NIH Data Management & Sharing

If the Data Management & Sharing (DMS) Plan is required in the proposed application:

• The DMS plan must be uploaded under the “Other Plans” attachment section.
  
• Needs to contain all the required elements and expectations per the DMS policy.
• Plans for Genomic Data Sharing (if applicable) should also be provided as part of the same DMS Plan attachment.
• Same formatting rules apply as with other NIH attachments. Currently, no formal page limit, but NIH policy website suggests that “DMS Plans are recommended to be two pages or less in length.”

Note: The Resource Sharing Plan attachment is not going away. NIH  just separated out the Data Management and Sharing Plan elements from that attachment. See General Application Guide (Forms-H or later) and Funding Opportunity Announcement for more details.

IMPORTANT: Always refer to the Funding Opportunity Announcement for any special, supplemental instructions for the DMS Plan that supercede the General Application Guide.

Investigators may request funds toward data management and sharing. Some reasonable, allowable costs that may be included are:

• Curating data
• Formatting data to required/accepted standards or for transmission to, or storage data a repository for long-term preservation or access
• Preparing metadata to foster discoverability, interpretation, and reuse
• Preserving and sharing data through established repositories, such as data deposit fees; if DMS Plan proposes deposition to multiple repositories, costs associated with each proposed repository may be included.
• Developing supporting documentation
• De-identifying data
• Local data management considerations (e.g., unique and specialized information infrastructure necessary to provide local management and preservation

Budgeting:
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. (For example, if the plan is to preserve and share data for 10 years in a repository with a deposition fee, the cost for the entire period must be paid before the end of the award period.)

Unallowable Costs

• Must not include infrastructure costs that are already part of Institutional Overhead (IDC); for example, Lane Library costs should not be budgeted since they are part of our IDC.
• Cannot include costs associated with routine conduct of research, including costs associated with collecting or gaining access to research data.
  

More Information

NOT-OD-21-015: Allowable Costs for Data Management and Sharing
NIH Data Management and Sharing Policy Website (Budgeting Page)

R&R Budget Form:
When filling out the R&R Budget Form:

DMS associated Costs should be placed under a single Other Direct Cost line item labeled “Data Management and Sharing Costs,” and should not mix any other costs under this line item.

• If a DMS Plan was submitted, but there are no costs associated, explicitly put “0” next to an Other Direct Cost item labeled "Data Management and Sharing Costs."
  
• Costs associated with Genomic Data Sharing (if applicable) should also go under this line item.
• Personnel costs specific to Data Management and Sharing activities must be included in this line item (instead of the personnel section). For example, if extra personnel effort is needed to specifically curate data for the project. The personnel section should reflect the effort and amount for the conduct of the Scope of Work.
  

For Modular Budgets, this is not a separate line item and the amount is still part of the modules. However, costs still need to be addressed in the Additional Narrative Justification document.

Budget Justification:
If the Data Management & Sharing Plan is required in the proposed application:

• In the budget justification attachment, include a justification for associated DMS costs under “Data Management and Sharing Justification” subheader/line item. (If no costs, specify there are “No anticipated costs.”)
• Include brief summary of type and amount of scientific data to be preserved and shared as well as the name of the established repository(ies) where they will be preserved and shared.
• Highlight general cost categories & include amounts and brief explanation (e.g., curating data & developing supporting documentation; local data management costs and activities, repository costs, etc.)
• Recommended length is no more than half a page for this specific justification.
• For Modular Budgets, similar information as above is needed, except the justification is provided in the Additional Narrative Justification attachment (separate attachment from the Personnel Justification attachment).
  

Plans are not part of the scored peer review criteria unless specifically noted in the Funding Opportunity Announcement. NIH Program Staff oversee review and approval of the DMS Plan prior to award.

If the DMS Plan that was proposed in the application cannot be approved based on the information provided, there will be a Just-in-Time process to resolve any issues or concerns, and may require submission of a revised DMS Plan.

If the plan is revised, this should be clearly documented internally so it is clear which version of the plan that the Investigator and Institution are required to comply with.

Should there be changes that need to occur during the award period that affect how data is managed or shared, Investigators will need to update the DMS Plan to reflect the changes and is subject to the funding NIH ICO approving the updated plan. It may be advisable to discuss potential changes with the Program Officer, first. If a formal change request is needed, make sure to notify your Institutional Official.