Data management and sharing (DMS) costs should be identified in the proposal budget and directly charged to the sponsored program award during the project period. Requirements to manage and share data are identified by some sponsors and/or on specific awards, which allows associated costs to be charged as direct costs to maintain compliance with terms and conditions. Reasonable costs should be identified and allocated and should be consistently treated as direct costs to the specific project, program or activity. Project budgets should include expected costs when applicable.
When budgeting for DMS costs, please remember:
- Using the NIH repositories can be challenging, and appropriate effort should be budgeted.
- For more information, please see “A word of caution . . .” below.
- MSU recommends the use of existing repositories for data sharing whenever practicable and discourages the development of new data repositories at MSU to fulfill data sharing requirements.
- Please see sponsor specific budgeting guidance through OSP Sponsor Information.
- Please budget (and spend) for scientific data and metadata preserved and shared beyond the award period.
- For instance, NIH has indicated: “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 before the end of the period of performance.”
- For more information on budgeting for NIH data management and sharing, please see: NIH Guide Notice NOT-OD-21-015, NIH Guide Notice NOT-OD-23-161, and NIH data-management-and-sharing-policy budgeting.
How to budget for Data Management and Sharing plans
Direct costs budgeted for activities within the Data Management Plan should be included as follows:
Detailed Budgets
Budget DMS costs in the appropriate cost category, e.g., personnel, equipment, supplies, and other expenses. Estimated DMS costs must be specified within the budget justification.
Modular Budgets – Add an Additional Narrative Justification describing the costs budgeted for the DMP.
Please note that any DMS costs incurred by subawards are to be included in the subawards Research & Related (R&R) budget.
A word of caution when budgeting: The NIH National Institute of Mental Health (NIMH) Data Archive (NDA) offers a Data Submission Cost Estimation Tool to estimate costs associated with DMS. Please be aware that agency-specific calculators may not capture all associated costs, which can result in an underestimation. The NIMH tool was reviewed at MSU by several employees, including a faculty member and data scientist that currently submit data to NIMH. Although MSU does not encourage using the estimator, if it is used, please consider the following:
- It is challenging to work with the NIH repositories and related data and information, and the time estimates for tasks are not realistic. For instance:
- Tasks identified take longer than described, e.g., finding a data structure that will work or creating one is more likely to take three hours than one hour per data structure.
- Some of the estimates need more multipliers, e.g., more time to work with some of the required data elements by number of data structures, submissions, and subjects.
- There may be limitations in finding data managers available. As a result, projects may need to use contractors and the rate shown is unlikely to be adequate and should be adjusted accordingly.
- Per 2 CFR 200, faculty should not budget their time as an hourly rate, although previous NIH instructions and tools recommended that faculty do so. Please note that NIH has updated their budgeting guidance (see NOT-OD-23-161) to better align with 2 CFR 200. Previously, NIH advised that all DMS costs should be budgeted as a single line item in Section F. However, MSU has advised budgeting personnel costs in their appropriate cost category. Please budget MSU faculty time as salaries, which is in keeping with the NIH Grants Policy Statement.
- The salary budget should be described in percentage terms in the budget rather than hourly rates.
- Showing the salary projections at the budgeting stage will support the way Salaries and Wages are expensed.
- Budgeting as salaries supports reflecting the appropriate “effort” on a project.
MSU will be watching for additional guidance for budgeting DMS. If you learn of recommended budgeting tools, please feel free to share with the OSP Proposal Team contact for your unit.
Additional Budgeting Resources:
