to PMC is not an allowable cost under the new Policy.
  • Authors do not have to pay an article processing charge (APC) to comply with the Policy. However, “reasonable” publication costs are allowed to be requested as direct or indirect costs.
    • NIH does not define what a “reasonable” publication cost is.
    • However, the Guidance provides language encouraging authors and institutions to consider a variety of factors when determining if a publication cost is “reasonable,” including sustainability of library or lab budgets and professional or institutional priorities.
  • The proposed Policy and Guidance documents outline additional unallowable publication costs, including:
    • Any fee requested during the publication process for submission to PMC (i.e., article development charges or other attempts to extract payment from manuscript deposit).
    • Costs for which the institution already pays a fee that would cover the publication (e.g., costs to publish in a journal for which the institution already has a “read-and-publish” agreement).
    • Costs that are charged differentially because the author is subject to NIH’s Public Access Policy.
    • Publication costs incurred after the closeout of the award.


Reuse of Publications

  • The Policy requires grantees to provide NIH with rights to the accepted manuscript that are equivalent to those of the Federal Purpose License (“A royalty-free, nonexclusive and irrevocable right to reproduce, publish, or otherwise use the work for federal purposes, and to authorize others to do so.”).
  • NIH is not proposing to authorize the public to make broad reuse of the work.



  • Non-compliance with the Policy, including failure to acknowledge federal funding in the manuscript, may be considered when making future funding decisions for the grantee or cause a delay in the continuation of non-competing grant awards.


NIH is the first agency to release its draft policy. All agency policies must be issued before December 31, 2024 as required by the Nelson Memo. If you have questions about NIH’s proposed Policy and Guidance documents, please contact:


Using this Guide

We have created and are actively developing this guide to walk OHSU members through the process of complying with the new NIH Data Management and Sharing Policy. An institution-wide task force is working on expanding and improving documentation and other supporting resources, including template language that investigators can include in their DMS plans. Bookmark this guide for easy access, as it will be updated frequently.

  • The Writing Your Data Management Plan section describes what the NIH expects you to address and useful resources for preparing your DMSP.
  • Sharing Scientific Data addresses required and encouraged practices for sharing data, including when to share data and how to choose a repository.
  • Budgeting outlines what costs may be requested in a funding application, and features resources for estimating costs for preserving, archiving, and promoting acceess to data.
  • Resources and Tools feature tools, documentation, educational opportunities, and services for data management and sharing available at OHSU and beyond.

Additionally, the Library hosts monthly workshops on preparing for the new NIH Data Management and Sharing Policy. The workshops are open to all OHSU members. We encourage all faculty, learners, and staff who will engage in activities related to generating, preserving, and sharing data to attend.

Quick Access to Key Resources