NCHR’s Comments on NIH Draft Policy on Data Sharing

National Center for Health Research, January 3, 2020

National Center for Health Research Public Comments on NIH’s Request for Public Comments on a DRAFT NIH Policy for Data Management and Sharing and Supplemental DRAFT Guidance

Thank you for the opportunity to comment on the draft Policy for Data Management and Sharing and associated draft guidances.

The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research, policies, and programs on a range of issues related to health and safety.  We do not accept funding from companies that make products that are the subject of our work.

We commend NIH for efforts to encourage data management and sharing.  Our Center has supported data sharing, and particularly for data funded by federal agencies or submitted to federal agencies as part of application materials to the FDA and other federal agencies.  Data sharing between scientists is an invaluable tool for confirming the accuracy of reported research findings and enabling other scientists to replicate results and understand any conflicting findings.  Taxpayers deserve to have NIH maximize the usefulness of the funds they’ve invested in research, through data sharing and other means.  We are confident that requiring responsible data management for NIH grant recipients will benefit the scientific community and the public.

Data sharing is an issue that has been debated and considered for several decades.  We understand that it takes time to finalize and implement these policies in an efficient and easy-to-use manner, in the meantime, NIH should require researchers to share their data with other researchers upon request.

National Center for Health Research can be reached at or at (202) 223-4000.