NIH has recently clarified that an institutional official or representative must be named as a contact for oversight of all data management and sharing plans. This individual will be Elizabeth Buchanan, Associate Vice-President, Research Administration (elizabeth.buchanan@uri.edu)

Ultimately, the PI and Study Team are responsible for all aspects of the DMSP, though URI as the recipient of funding must ensure that adherence to the plans is upheld, as with other compliance related activities. 

You must comply with the ICO-approved plan and document that compliance in the annual Research Performance Progress Report (RPPR). Non-compliance may result in enforcement action from the NIH such as

• Addition of special terms and conditions to the award
• Termination of the award

Non-compliance may also affect future funding decisions. To avoid possible issues when reporting progress, ensure that your submitted plan contains enough detail for the AVPR and program officer to be able to evaluate compliance.