The document summarizes the findings from a 2022 COGR survey assessing the financial and administrative burdens imposed by the new NIH Data Management and Sharing (DMS) Policy, effective January 2023, which expanded data management requirements to all NIH-funded research projects generating scientific data. The survey, completed by 34 institutions (29 mid-size to large and 5 smaller institutions), revealed that the annual cost of compliance is substantial, with mid-size to large research institutions projecting costs exceeding $1 million per institution—split roughly equally between central administrative functions and academic units, especially impacting faculty and principal investigators. For smaller and emerging institutions, while a limited sample prevents wide extrapolation, the cost remains significant and may pose a deterrent to participation in the federal research ecosystem.
The study structured cost estimation around measurable “Burden Factors” tied to typical research administrative units and a range of DMS-related activities (from planning and data storage to long-term retention), translating these into monetary costs based on new staffing, opportunity costs, IT expenditures, and training requirements. Faculty and researchers, in particular, are seen to face a sizeable shift from scientific work toward administrative compliance, potentially reducing research productivity. The document further highlights structural funding inadequacies: although NIH allows DMS costs to be direct-charged, institutional reimbursement is limited by caps and budget constraints, exacerbating the issue of compliance requirements operating as unfunded mandates. COGR warns that continued inaction on addressing these burdens not only threatens the inclusion of smaller institutions but also risks diminishing the overall effectiveness, creativity, and leadership of the U.S. scientific enterprise.
