Data Management & Sharing Plan

NIH requirement effective January 25, 2023.

The below information was modiefied and adapted directly from the NIH website.

Data management is the process of validating, organizing, protecting, maintaining, and processing scientific data to ensure the accessibility, reliability, and quality of the data for its users.

Proper data management helps maintain scientific rigor and research integrity. Keeping good track of data and associated documentation lets researchers and collaborators use data consistently and accurately. Carefully storing and documenting data also allows more people to use the data in the future, potentially leading to more discoveries beyond the initial research.

NIH emphasizes the importance of good data management practices and encourages data management to be reflective of practices within specific research communities.

DMPTool SMHS Instructions

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Writing a Data Management & Sharing Plan

DMS plans should be no more than two pages and include the following elements:

1. Data Type:

Describe the scientific data to be managed and shared.
Summarize the types and amount of scientific data that will be generated or used.
Outline which scientific data will be preserved and shared and explain the reasons for this.
Create a brief list of metadata or any other associated documentation that will be used to facilitate the interpretation of data being used.

2. Related Tools, Software and/or Code

Outline whether any specialized tools will be used fir collecting or using any scientific data.

3. Standards

If there are any standards being applied to the scientific data being used, describe them.

4. Data Preservation, Access, and Associated Timelines

Name any repositories where any scientific data from a project will be archived.
Specify the unique identifier or other indexing mechanism that will be associated with the data and make it searchable.
Address when the data will be searchable and for how long.

5. Access, Distribution, or Reuse Considerations

Describe any factors that might affect access, distribution, or reuse of the scientific data being used or generated. This might include the following:
- Informed consent
- Privacy or confidentiality protections
- Control and access of human scientific data
- Restrictions or limitations

6. Oversight of Data Management and Sharing

Specify how the data management sharing plan will be managed and maintain compliance and who will be responsible for this oversight.

Budgeting for Data Management & Sharing

NIH recognizes that making data accessible and reusable for other researchers may incur costs. For that reason, investigators may request funds toward data management and sharing in the budget and budget justification sections of their applications.

Allowable Costs

Curating data
Developing supporting documentation
Formatting data, storage of data, or long-term preservation of data
De-identifying data
Preparing metadata
Local data management
Preserving and sharing data through repositories

Unallowable Costs

Infrastructure costs that are included in institutional overhead.
Costs associated with the routine research conduct, such as collecting research or getting access.
Costs that are double charged or inconsistently charged as both direct and indirect costs.

Requesting & Justifying Costs for Data Management and Sharing

To be included:
- A line item in the budget form
- A brief summary of the DMS plan and a description of DMS costs
- Label costs "Data Management and Sharing Costs"
- Label justification of costs "Data Management and Sharing Justification"

NIH Grants Policy Statement

8.4.2 Record Retention and Access - Revised December 2022

Recipients generally must retain financial and programmatic records, supporting documents, statistical records, and all other records that are required by the terms of a grant, or may reasonably be considered pertinent to a grant, for a period of 3 years from the date the annual FFR is submitted. For awards under SNAP (other than those to Federal institutions), the 3-year retention period will be calculated from the date the FFR for the entire competitive segment is submitted. Those recipients must retain the records pertinent to the entire competitive segment for 3 years from the date the FFR is submitted to NIH. Federal institutions must retain records for 3 years from the date of submission of the annual FFR to NIH. See 2 CFR Part 200.334 and 45 CFR Part 75.361 for exceptions or qualifications to the 3-year retention requirement exist (e.g., if any litigation, claim, financial management review, or audit is started before the expiration of the 3-year period), the records must be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken). Maintain the information for the retention period for other types of grant-related records, including F&A cost proposals and property records. See 2 CFR Part 200.334 and 45 CFR Part 75.361 and 2 CFR Part 200.337 and 45 CFR Part 75.364 for record retention and access requirements for contracts under grants.

