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ARL Comments on Draft NIH Policy for Data Management and Sharing

On November 6, 2019, the US National Institutes of Health (NIH) published a request for public comments on a DRAFT NIH Policy for Data Management and Sharing and supplemental DRAFT guidance. NIH has a long history of promoting public access to the research it funds, including policies for sharing scientific data generated from large awards, genomic data, and data from clinical trials.

The Association of Research Libraries (ARL) welcomes the opportunity to comment on these new draft policies, expanding the guidance on data sharing to all extramural awards, contracts, intramural research projects, and other funding agreements. ARL offers these comments in consultation with member representatives, experts in the data librarian community, and through consultation with a wider group of institutional stakeholders who recently met to draft implementation guidelines for effective data practices recommended by the US National Science Foundation.

Comments of the Association of Research Libraries Regarding “DRAFT NIH Policy for Data Management and Sharing, and Supplemental DRAFT Guidance: Elements of an NIH Data Management and Sharing Plan”

January 9, 2020

Thank you for the opportunity to comment on the draft version of NIH Policy for Data Management and Sharing, and Supplemental DRAFT Guidance: Elements of an NIH Data Management and Sharing Plan. I submit the following views on behalf of the Association of Research Libraries (ARL), a nonprofit collective of 124 leading research institutions in the United States and Canada.

ARL offers the following comments:

  • ARL applauds the expansion of data sharing to all extramural awards, and the recognition that data sharing is part of good data management and practice.
  • ARL recognizes the commitment of the NIH and the National Library of Medicine (NLM) to data-powered health advancements and data science, which are dependent on a robust curation and sharing culture.
  • As members of the Confederation of Open Access Repositories, hosts and administrators of institutional repositories of various types, and data curators, the ARL community welcomes the opportunity to partner and consult on the development of desirable criteria for data repositories.
  • In the interests of reducing complexity and burden, ARL encourages (to the extent practicable and scientifically valid) the NIH Institutes, Centers, and Offices (ICOs) to harmonize their supplemental guidance to this policy.
  • ARL welcomes the draft policy’s steps toward the integration of data management and sharing plans (DMPs) within regular reporting intervals. While the draft policy does not call for machine-readable DMPs, recognition that the plan will be revisited with regular grant reporting is an important step toward creating a culture of active DMPs.
  • ARL applauds the inclusion of guidance for the adoption of common data elements and standards for scientific data and associated metadata in data management and sharing plans.
  • ARL thanks the NIH for including data curation and data preservation in allowable costs as these are necessary activities for meaningful data sharing.
  • ARL welcomes the proposed enforcement of the policy as a term and condition of awards.

ARL offers the following additional recommendations for the Draft Policy:

  • ARL welcomes the proposed reduction in faculty administrative burden that would result from “just in time” data management and sharing plans, and suggests that upon submission a plan be considered in draft, with the elements that need to be evaluated for scientific merit; and the full plan delivered upon award, allowing time for critical intra-institutional consultation (with research offices, computing, and libraries, for example).
  • ARL recommends that NIH collect and share data on any cost adjustments for data management between submission and award, and over the course of the awards, so that the community can benefit from data on estimated and actual costs.
  • ARL recommends that DMPs from funded awards be made available within the awardee’s institution, if not publicly.
  • ARL recommends that NIH strongly encourage machine-readable, or “active” DMPs.
  • ARL recommends that NIH require or strongly encourage the use of data citation principles as well as persistent identifiers (PIDs) such as ORCIDs for data collectors/managers or digital object identifiers (DOIs) for data sets.
  • ARL recommends that NIH ICOs provide public guidance on good/exemplar data management and sharing plans.
  • ARL recommends that NIH include “well-documented” or “curated” in its definition of data sharing.

Thank you for your consideration of these comments.

Mary Lee Kennedy
Executive Director
Association of Research Libraries


About the Association of Research Libraries

The Association of Research Libraries (ARL) is a nonprofit organization of 124 research libraries in Canada and the US whose mission is to advance research, learning, and scholarly communication. The Association fosters the open exchange of ideas and expertise, promotes equity and diversity, and pursues advocacy and public policy efforts that reflect the values of the library, scholarly, and higher education communities. ARL forges partnerships and catalyzes the collective efforts of research libraries to enable knowledge creation and to achieve enduring and barrier-free access to information. ARL is on the web at ARL.org.

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