No. The policy only applies to new competing proposals and renewal applications, it does not retroactively apply. The effective date of the DMS Policy is January 25, 2023, including for:
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Competing grant applications that are submitted to NIH for the January 25, 2023 and subsequent receipt dates
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Proposals for contracts that are submitted to NIH on or after January 25, 2023
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NIH Intramural Research Projects conducted on or after January 25, 2023
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Other funding agreements (e.g., Other Transactions) that are executed on or after January 25, 2023, unless otherwise stipulated by NIH
Competing Continuations for projects existing prior to January 25th will require a DMSP if submitted on or after 1/25. Competing continuations go back into the pool of all applications vying for funding.
Non-competing continuations (yearly progress reports or RPPRs) for projects that started prior to January 25th do not require a DMSP. These projects do not go into the general pool of applications vying for funding.
Researchers applying for a competitive renewal for research generating scientific data will be expected to submit a DMS Plan at the time of the renewal funding application. If the previously awarded funding application was subject to the DMS Policy and included a Plan, applicants should update the Plan to be consistent with the proposed competitive renewal application.
Read more about competitive renewal applications.