These record retention policies apply to both paper and electronic storage of applicable information, including electronic storage of faxes, copies of paper document, images, and other electronic media. Institutions that rely on an electronic storage system must be able to assure such a system is stable, reliable, and maintains the integrity of the information. When storing electronic images of paper documents, the system must also assure a full, complete, and accurate representation of the original, including all official approvals.

NIH, Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their authorized representatives, must have the right of access to any documents, papers, or other records of the non-Federal entity which are pertinent to the NIH award, to make audits, examinations, excerpts, and transcripts. The right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and discussion related to such documents. The rights of access in this section are not limited to the required retention period but lasts as long as the records are retained. Pass-through entities must not impose any other access requirements upon non-Federal entities.

Frequently Asked Questions

A.Policy Scope

1. How does the DMS Policy fit in with other NIH data sharing policies and requirements (e.g., individual NIH Institute/Center or Office (ICO) funding polices, the NIH Genomic Data Sharing (GDS) Policy, the NIH Policy on Dissemination of NIH-Funded Clinical Trial Information)?

The DMS Policy establishes the foundation for NIH’s data management and sharing expectations, which NIH ICOs and programs may build upon to meet their programmatic needs (e.g., designated repositories, specific data collection standards). Current NIH policies specific to certain types of research (e.g., clinical trials, research generating large-scale genomic data) continue to apply and complement the goals of the new DMS Policy. In the event that another applicable policy has more detailed expectations than that of the DMS Policy, those expectations should be followed in addition to the DMS Policy. Researchers and award recipients are advised to consult with the funding NIH ICO on how to comply with all applicable data sharing policies potentially affecting their NIH-supported research project.

(Updated 1/25/22)

2. How does the DMS Policy interact with the data sharing expectations of other research partners (e.g., other funding agencies, collaborators)?

Award recipients are responsible for ensuring that any research partnerships allow for compliance with the DMS Policy. Data sharing expectations should be established prior to the initiation of a partnership, whenever feasible, and any limitations to sharing should be described in Plans. Researchers and award recipients are advised to consult with the funding NIH ICO on how to comply with all applicable data sharing policies potentially affecting their NIH-supported research project.

(Updated 1/25/22)

3. Are projects establishing repositories or creating data infrastructure subject to the DMS Policy (i.e., establishing a data coordinating center with no research question proposed)?

No. Projects that only develop or support infrastructure resources (e.g., repository or knowledgebase establishment) and do not generate findings or scientific data are not subject to the DMS Policy. However, NIH recommends that the infrastructure developed with NIH resources comport with the desired characteristics for repositories (see “Selecting a Repository for Data Resulting from NIH-Supported Research”).

(Updated 1/25/22)

4. Does the DMS Policy apply to training activities, including Training Programs (e.g., Ts, D43) and Fellowship Programs (Fs)?

No. The DMS Policy does not apply to awards for Training Programs (e.g., Ts, D43) and Fellowship Programs (Fs); however, Research Career Programs (Ks) are subject to the DMS Policy. While Training and Fellowship Programs are not subject to the DMS Policy, NIH encourages trainees and fellows to consider integrating data management and sharing practices into their activities if appropriate. Please see a complete list of NIH activity codes subject to the DMS Policy.

For other activity codes subject to the DMS Policy that also include a training or infrastructure development component, applicants are only expected to address in Plans the sharing of scientific data generated in the course of their research. Applicants are not expected to address in their Plans the sharing of scientific data generated during training or infrastructure development.

(Updated 12/20/2022)

B.Managing and Sharing Scientific Data

1. Am I expected to share all data generated during my research?

No. Under the DMS Policy, researchers are expected to maximize the appropriate sharing of scientific data, which is defined as data commonly accepted in the scientific community as being of sufficient quality to validate and replicate the research findings.

Not all data generated during NIH-supported research will constitute scientific data under the DMS Policy. Specifically, the DMS Policy does not expect researchers to share:

Data that are not necessary for or of sufficient quality to validate and replicate the research findings,
Laboratory notebooks,
Preliminary analyses that are not necessary for or of sufficient quality to validate and replicate the research findings,
Completed case report forms,
Drafts of scientific papers,
Plans for future research,
Peer reviews,
Communications with colleagues, or
Physical objects, such as laboratory specimens.

