Helping You Comply with the Data Management and Sharing Policy Through eRA System Validations

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NOTE: This content does not reflect the July 31, 2023 application instruction update for DMS. Please see NOT-OD-23-161 for details.

No one wants to find out they’ve missed a requirement when it’s too late to do anything about it.  

Our eRA Systems (e.g., ASSIST, eRA Commons) perform several business rule validations to support our Data Management and Sharing (DMS) Policy implementation. The validations ensure the DMS Plan, associated budget line item, and budget justification are included when the DMS Policy applies and are not included when it doesn’t. 

By flagging each active funding opportunity announcement (FOA) as requiring a Data Management and Sharing (DMS) Plan or not, we are able to compare opportunity expectations against your application data. You simply need to take advantage of the application validation features available in ASSIST, Grants.gov’s Workspace, and many institutional system-to-system solutions. Validate your application well in advance of your due date and you’ll have plenty of time to correct your application and still submit by the deadline.   

The Scientific Data Sharing site has a wealth of information including a Research Covered Under the Data Management & Sharing Policy page which describes the types of NIH grant programs for which the policy does and does not apply.  

The policy applies to the vast majority of NIH FOAs. The policy does not apply to Training (T) and Fellowship (F) FOAs or any FOA that includes this text inserted in Section IV. Application and Submission Information: 

“Note: Effective for due dates on or after January 25, 2023 a Data Management and Sharing Plan is not applicable for this FOA.”

Follow the application guide and FOA instructions and you shouldn’t have any problems. If you do encounter an error, take a deep breath, and take action. If you are unable to clear the error on your own, reach out to the eRA Service Desk for assistance.  

eRA System Validations and the Actions You Can Take to Address Them

Error Message  Actions  
The “Data Management and Sharing Plan” attachment must be included for this application.  Verify the DMS Policy applies to the FOA  

  • Applies: Include a DMS Plan attachment in the Other Plan(s) field of the PHS 398 Research Plan or PHS 398 Career Development Award Supplemental form (whichever form is included). 
  • Does not apply: Contact the eRA Service Desk for assistance.  
The “Data Management and Sharing Plan” attachment cannot be submitted for this application.  Verify the DMS Policy applies to the FOA  

  • Applies: Contact the eRA Service Desk for assistance. 
  • Does not apply: Remove any attachments from the Other Plan(s) field of the PHS 398 Research Plan, PHS 398 Career Development Award Supplemental, PHS Fellowship Supplemental, or PHS 398 Research Training Program Plan form (whichever form is included). 
An Other Plan(s) attachment is not allowed at the component level. The Data Management and Sharing plan should only be included in the Overall Component.   In your multi-project application, remove any attachments from the Other Plan(s) field of the PHS 398 Research Plan, PHS 398 Career Development Award Supplemental, or PHS 398 Research Training Program Plan forms in any non-Overall component. 
An entry labeled “Data Management and Sharing Costs” must be entered in the Other Direct Cost section F of the R&R Budget form for at least one component since an attachment has been uploaded to the Other Plan(s) section of the Research Plan form in the Overall.   For multi-project applications, the DMS Plan is included with the Overall component, but the associated Data Management and Sharing Costs must be included in at least one non-Overall component (the Overall component doesn’t have its own budget form, it is calculated by combining the budgets in the other components where the work is done). 

Verify the DMS Policy applies to the FOA  

  • Applies: Verify at least one component includes at least one budget period on the R&R Budget form with an Other Direct Cost entry in section F with the exact label “Data Management and Sharing Costs” (without quotes). We do a text string match.If no cost will be incurred, include the “Data Management and Sharing Costs” entry and indicate “0” Funds Requested. 
  • Does not apply: Remove any attachments from Other Plan(s) field of the PHS 398 Research Plan in the Overall component. 
An entry labeled “Data Management and Sharing Costs” must be entered in the Other Direct Cost section F of the R&R Budget form since an attachment has been uploaded to the Other Plan(s) section of the <Insert appropriate form name>.   Verify the DMS Policy applies to the FOA  

  • Applies: Verify at least one budget period on the R&R Budget form includes an Other Direct Cost entry in section F with the exact label “Data Management and Sharing Costs” (without quotes). We do a text string match.If no cost will be incurred, include the “Data Management and Sharing Costs” entry and indicate “0” Funds Requested. 
  • Does not apply: Remove any attachments from Other Plan(s) field of the PHS 398 Research Plan or PHS 398 Career Development Award Supplemental form (whichever form is included). 
“Data Management and Sharing Costs” can only be entered on one of the lines in Section F Other Direct Costs within the same budget period.  Verify every budget period of the R&R Budget form has no more than one Other Direct Cost entry in section F labeled “Data Management and Sharing Costs.” 
An attachment must be uploaded under the Additional Narrative Justification attachment of the Modular Budget form to specify “Data Management and Sharing Costs.”   Verify the DMS Policy applies to the FOA  

  • Applies: Ensure the Modular Budget form includes an Additional Narrative Justification attachment that contains a data management and sharing justification. 
  • Does not apply: If an Other Plan(s) attachment is included on the PHS 398 Research Plan form, remove it (the existence of the attachment triggers the error). 

2 Comments

  1. This is a huge burden on investigators with nothing useful in return. Do you really want people to apply for grants?

  2. These requirements are another example of the increasing burden that NIH places on investigators. The requirements for progress and close out reports that link publications and reporting results to ncbi, clinicaltrials. gov respectively, are extremely burdensome and duplicative of peer reviewed published papers (published in open access or NCBI compliant). For e.g., clinical trials compels us to report data in ways that may not be found in our publications requiring additional staff burden. Since data analyses sometimes occurs after the funding period is over, staff are not available to assist with these various reporting requirements placing a burden on Principal Investigators. I am uncertain about the extent to which P.Is. can focus on their science vs. fulfilling every reporting hoop that NIH imposes on us.

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