NIH Policy Change: New Data Management and Sharing Policy

Human participant research (IRB) implications

Per the Final NIH Policy for Data Management and Sharing (NOT-OD-21-013), starting on January 25th, 2023, all grant applications submitted to the National Institutes of Health (NIH) are required to include and follow a Data Management and Sharing Plan (DMSP). The new policy intends to promote transparency and accountability in research by setting a minimum set of expectations for data management and sharing.

The Cornell University IRB is in the process of putting together a guidance document regarding the impact of the policy on our process and procedures. For now, when you are submitting protocols to the IRB for review that involve (or potentially involve) NIH funding, you should plan to include your Data Sharing and Management Plan in the protocol. In your RASS-IRB application, you can upload this in the Additional Documents section, under Other Documents.

Below, we have provided resources to read more about this policy change, and learn how it impacts you and your research.



  • For questions about how this policy might impact your current NIH funding or upcoming proposal submission, contact your OSP Grant & Contract Officer.
  • To request a review or to get help drafting a DMS Plan, contact CDS at
  • For questions about how this policy might impact your human participant research, contact the IRB office at
Published on: Monday, January 30, 2023 - 12:51pm