Importantly, not all scientific data may be appropriate to share. See the FAQ “What are justifiable reasons for limiting sharing of data?” for examples of potentially justifiable factors limit sharing of scientific data.

NIH Institutes, Centers, or Offices (ICOs), notices of funding opportunities (NOFOs), funding opportunities, and other NIH policies (e.g., the Genomic Data Sharing Policy) may have additional expectations for what data should be shared. Additionally, see the FAQ “If researchers are reusing existing, shared data to generate new datasets, are they expected to reshare the primary data they incorporated into their new analysis?” for more information on the DMS Policy’s expectations for sharing primary data accessed during the course of a study.

(Updated 7/26/22)

2. When should scientific data be shared?

Scientific data should be made accessible as soon as possible, and no later than the time of an associated publication or the end of the performance period of the extramural award that generated the data. Specifically, the DMS Policy expects scientific data to be shared by the earlier of two timepoints:

The time of an associated publication: Scientific data underlying peer-reviewed journal articles should be made accessible no later than the date on which the article is first made available in print or electronic format.

The end of the performance period: Scientific data underlying findings not disseminated through peer-reviewed journal articles should be shared by the end of the performance period unless the grant enters into a no-cost extension. If a no cost extension is permitted, then the recipient should share the data by the end of the extended performance period. These scientific data may underlie unpublished key findings, developments, and conclusions; or findings documented within preprints, conference proceedings, or book chapters. For example, scientific data underlying null and negative findings are important to share even though these key findings are not always published. Researchers should be aware that some preprint servers may require the sharing of data upon preprint posting, and repositories storing data may similarly require public release of data upon preprint posting.

See the FAQ “Do SBIR/STTR projects have to share scientific data under the DMS Policy?” for more information on the data sharing expectations for SBIR/STTR awards.

NIH Institutes, Centers and Offices (ICOs), notices of funding opportunities (NOFOs), funding opportunities, and other NIH policies (e.g., the Genomic Data Sharing Policy) may specify earlier expectations for data sharing timelines, in which case, the data should be made available as required by those expectations.

(Updated 7/26/22)

3. Does the timeline for sharing scientific data change in the event of a no cost extension?

If a no cost extension is granted for an extramural award, scientific data should be made accessible no later than the time of an associated publication, or the end of the no cost extension, whichever comes first.

(Updated 7/26/22)

4. How will researchers be expected to comply with the DMS Policy in the event of a competitive renewal?

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.

When a competitive renewal is successful, it may be appropriate to extend the sharing of scientific data into the new competitive renewal period (for example, for longstanding research projects with an established data deposition schedule that has been approved by the funding ICO). At the time of the competitive renewal application, researchers should update the Plan to address scientific data that were not shared during the initial award and scientific data that are anticipated to be generated if the competitive renewal is awarded. Plans should include updated timelines for sharing scientific data should the renewal be successful. If the competitive renewal is not awarded, applicants will be expected to comply with the previously approved Plan from the initial award period.

(Updated 12/20/22)

5. What are justifiable reasons for limiting sharing of data?

NIH expects that researchers will take steps to maximize scientific data sharing, but may acknowledge in Plans that certain factors (i.e., ethical, legal, or technical) may necessitate limiting sharing to some extent. Foreseeable limitations should be described in DMS Plans. Per the supplemental information “Elements of an NIH Data Management Sharing Plan,” a compelling rationale for limiting scientific data sharing should be provided and will be assessed by NIH. Potential examples of justifiable factors include:

informed consent will not permit or will limit the scope or extent of sharing and future research use
existing consent (e.g., for previously collected biospecimens) prohibits sharing or limits the scope or extent of sharing and future research use
privacy or safety of research participants would be compromised or place them at greater risk of re-identification or suffering harm, and protective measures such as de-identification and Certificates of Confidentiality would be insufficient
explicit federal, state, local, or Tribal law, regulation, or policy prohibits disclosure
restrictions imposed by existing or anticipated agreements (e.g., with third party funders, with partners, with repositories, with Health Insurance Portability and Accountability Act (HIPAA) covered entities that provide Protected Health Information under a data use agreement, through licensing limitations attached to materials needed to conduct the research)
datasets cannot practically be digitized with reasonable efforts

