The COGR Review of the Final NIH Policy for Data Management and Sharing provides a thorough analysis of the challenges institutions and researchers face regarding budgeting and costing in compliance with the new NIH policy effective January 25, 2023. The document acknowledges that while the policy aims to enhance robust data sharing and scientific advancement, it introduces significant new compliance requirements that may increase the administrative and cost burden, potentially creating barriers for smaller or emerging research institutions. Key concerns highlighted include the sufficiency and audit risks associated with single-line budget requests, limitations of the NIH’s current cost estimation tools, uncertainty about acceptable budgeting for data repositories and storage, and the perception that proposing realistic DMS costs could adversely affect funding prospects.
The review underscores the importance of clear NIH guidance, flexibility in institutional cost modeling, and the need for mechanisms to effectively recover and manage post-performance DMS costs. It advocates for the use of default budget factors to assist with initial implementation and calls for simplification in budgeting for both labor and non-labor costs associated with data management. Additionally, the review emphasizes the necessity for appropriate oversight without imposing unrealistic monitoring or reporting expectations. COGR encourages NIH to adopt reasonable and fair standards for enforcement and auditing, recommending a grace period during the first year of policy implementation. The document concludes with a commitment to ongoing engagement with NIH and stakeholders to collaboratively address emerging issues, ensuring the policy’s successful adoption across diverse research environments.
