NIH Data Management and Sharing Policy: Plan Details

Six Elements of a Data Management and Sharing Plan 

• Data type 

• Related tools, software, and/or code 

• Data standards 

• Data preservation, access, associated timelines 

• Access, distribution, or reuse consideration 

• Oversight of data management & sharing

NIH has developed an optional DMS Plan format page that aligns with the recommended elements. Access the Word document here.

For additional perspective on language to be included regarding "Informed Consent" see the following resource:
Informed Consent for Secondary research with Data and Biospecimens: Points to Consider and Sample Language for Future Use and/or Sharing.

A particular challenge related to Human/Biospecimen Subject Research is how to handle retrospective research protocols. For questions regarding sharing of data related to Retrospective Research Protocols, please contact IRB/PB Submissions.

NIH application budgets may request funding for permissible costs associated with data management and sharing. Costs may include personnel costs, curation costs, data deposit fees, and long-term data preservation costs. All costs budgeted must meet the criteria for allowability consistent with both NIH and federal guidelines and cost principles. 

Important note: Any costs requested to support complying with the NIH Data Management and Sharing (DMS) Policy must be incurred during the project period, including for allowable costs related to scientific data and metadata preserved and shared beyond the award period. For example, costs for long term storage and data management activities may be requested, and the cost of the storage must be paid before the grant ends.  

Reasonable, Allowable Costs 

• Curating data 

• Developing supporting documentation 

• Formatting data according to accepted community standards, or for transmission to and storage at a selected repository for long-term preservation and access 

• De-identifying data 

• Preparing metadata to foster discoverability, interpretation, and reuse 

• Local data management considerations, such as unique and specialized information infrastructure necessary to provide local management and preservation (for example, before deposit into an established repository). 

• Preserving and sharing data through established repositories, such as data deposit fees. (If the DMS plan proposes deposition to multiple repositories, costs associated with each proposed repository may be included.) 

Unallowable Costs 

• Infrastructure costs that are included in institutional overhead [for example, Facilities and Administrative costs (F&A)] 

• F&A, or indirect, costs are costs that cannot be readily attributed to a specific project. These costs are incurred for a common purpose benefitting more than one objective, such as utilities, facilities, maintenance, depreciation, and administrative expenses. 

• Costs associated with the routine conduct of research, including costs associated with collecting or gaining access to research data 

• Costs that are double charged or inconsistently charged as both direct and indirect costs 

Requesting Costs 
DMS costs should be listed as a single Other Direct Costs line item, labeled “Data Management and Sharing Costs” on the application budget. A brief summary of the DMS plan, inclusive of a description of any requested DMS costs, must be outlined in the application budget justification and should be no more than half a page. 

For Modular Budgets only, please use the “Additional Narrative Justification” document to provide this required justification, in addition to any other relevant items that should be included in the Additional Narrative Justification, per NIH guidelines.   

A resource from the National Academies of Sciences, Engineering, and Medicine which might be useful in determining how to plan for costs from data management is Forecasting Costs for Preserving, Archiving, and Promoting Access to Biomedical Data as well as this user's guide.