Examples of reasons that would generally not be justifiable factors limiting scientific data sharing include:

data are considered to be too small
data that researchers anticipate will not be widely used
data are not thought to have a suitable repository

See the FAQ “If researchers are reusing existing, shared data to generate new datasets, are they expected to reshare the primary data they incorporated into their new analysis?” for more information on the DMS Policy’s expectations for sharing primary data accessed during the course of a study.

NIH respects and recognizes Tribal sovereignty and American Indian and Alaska Native (AI/AN) communities’ data sharing concerns, and NIH has proposed additional considerations when with working with Tribes in the draft supplemental information on “Responsible Management and Sharing of AI/AN Participant Data.”

(Updated 7/26/22)

6. Do SBIR/STTR projects have to share scientific data under the DMS Policy?

Under the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Program Policy Directive, SBIR and STTR awardees may withhold applicable data for 20 years after the award date, as stipulated in the specific SBIR/STTR funding agreement and consistent with achieving program goals.

(Updated 1/25/22)

7. If researchers are reusing existing, shared data to generate new datasets, are they expected to reshare the primary data they incorporated into their new analysis? Are the derived data generated considered scientific data and expected to be shared?

The DMS Policy applies to research that results in the generation of scientific data. Scientific data can result from secondary research, but researchers are not expected to share the existing, shared primary data used to conduct the secondary research. Researchers are, however, expected to maximize appropriate sharing of any new, derived data generated as a result of their research. Note that use of data obtained from repositories or other sources and derived data may be subject to limitations on sharing as a condition of access, which is a justifiable reason for limiting sharing under the DMS Policy (see FAQ “What are justifiable reasons for limiting sharing of data?”).

(Updated 7/26/22)

8. Does the DMS Policy apply to social and behavioral scientific research? Can qualitative data be “scientific data”?

Yes, NIH-supported social and behavioral scientific research that results in the generation of scientific data are subject to the DMS Policy. Qualitative data may constitute scientific data if it meets the definition in the DMS Policy. See FAQs relating to which data should be shared and justifiable limitations to sharing scientific data for additional considerations for sharing qualitative data.

(Updated 7/26/22)

9. Does the DMS Policy expect sharing of data generated using fundamental basic science techniques (e.g., western blots, electrophoretic gels, flow cytometry)? If so, where should these data be shared?

Yes. Under the DMS Policy, researchers are expected to maximize the appropriate sharing of scientific data, which is defined as data commonly accepted in the scientific community as being of sufficient quality to validate and replicate the findings, regardless of the technique utilized. In some cases, data generated using fundamental basic science techniques may not be considered scientific data. For example, data generated from optimizing a protocol that does not support a research finding may not constitute scientific data and therefore may not be expected to be shared. See the FAQ “When should scientific data be shared?” and “Am I expected to share all data generated during my research?” for additional information.

NIH strongly encourages the use of established repositories to the extent possible for preserving and sharing scientific data. Options for sharing these data types include discipline or data-type specific repositories, or other repositories, including generalist repositories. For more information, please see Supplemental Information “Selecting a Repository for Data Resulting from NIH-Supported Research” and a list of NIH-supported scientific data repositories.

(Updated on 10/20/2022)

10. Should multiple DMS Plans be submitted with each application for funding, including large, multicomponent awards?

No. The DMS Policy expects only one DMS Plan to be submitted with each application and does not expect separate Plans to be developed for individual projects under that application. In multicomponent applications, the DMS Plan must be in included in the Overall component. Applicants are encouraged to determine whether and how to coordinate responsibilities with respect to Plans with all Program Directors/Principal Investigators and all Key Personnel on the same application.

