Prior Approval Requests for Revisions to an Approved Data Management and Sharing (DMS) Plan Must be Submitted Using the Prior Approval Module
Notice Number:

Key Dates

Release Date:

September 27, 2023

Related Announcements

  • October 29, 2020 - Final NIH Policy for Data Management and Sharing. See Notice NOT-OD-21-013.

Issued by



The purpose of this Notice is to remind the extramural research community that any changes to an approved Data Management and Sharing Plan (DMS Plan) (for funded awards subject to the Final NIH Policy for Data Management and Sharing (DMS) Policy) requires the recipient to submit a timely formal prior approval request to the funding NIH Institute, Center, or Office (ICO). This notice also informs the community that recipients must submit these requests through the Prior Approval Module in eRA Commons. This functionality will be available for NIH grants effective October 12, 2023, and will be used exclusively for submitting requests for updating the DMS Plan. Emails and other communications are not acceptable.


Under the final NIH Policy for Data Management and Sharing (DMS Policy), NIH requires a recipient to comply with the DMS Plan as approved by the funding NIH ICO. If DMS Plan revisions are necessary (e.g., new scientific direction, a different data repository, or a timeline revision) Plans should be updated by recipients and reviewed and approved by the NIH ICO. All requests for NIH awarding ICO prior approval must be submitted by the Authorized Organization Representative (Signing Official (SO) role in eRA Commons) at least 30 days in advance of the requested change, and the currently approved DMS Plan remains in effect for the award until the request is approved by the funding NIH ICO.

Process for Submitting Prior Approval Requests

In the Prior Approval Module, recipients must Select Prior Approval Other Request and follow the instructions provided to complete the required entry. This functionality may only be used for revised DMS Plan prior approval requests.

The request must be submitted by a Signing Official.

Prior Approval Other Request Instructions

  • Description: Enter DMS Plan Revision (without quotations).
  • Effective Date: Enter the effective date of the requested changes.
  • Justification Document: Provide the rationale and justification for the requested changes.
  • Budget Document: Provide if the revised DMS Plan impacts the budget. Include information for current and future budget periods. Note: This is not a supplement request.
  • Other Supporting Documents: Attach the revised DMS Plan.

All uploaded documents must be in PDF format.



Please direct all inquiries to:

Office of Extramural Research (OER)

For technical issues related to the Prior Approval Module, please contact the
NIH eRA Service Desk at: