CMS' Extension Request Form Requirement

Effective August 11, 2026, CMS is implementing a new policy requiring an extension form to be submitted with every research (RIF and LDS) Data Use Agreement (DUA) extension request. This form must detail the status of your study and must accompany all Researcher DUA extension submissions.

CMS is implementing this requirement to enhance oversight of DUA extensions and ensure compliance with applicable laws and policies. To extend a DUA, you must provide information to CMS on the status of your study, links to publications and/or the plans to publish the study's findings.

CMS research DUAs are approved for one year. At the end of the approval period, the DUA must either be extended or closed. If extending your DUA, you must complete and submit the DUA Extension Request Form with your extension request.

To request an extension, please visit the ResDAC website for instructions.

Organizations that do not submit the extension form will not receive an extension of their DUA. DUAs that are not extended by the set expiration date will be in violation of CMS policy. If a DUA expires, all DUAs held by the requesting organization will be frozen, blocking all actions to request new DUAs, update existing DUAs, and extend existing DUAs. Organizations may also face the following consequences:

• CMS may require the requesting organization to submit a Corrective Action Plan (CAP). This plan must be approved by CMS before access is reinstated.
• Continued non-compliance can result with forced closure of DUAs, destruction of data, and being prohibited from future participation in CMS' research data disclosure program.