Update coming to Data Management and Sharing Plan budgets

If you have submitted an NIH research grant proposal in 2023, you have likely had to comply with the new Data Management and Sharing (DMS) policy requirements. Essentially, NIH issued the DMS policy to promote the sharing of scientific data, and all proposals for specific grant mechanisms submitted on or after January 25, 2023 are required to comply. In a prior post, I provided more information about the requirements of the new Data Management and Sharing (DMS) policy.

The DMS policy requires all funded investigators and institutions to:

• Plan and budget for data management and sharing
• Submit a Data Management and Sharing Plan attachment as part of their grant application
• Ensure compliance with the approved DMS plan when the grant is awarded

A new notice, NOT-OD-23-161 NIH Application Instruction Updates – Data Management and Sharing (DMS) Costs, was recently released to provide updated guidance on budgeting for project data management. When the policy was initially implemented, Principal Investigators and institutions were instructed to add all DMS related costs as a single line item direct cost in the proposal budget. This led to confusion and accounting challenges, as some of this lump sum often included effort for project personnel to aid in data management. With the release of this notice, new guidance is provided for DMS budgeting that is effective for applications submitted for due dates on or after October 5, 2023, 

According to the updated instructions, "NIH will no longer require the use of the single DMS cost line item. NIH recognizes that DMS costs may be requested in many cost categories. Therefore, in line with our standard budget instructions, DMS costs must be requested in the appropriate cost category, e.g., personnel, equipment, supplies, and other expenses, following the instructions for the R&R Budget Form or PHS 398 Modular Budget Form, as applicable." The costs will still need to be specifically described as DMS costs in the Budget Justification for detailed budgets or Additional Narrative Justification for modular budgets.

This is a welcome update! The additional work required to understand what is required and write the DMS plan has already caused challenges among many of my colleagues. The confusing budgeting that was required was creating additional unnecessary headaches. With this new notice, NIH is acting quickly to improve the situation and help to streamline the proposal budgeting.

How do I address the new NIH Data Management and Sharing Plan (DMSP) requirements?

In January of 2023, the Final NIH Policy for Data Management and Sharing was released after several years of development. The goal of this policy is "to promote the management and sharing of scientific data generated from NIH-funded or conducted research". A Data Management and Sharing Plan attachment (also called DMSP and DMS Plan) is now required for submission as part of most NIH research grant proposal mechanisms (e.g. R01, R21, R03) and not currently for training grants or fellowships. If you are not sure whether your proposal is required to comply with the policy, NIH has created a helpful page.

The Data Management and Sharing Policy requires investigators and institutions to: 

1. Plan and budget for the managing and sharing of data
2. Submit a Data Management and Sharing Plan for review when applying for funding
3. Comply with the approved Data Management and Sharing plan

What does this mean for your grant proposal? First, you will need to write a Data Management and Sharing Plan that includes the specified information. A blank format page that can be used to create the document is located here. 

You will also need to consider whether the data sharing activities proposed in your application will incur any costs. These costs can be budgeted as a separate line item provided they fall into one of the allowable categories. It is important to work closely with a pre-award research administration professional at your institution to ensure these costs are budgeted appropriately and in line with any institutional requirements.

One important note: the Data Management and Sharing Plan does not replace the Resource Sharing Plan. You may still need to include both with your application.

For more information, hear directly from NIH program staff in the video below: