Response to the NIH “Request for Information on Recommendations for Improving NRSA Fellowship Review”

Thank you for your work to improve the process of fellowship review for National Research Service Award (NRSA) fellowship applications, and for soliciting public input on this matter. In general, your proposed changes are a large improvement for the NRSA fellowship application and review process. The current proposal, however, lacks a consideration of data management and sharing. This works against current NIH-wide and government-wide efforts to improve the quality of data management and sharing throughout federally funded research.

NIH should require fellowship applications to have Data Management and Sharing Plans just like other applications for NIH support. Data management and sharing is something that must be performed by the entire scientific workforce. It is not something that can be left only to senior researchers, which is the impression one gets from exempting fellowship applications from the requirement of Data Management and Sharing Plans. Requiring Data Management and Sharing Plans from researchers at the beginning of their scientific careers will spur them to think deeply from the outset about how to perform excellent data management and sharing. It would motivate a change in culture that NIH and the White House Office of Science and Technology Policy have acknowledged is necessary.

Data Management and Sharing Plans should also be scored as part of the Science and Scientific Resources criterion. Not including this gives the impression that it is a secondary factor worth little consideration. An excellent Data Management and Sharing Plan is essential to the quality and impact of the planned science. It will give reviewers another chance to see how carefully applicants and their mentorship team have considered appropriate aspects of their research plan. Giving priority to those applications that will have excellent data management and sharing better leverages limited NIH funds.

Furthermore, skills in data management should be specifically mentioned as an example of scientific skills in the Training Plan and Training Resources criterion.

The changes suggested in this letter will help NRSA fellowship programs work in concert with existing NIH and government-wide initiatives to improve data management and sharing. I hope you will consider implementing them while you are already revising fellowship application and review processes. It is the right time to improve the handling of data management and sharing in NIH fellowship support.

Thank you again for your work on this important aspect of training the next generation of researchers.