Skip to Main Content

NIH Data Management and Sharing Policy

This guide supports researchers' efforts to comply with the NIH Data Management and Sharing Policy. It offers step-by-step guidance on how to plan for data sharing and write a data management and sharing plan to meet NIH requirements.

Overview

NIH covers costs for critical data management and sharing (DMS) activities, including de-identification, dataset documentation, preparing data for repository deposit, and repository fees. NIH acknowledges that these costs may be challenging to anticipate and itemize, and will likely allow some revisions for awarded grants.

Unless a project is planning large-scale data availability as a central purpose, it may be best to start with known costs that clearly apply to data management and sharing, balanced by a flexible amount for unanticipated costs. Initially, more time may be needed for this area of budget planning.

This section of the guide focuses on where to list costs and categories of allowable costs, including those specific to JHU research support. For more details, see NIH's "Budgeting for Data Management and Sharing" guidance.

Note that costs must be incurred and applied during the grant's performance period. Services continuing after a particular grant's funding must be either prepaid from that grant, or covered by other funds.

Johns Hopkins University School of Medicine's Office of Research Administration (ORA) and Johns Hopkins University Research Administration (JHURA) also provide JHU Specific Budget Guidance, linked at the JHURA Data Management and Sharing page

Allowable Data Management and Sharing Costs

Reasonable, allowable costs associated with DMS plans should be requested in the budget and budget justification sections of the application. Total costs are aggregated on a single "Data Management and Sharing Costs” budget line in section F, itemized in the "Budget Justification" section L. 

Costs that can be directly charged to the award include costs for:

  • Curating data and developing supporting documentation
    • Formatting data according to accepted community standards
    • De-identifying data
    • Preparing documentation metadata to foster discoverability, interpretation, and reuse
    • Formatting data for transmission to and storage at a selected repository for long-term preservation and access
  • Local data management considerations
    • Unique and specialized information infrastructures necessary to provide local management and preservation (e.g., before deposit into an established repository)
  • Preserving and sharing data through established repositories
    • Repository data deposit fees necessary for making data available and accessible

Example 1: If a DMS plan proposes preserving and sharing scientific data for 10 years in an established repository with a deposition fee, the cost for the entire 10-year period must be paid prior to the end of the period of performance.

Example 2: If the DMS plan proposes deposition to multiple repositories, costs associated with each proposed repository may be included.

  • Personnel costs associated with these specific activities
    • A statistician’s services to anonymize shared data
    • A data manager’s time formatting, documenting, and depositing datasets

Note that activities related to routine data management during research may not belong in section F. (See NIH’s R&R Budget Form Section F: 8-17.)

Budget requests for data management and sharing must NOT include: 

  • Infrastructure costs that are included in institutional overhead (for instance, facilities and administrative costs
  • Costs associated with the routine conduct of research, including costs associated with collecting or gaining access to research data. This would include personnel activities for routine data management during research not clearly associated with data sharing. 
  • Costs that are double charged or inconsistently charged as both direct and indirect costs

Note that both "Data Management Expenses" and "Activities" are listed and detailed in the Budget Justification section, itemized by the categories "Personnel" and "Other Expenses."

For more details see NIH's "Budgeting for Data Management and Sharing" guidance.

Where to Include Costs in the Budget

Format for Submitting the DMS Budget and Justification

Budget requests should be included in one of the following ways: 

NIH's Budget Guidance and Examples of Annotated Forms

Quoted from NIH Grants and Funding's "How to Apply - Application Guide."

Section G: 300 R&R Budget Form

Special Instructions for Applications Submitted with a Data Management and Sharing Plan:

  • Overall Component
    • Include budget information for data management and sharing costs in the Overall Component.
  • Other Components
    • Include budget information for data management and sharing costs within the applicable component(s).
    • Do not include a "Data Management and Sharing Plan" attachment within the components.
    • Any component-specific information should be described within the overall "Data Management and Sharing Plan" attachment provided within the PHS 398 Research Plan Form in the Overall Component.

Budgeting other direct costs

Section L: Budget Justification 

If a data management and sharing plan is required in the proposed application [see instructions for the "Other Plan(s)" attachment on the PHS 398 Research Plan Form and the PHS 398 Career Development Award Supplemental Form, as applicable], include a brief justification of the proposed activities that will incur costs.

The data management and sharing justification must be clearly labeled as "Data Management and Sharing Justification" in the budget justification attachment.

Provide a brief summary of the type and amount of scientific data 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 activities, preserving and sharing data through established repositories, etc., including an amount for each category and a brief explanation. Specify in the justification if no costs will be incurred for data management and sharing. The length of the justification should be no more than half a page. 

For more information, see the following NIH guidance:

Budget justification form

Considerations when Preparing DMS Budgets

Questions to Consider
  • How much dedicated staff time will be required to support the data management and sharing activities proposed in the DMS plan?
  • Will staff or a service center/third party vendor be performing any of the following activities?  If so, include these costs in the DMS budget.
    • Curating data
    • Developing supporting documentation
    • Formatting data according to accepted community standards
    • 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
  • Are there applicable data storage or repository costs?
  • Are there costs associated with any specialized information infrastructure necessary to provide local management and preservation of the data (e.g., the Johns Hopkins Precision Medicine Analytics Platform)? 
  • Are any sub-recipients performing DMS activities?
Suggested Costs for Routine Data Management and Sharing

The following are DMS cost estimates from JHU's Biostatistics, Epidemiology and Data Management (BEAD) Core. The BEAD Core provides research support services, including writing data management plans.

Note that these costs are provided as suggestions only and should be commensurate with the activities of the individual DMS plan. Costs may be replaced with BEAD Core subscription hours either in-full or in-part for faculty in subscribing departments.

  • R01-level funding
    • 40% of a data manager per year ($30,000 to $40,000)
    • 2-5% Co-I to supervise/guide data manager ($5,000 to $10,000)
  • R21-level funding
    • 20% of a data manager per year ($15,000 to $20,000)
    • 2% Co-I to supervise/guide data manager ($5,000)
  • U's (such as a U54) (typically three RO1s combined)
    • 100% of a data manager (some efficiency gained, but depends on the three projects included)
    • 10% of a Co-I
  • K-level funding
    • 20-40 hours per year ($120/hr)

JHU Services and Allowable DMS Costs

JHU offers a variety of research support services whose fees could be included in the budgets of NIH grants. Note that these fees may not be appropriate as allowable costs for the "Data Management & Sharing" budget line.

These costs should often be listed as "associated with the routine conduct of research, including costs associated with collecting or gaining access to the research data" or as infrastructure costs (e.g., facilities and administrative costs). 

In some cases, service providers may not itemize charges for DMS support services such as de-identification, instead bundling them with other types of services in a single fee. In such cases, these bundled costs should be listed elsewhere, such as under research conduct support.

Resources for Estimating Allowable DMS Costs