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(NIH) published a request for public comments on a DRAFT NIH Policy for Data Management and Sharing and supplemental DRAFT guidance.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.
ARL has proposed 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. The Association suggests that NIH strongly encourage machine-readable, or “active” DMPs. Further, it recommends that NIH should 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.
Additionally, ARL proposes that NIH ICOs provide public guidance on good/exemplar data management and sharing plans, and that NIH include “well-documented” or “curated” in its definition of data sharing.
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