(Updated on 12/20/2022)

11. Are applications for awards that support a variety of activities or generate many data types limited to a DMS Plan of two pages or less?

No. Some research projects may propose a larger number of activities or generate a larger number of data types, which may necessitate more detail in a DMS Plan. NIH provides an optional DMS Plan format page, but use of this format page is not required. NIH will accept DMS Plans longer than the recommended two pages as long as Plans provide sufficient information for NIH program staff to assess the Plan. Please see supplemental information “Elements of an NIH Data Management and Sharing Plan” for more information.

(Updated on 10/20/2022)

12. When should NIH-funded ancillary studies share data under the DMS Policy when the parent award is not subject to the DMS Policy?

Different NIH policies, guidance, Institutes, Centers, or Offices (ICOs) may define ancillary studies differently. For the purposes of this FAQ, an NIH-funded ancillary study is an adjunctive or supplementary study to an ongoing (“parent”) study when the parent study and the ancillary study are supported by separate NIH awards. An ancillary study may or may not be a clinical trial and may or may not involve collecting new data or biospecimens. Ancillary studies can generate scientific data.

Applications for new and competing NIH-funded ancillary studies otherwise subject to the DMS Policy submitted on or after January 25, 2023, are expected to comply with the DMS Policy, including submitting Data Management and Sharing Plans. However, ancillary studies that are subject to the Policy prior to the parent study are not expected to share scientific data if it would conflict with the sharing policies or plans of the parent study or agreements entered into with the parent study. As with any limitations on sharing, data sharing limitations that stem from agreements between parent and ancillary studies should be described in Plans. However, sharing of data from ancillary studies regardless of the parent award status may still be expected by other NIH policies, such as the Genomic Data Sharing Policy and ICO policies, or as stipulated in funding agreements.

(Updated on 12/20/2022)

13. How should DMS Plans be prepared when the application is for a large data-generating resource (e.g., core facilities)? What does the DMS Policy expect for research supported by other awards that collaborate with experts from the resource or use data generated by the resource?

The DMS Policy expects only one DMS Plan to be submitted for each application, including for multi-component applications. Applicants are encouraged to determine whether and how to coordinate Plans with all Program Directors/Principal Investigators and all Key Personnel on the same application.

Research not supported or conducted by NIH that is conducted in collaboration with experts from NIH-supported resources (e.g., core facilities) or uses data generated by the resource is not subject to the DMS Policy. However, the NIH ICO funding the resource, or data use agreements may specify expectations for sharing data. See also the FAQ “If researchers are reusing existing, shared data to generate new datasets, are they expected to reshare the primary data they incorporated into their new analysis? Are the derived data generated considered scientific data and expected to be shared?”

(Updated on 12/20/2022)

14. Do administrative supplements and competing revisions (i.e., Type 3s) need to include a separate Data Management and Sharing Plan?

No. Administrative supplements and competing revisions are not subject to the DMS Policy. However, if an awarded supplement request, including competing revision, changes the parent award’s approved approach to data management and sharing, the DMS Plan of the parent award should be updated.

(Updated on 12/20/2022)

C.Considerations for Scientific Data Derived from Human Participants

1. What steps does the DMS Policy take to ensure institutions and researchers protect research participants?

Award recipients must comply with any applicable laws, regulations, statutes, guidance, or institutional policies related to research with human participants and that protect participants’ privacy. The DMS Policy encourages respect for participants by encouraging researchers and award recipients to:

Address data management and sharing plans during the informed consent process to ensure prospective participants understand how their data will be managed and shared;
Outline steps they will take for protecting the privacy, rights, and confidentiality of prospective participants (i.e., through de-identification, Certificates of Confidentiality, and other protective measures);
Assess limitations on subsequent use of data and communicate these limitations to the individuals or entities (e.g., repositories) preserving and sharing the data; and
Consider whether access to shared scientific data derived from humans should be controlled, even if de-identified and lacking explicit limitations on subsequent use. Sharing via controlled access may be specified by certain funding opportunities or the funding NIH ICO(s).

