This document, Chapter 4 Part II of the COGR NIH DMS Readiness Guide, addresses the key budgeting and costing considerations associated with implementing the NIH Data Management and Sharing (DMS) Policy at academic and research institutions. It emphasizes the importance of carefully identifying, budgeting, and managing both direct and indirect DMS-related costs in grant applications. The guide outlines the complexities of incorporating DMS costs, particularly the challenges and risks associated with NIH’s current requirement to capture all such costs (including labor and subaward expenses) in a single line item on the budget. This practice, the document argues, is counterintuitive to standard budget and cost accounting principles and raises concerns about accurate cost estimation, allocation, and audit risk.
The guide recommends that institutions leverage experienced personnel and utilize tools (such as the NIMH Data Archive Cost Estimation Tool), but also notes limitations in existing calculators and advises developing institution-specific resources for more accurate budgeting. It advocates for early and detailed project planning to anticipate all labor and non-labor DMS costs and provides practical strategies for estimating these costs when complete information is lacking. The document further advises institutions to establish internal review processes, collaborate across departments (e.g., pre-award offices, libraries, IT), and develop prompts or tools to ensure budgeting comprehensively addresses DMS requirements. The guide recognizes the evolving nature of best practices under the NIH DMS policy and commits to ongoing review and updates as further guidance from NIH and community feedback become available.
