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NIH Data Management and Sharing Policy

Guide to Complying With the 2023 NIH Data Management and Sharing Policy

Budgeting

As outlined in the NIH Supplemental Policy Information: Allowable Costs for Data Management and Sharing, investigators may request funds toward data management and sharing in the budget and budget justification sections of their applications. All allowable costs submitted in the budget requests must be incurred during the award period, even for scientific data and metadata preserved and shared beyond the award period. 

The NIH suggests reviewing "Forecasting Costs for Preserving, Archiving, and Promoting Access to Biomedical Data" to properly budget for data management and sharing costs. 

Allowable and Unallowable Costs

The NIH provides the following examples for allowable and unallowable costs: 

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

Unallowable Costs 

  • Infrastructure costs that are included in institutional overhead
  • 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