(Updated 1/25/22)

2. Does the DMS Policy expect that research informed consent obtained from research participants must allow for broad sharing and the future use of data (either with or without identifiable private information)?

No. Informed consent for participation in research remains the cornerstone of trust between researchers and research participants and thus the DMS Policy does not dictate how this process is achieved. Rather, researchers’ intention for scientific data management and sharing, as proactively described in Plans, is strongly encouraged to be part of the informed consent process. The DMS Policy does not expect that informed consent given by participants will be obtained in any particular way. For example, a study may plan to utilize consent for broad sharing of identifiable private information (e.g., the broad consent provision of the Common Rule at 45.CFR.46.116(d))) but it is not required by the DMS Policy.

As a resource for the community, NIH has developed a resource for developing informed consent language in research studies where data and/or biospecimens will be stored and shared for future use.

Researchers also should be aware that they may be subject to other requirements or particular expectations, for consent, such as the NIH Genomic Data Sharing Policy.

(Updated 7/26/22)

D.Compliance and Enforcement

1. How will noncompliance with the NIH DMS Policy be handled?

NIH will monitor compliance with Plans over the course of the funding period during regular reporting intervals (e.g., at the time of annual Research Performance Progress Reports (RPPRs)). Noncompliance with Plans may result in the NIH ICO adding special Terms and Conditions of Award or terminating the award. If award recipients are not compliant with Plans at the end of the award, noncompliance may be factored into future funding decisions.

For contracts, noncompliance with the DMS Plan will be handled in accordance with the terms and conditions of the contract and applicable Federal Acquisition Regulation (FAR).

(Updated 8/08/22)

E.Contracts

1. What is the effective date of the DMS Policy (NOT-OD-21-013) for contracts?

The DMS Policy (NOT-OD-21-013) applies to proposals submitted on or after January 25, 2023.

For contract implementation, the NIH Document Generation System (DGS) language regarding the policy shall be included in all solicitations released as of July 1, 2022, with an original proposal receipt date of January 25, 2023, or after. The Policy will not apply to solicitation amendments that result in proposal receipt extensions resulting in proposal submission to NIH on or after January 25, 2023 or beyond.

The NIH Data Sharing Policy NOT-OD-03-032, dated February 26, 2003, will remain applicable to proposals received prior to January 25, 2023, and contracts resulting from those proposals.

Contracting officers should ensure the DGS language for either NOT-OD-21-013 or NOT-OD-03-032 as applicable is included in all solicitations.

(Updated 8/08/22)

2. When should DMS Plans be submitted and deemed acceptable for a contract?

The DMS Plan must be submitted with the proposal provided by the offeror. In contrast to the Data Sharing Policy NOT-OD-03-032, the DMS Plan must be deemed acceptable prior to contract award.

(Updated 8/08/22)

3. How will NIH evaluate the DMS Plan, prior to contract award?

The evaluation of DMS Plans will be conducted by the agency, with input from the Contracting Officer’s Representative (COR) and other NIH subject matter experts as part of the proposal evaluation process.

(Updated 8/08/22)

4. How would a post-award revision to a DMS Plan be handled?

In accordance with the COR’s technical monitoring responsibilities, the COR would evaluate the post-award revision, in order to determine whether it is still considered acceptable.

(Updated 8/08/22)

5. If the offeror has questions prior to contract award, who should they contact?

Prior to contract award all questions/comments regarding the solicitation or award, including the DMS Plan, shall be submitted to the Contracting Officer (CO) referenced in the solicitation.

(Updated 8/08/22)

6. When is the data obtained through research projects expected to be shared?

Scientific data should be made accessible as soon as possible, and no later than the time of an associated publication or the end of the period of performance, whichever comes first. The DMS Policy expects scientific data to be shared at the earlier of:

The time of an associated publication: Scientific data underlying peer-reviewed journal articles should be made accessible no later than the date on which the peer-reviewed article is first made available in print or electronic format.
The end of the performance period: Scientific data underlying findings not disseminated through peer-reviewed journal articles should be shared as soon as possible and no later than the end of the performance period. These scientific data may underlie unpublished key findings, developments, and conclusions; or findings documented within preprints, conference proceedings, or book chapters. For example, scientific data underlying null and negative findings are important to share even though these key findings are not always published. Researchers should be aware that some preprint servers may require the sharing of data upon preprint posting, and repositories storing data may similarly require public release of data upon preprint posting.

