Results from the COGR Survey on the Cost of Complying with the New NIH DMS Policy


COGR conducted a survey in the fall of 2022 to project the annual cost impact of the new NIH Data Sharing and Management Policy (DMS), effective on January 25, 2023. Thirty-four (34) institutions completed the survey.


Survey Report (Full Text)


The “Key Findings” of the report are:


For mid-size to large research institutions, the annual projected cost impact is expected to exceed $500,000 at the central administrative level, while also exceeding $500,000 at the academic level––a total impact that exceeds $1 million per institution. Cost impact is measured both by new expenditures and reallocation of effort away from an individual’s current responsibilities. In the case of Researchers and Investigators, this results in a shift away from conducting science in the lab toward tasks that might be considered more administrative in nature. For smaller and emerging research institutions, the cost impact also is expected to be significant, and for these institutions, the disproportionate negative impact may discourage their participation in the federal research ecosystem.


We are grateful to the 34 institutions that participated in the survey! Your thoughtfulness, patience, and effort resulted in high-quality data and enabled us to draw strong conclusions based on the survey results.  


For questions, contact:

David Kennedy, Director of Costing and Financial Compliance, at

Krystal Toups, Director of Contracts and Grants Administration, at

Released May 11, 2023


Additional Resources:

COGR's Resource Page on NIH Data Management and Sharing

COGR's Readiness Guide on NIH Data Management and Sharing