The proposed provisions build on the agency’s efforts to make data arising from federally funded research more accessible to the public. The RFI sought input in three areas: types of data to be covered by the policy; data elements that must be included in data management and sharing plans; optimal timing for implementing a new data management and sharing policy to ensure compliance.
In its comments, FASEB highlighted its 2016 “Statement on Data Management and Access,” which presented guiding principles and recommendations to aid stakeholder efforts for advancing data management in the biological and biomedical sciences. FASEB also referred to comments submitted earlier this year in response to NIH’s draft Strategic Plan for Data Science. Two overarching concerns were raised by FASEB: community preparedness to ensure that key data are consistently findable, accessible, interoperable, and re-usable (FAIR); the need to strike a balance between data accessibility and administrative efforts so researchers are not deterred from sharing or reusing datasets.
While FASEB generally agreed with the proposed definition of “scientific data” as that which underlies publication, it also urged expanding it to recognize the importance of experiments yielding negative, and frequently unpublished, results. FASEB also recommended active engagement with the research community to develop a data management framework that is flexible and adaptable to the breadth of research activities supported by NIH.
Finally, FASEB suggested conducting a pilot to test reporting templates and guidance documents prior to broader roll-out, and a tiered approach for implementation to ensure community preparedness and compliance.