NIH Institutes, Centers and Offices (ICOs), funding opportunities, and other NIH policies (e.g., the Genomic Data Sharing Policy) may specify earlier expectations for data sharing timelines, in which case, the data should be made available as required by those expectations. To ensure compliance with the DMS Plan, COs shall include the timeframe for data sharing in all applicable contract deliverables.

(Updated 8/08/22)

7. How will an offeror’s history or experience of data sharing or lack thereof be considered for future contracts?

The DMS Policy, NOT-OD-21-013 states, “after the end of the funding period, non-compliance with the NIH ICO-approved Plan may be taken into account by NIH for future funding decisions for the recipient institution.” Within contracts, enforceability of the DMS Plan does not extend beyond the period of performance of the contract. COs are encouraged to use alternative means of evaluating an offeror’s history of data management and sharing outside the performance period of a contract. For example, CO’s could provide the DMS questionnaire (data management and sharing history) to offerors in solicitations and use Contractor Performance Assessment Reporting System (CPARS) to capture DMS during contract performance.

(Updated 8/08/22)

F.Budget/Costs

1. How do I reflect data management and sharing (DMS) costs in the detailed R&R Budget form of my application?

All direct costs for data management and sharing activities, including personnel costs specific to those activities, must be included in the single line item on the budget form.

The line item must be titled "Data Management and Sharing Costs" (without quotation marks but following exact phrasing and spacing). Do not combine DMS costs with any "Other" costs. If no cost will be incurred, enter "0" in the "Funds Requested" column.

Supporting details must be outlined in the budget justification attachment in a section clearly labeled "Data Management and Sharing Justification". The recommended length of the justification should be no more than half a page.

See the application guide instructions for the R&R Budget Form for additional details.

(Updated 2/2/23)

2. How do I reflect data management and sharing (DMS) costs using the modular budget form?

Use the Additional Narrative Justification attachment in the PHS 398 Modular Budget Form and include a section clearly labeled "Data Management and Sharing Justification" followed by the requested dollar amount. If no cost will be incurred, enter "0" for the requested dollar amount. Also include a brief justification of the proposed activities that will incur costs.

See the application guide instructions for the R&R Budget Additional Narrative Justification attachment for additional details.

(Updated 2/2/23)

3. How do I include data management and sharing (DMS) costs incurred by subawards within my application?

DMS costs for each subaward must be listed as a single line item on the R&R Budget for the subaward (F. Other Direct Costs, 8-17 Other). If no DMS costs are anticipated on the subaward, the line item is not required. A DMS costs line item must still be listed on the project/parent R&R Budget Form for the parent DMS costs, including $0 if no costs are anticipated for the parent.

For complex grant applications that involve an overall budget and multiple project/core budgets, DMS costs must be included within the applicable component(s), as outlined in the application instructions.

For grant applications submitting a modular budget, include all DMS costs request information in the Additional Narrative Justification attachment on the PHS 398 Modular Budget Form, as outlined in the application instructions.

(Corrected 2/15/23)

4. What do I do if I don’t anticipate any direct costs associated with implementing my Data Management and Sharing Plan?

If there are no anticipated data management and sharing costs, this should be noted in the budget justification. Also include a line item titled "Data Management and Sharing Costs" in section F. Other Direct Costs of the R&R Budget Form and enter “0" in the "Funds Requested" column.

(Updated 2/2/23)

5. What should I include in the budget justification summary regarding data management and sharing (DMS) costs?

In a section clearly labeled "Data Management and Sharing Justification" include the requested dollar amount (enter "0" for the requested dollar amount if no cost will be incurred) and a brief justification of the proposed activities that will incur costs.

