The memorandum, submitted jointly by the Association of American Universities, Association of Public and Land-grant Universities, and the Council on Governmental Relations, offers a comprehensive response to the National Institutes of Health’s (NIH) request for input on draft provisions for a Data Management and Sharing Policy for NIH-funded research. The associations commend NIH’s efforts to enhance data accessibility in federally funded research and detail their ongoing initiatives, such as workshops and reports, to facilitate effective data sharing and management frameworks. They highlight the inherent complexities of data management, emphasizing the need for continued dialogue and collaboration between universities and federal agencies, particularly through diverse and inclusive forums that can shape robust policy outcomes.
The memorandum acknowledges support for NIH's proposed definition of scientific data but urges greater clarity and guidance on standards for data, metadata, and data management plans. The associations express concern over logistical challenges, including the lack of expertise among researchers in data management, ambiguities surrounding long-term data stewardship post-grant, and the difficulty of estimating future data outputs in research planning. Recommendations include extending the implementation timeline to two years, considering reasonable cost allowances within grant proposals, and harmonizing data management requirements across federal agencies. The associations also advocate the creation of NIH-hosted repositories for disciplines lacking community infrastructure and call for flexibility in data compliance processes, particularly where unexpected changes arise. Overall, the memorandum stresses the importance of ongoing collaboration, clarity on policy provisions, and accommodations that recognize the evolving nature of research data management.