Provide a summary of type and amount of scientific data to be preserved and shared and the name of the established repository(ies) where they will be preserved and shared. Indicate general cost categories such as curating data and developing supporting documentation, local data management considerations, preserving and sharing data through established repositories, etc., including an amount for each category and a brief explanation. The recommended length of the justification should be no more than half a page.

See the application guide instructions for the Budget Justification attachment in the R&R Budget Form and the Additional Narrative Justification attachment in the PHS 398 Modular Budget Form.

(Updated 2/2/23)

6. How do I budget effort for personnel whose duties are included and budgeted as part of the Data Management and Sharing Plan?

All costs for data management and sharing activities, including personnel costs, must be included in the single line item on the R&R Budget Form in section F. Other Direct Costs. This includes the salary and fringe benefits corresponding to the time it takes personnel to undertake data activities (e.g., formatting, curating, developing supporting documentation).

Do not include personnel costs related to data management and sharing activities in section A. Senior/Key Person or section B. other Personnel.

Supporting details, including a breakdown of any personnel effort, must be included in the budget justification.

(Updated 2/2/23)

7. Can I include subscription fees to an electronic lab notebook system as an allowable cost under the data management and sharing budget line item?

A subscription fee to a cloud-based electronic lab notebook system (e.g., system that stores in a structured manner research protocols, notes, experimental data, results, and metadata) can only be charged as a direct cost if the system is being used solely to advance work under that project. If the notebook system is used for the benefit of the entire lab, or many projects, it is an indirect cost, and may not be charged as a direct cost.

See Budgeting for Data Management & Sharing for additional information on allowable and unallowable costs.

(Updated 2/2/23)

8. Can the data management and sharing costs listed in my budget include the cost of long-term preservation and sharing beyond the award period?

All allowable costs submitted in budget requests must be incurred (e.g., curation fees, data repository fees) during the performance period, even for scientific data and metadata preserved and shared beyond the award period.

Reasonable, allowable costs may be included in NIH budget requests when associated with curating data and developing supporting documentation, local data management considerations, and preserving and sharing data through established repositories.

See NOT-OD-21-015: Supplemental Information to the NIH Policy for Data Management and Sharing: Allowable Costs for Data Management and Sharing for additional details.

(Updated 2/2/23)

9. Are allowable data management and sharing costs included in the $250,000 cap for modular budgets?

Yes. If the total direct costs, including data management and sharing costs, exceed $250,000 in any budget period then a modular budget may not be used.

(Updated 2/2/23)

10. Are data management and sharing costs included in determining whether prior agreement is needed from an Institute/Center to accept assignment of an application with $500,000 or more in direct costs?

Yes. Data management and sharing costs are included as direct costs. Applicants must seek agreement to accept assignment from Institute/Center staff at least 6 weeks prior to the anticipated submission of any application when the total direct costs (excluding consortium F&A costs) are $500,000 or more in any budget period.

See NIH Grants Policy Statement, Section 2.3.7.2 Acceptance for Review of Unsolicited Applications Requesting $500,000 or More in Direct Costs for additional policy information.

(Updated 2/2/23)

11. Do I need to submit a Data Management and Sharing Plan with a non-competitive renewal?

No, the DMS policy does not apply to non-competitive renewals (Type 5), only competing (Type 1 & 2) applications.

(Updated 2/2/23)

12. Are there any additional post-award financial reporting requirements associated with the Data Management and Sharing Policy?

At this time there are no additional financial reporting requirements related to Data Management and Sharing. Reporting must be done as outlined in the Federal Financial Report (FFR) instructions. Internally, recipients should track expenditures in accordance with their institutional policies.

(Updated 2/2/23)

13. How will NIH factor in data management and sharing costs when making recommendations for funding?

NIH recognizes that data sharing costs may impact award budgets. Institutes and centers will consider these costs when reviewing and approving award budgets, in line with their priorities and the availability of funds.

(Updated 2/2/23)