Data Sharing Regulations and NIH Budgeting Guidance

Author: Heather Lennon, Strategic Operations and Training 


Recently, the Office of Science and Technology Policy (OSTP) released new requirements on public access to publications and data resulting from federal funding in a memo known as The Nelson Memo.  The Nelson memo calls for ALL federal agencies to update their public access policies to ensure sponsor-funded research, including publications and data, is freely and immediately available to the public. To meet this mandate, all federal agencies must update their data-sharing policies by December 31, 2025.  

Initial NIH & NSF Updates to Data Management and Sharing Plans 

Since the Nelson memo, federal agencies, including the NIH and NSF, have begun to require new elements in their data management plans. NIH’s new Data Management and Sharing Plan (DMSP) went into effect on January 25, 2023. Under the new policy, ALL competing grants that generate scientific data must include data management plans and plans for sharing data during the entire funding period, and for a minimum of three years after the end date of the award. This applies to all research projects, certain career development awards (Ks), STTR/SBIRs, and research center proposals. It does not apply to Training (Ts), Fellowships (Fs), or Conference (R13) proposals. Plans should be limited to 2-3 pages and must not include hyperlinks. After a proposal is submitted, questions related to the data management plan will be addressed at Just in Time (JIT), and progress towards the data management plan will be documented in the annual Research Performance Progress Report (RPPR).   

For NSF, proposals must continue to include Data Management Plans of no more than two pages in the supplementary documents section. The plan should describe how the proposal will conform to NSF policy on the dissemination and sharing of research results. Within the budget, costs for data management can be included as direct costs. And, similar to NIH, data management plans will be monitored as part of the award’s annual report.  

Budgeting for NIH Data Management and Sharing Plans 

Below are examples of allowable and unallowable data management costs provided by the NIH. 

Allowable Costs/Budget Examples: 

  • Curating data 
  • Budget Example: Contacting a generalist repository for curation support services 
  • Developing supporting documentation 
  • Budget Example: Research personnel effort needed to create and retain appropriate documentation beyond the effort needed to simply generate or collect data.  
  • Formatting data according to accepted community standards, or for transmission to and storage at a selected repository for long-term preservation and access. 
  • Budget Example: Support services that may be offered by the repository. 
  • De-identifying data 
  • Budget Example: Research personnel effort to systematically remove all identifiers from a data set prior to sharing 
  • Engaging a third-party vendor to certify that a data set has been fully de-identified 
  • Preparing metadata to foster discoverability, interpretation, and reuse 
  • Budget Example: Research personnel effort needed to document appropriate metadata beyond the effort needed to simply generate or collect the data 
  • Unique, project-specific information resources necessary to provide local management and preservation 
  • Budget Example: Charges from an external vendor for cloud storage prior to deposit into an established repository 
  • Preserving and sharing data through established repositories  
  • Budget Example: Data deposit fees 

Unallowable Costs: 

  • Infrastructure costs typically included as indirect costs/F&A 
  • Costs associated with routine conduct of research 

It is important to remember that data management should be happening throughout the life of the project and that data costs included in the budget must only be incurred during the project period, even for scientific data and metadata preserved and shared beyond the life of the award. For example, if a DMS plan proposes preserving and sharing scientific data for 10 years in an established repository with a disposition fee, the cost of the entire 10-year project must be paid before the end of the period of performance. Keep in mind, costs will vary widely by discipline, type of data, amount of data, the length of time for sharing the data, and the amount of time it will take to curate the data in a format that will be findable and reusable by the research community. 

Below are a few questions to consider asking your PI while working on the budget: 

  • Is there a fee for the repository you are using? *Tip: Identifying the repository is a good first step for the budget and often drives many costs.  
  • Will you need dedicated staff time for any data management and sharing functions to meet the requirements of the repository? Will you need to hire new staff? 
  • Is there a fee associated with any tools or software you are planning to use to collect or analyze the data? 
  • Will metadata be prepared?  
  • Will any data need to be de-identified?
  • Do you have subrecipients, and will they need to budget for data sharing? 

In addition to these questions, there are a few additional resources that may be helpful as you develop the budget. The National Institute of Mental Health Data Archive (NDA) has developed a Data Submission Cost Estimation Tool. While the tool is specific to NDA, it can be revised specifically to your proposal to help develop data management and sharing costs. Additionally, the National Academies of Sciences, Engineering, and Medicine has developed a generalized checklist of data sharing items to consider for administrators as well as a data cost driver workbook that may be helpful for your PI while considering data costs. Both tools can be found in the Resources section below. 

Once the budget is finalized, all direct costs related to data management, including personnel costs specific to these activities, must be included as a single line item titled “Data Management and Sharing Costs” in the R&R budget form. If no costs will be incurred, the line item must still be included with $0 entered in the “Funds Requested” column. Supporting details related to the data management must be included in the budget justification and clearly labeled “Data Management and Sharing Justification.” Justifications should be no more than half a page. For modular budgets, DMS costs must be included in the Additional Narrative Justification. A separate section within the justification should be labeled “Data Management and Sharing Justification” followed by the requested dollar amount.  

Data Management Resources at Emory 

There are several data management sharing resources available right here at Emory. It is important for your PI to be aware of these resources as oversight of individual project related data management and sharing plans is the responsibility of the PI and other named delegates in the project team. If your PI is looking for a repository, Dataverse at Emory may be a good place to start. Dataverse is Emory’s open data repository offered through a partnership between Emory and the Odum Institute at the University of North Carolina at Chapel Hill. Made available through a web accessible repository at no cost to depositors or users, Dataverse assigns each data set a Digital Object Identifier (DOI) for reliable citation and linking. Additional resources related to data management can be found at This site contains a wealth of information related to creating and writing data management plans, how to store data, and library staff contacts specific to data management.  

For information related to data management at Emory, including how to write data management plans, repositories, library support staff contact, etc., see: 

  • Emory Research Data 

  • Dataverse at Emory University 

  • Emory Thursdays at Three (T@3) – “Current Data Sharing Regulations” 



  • Office of Science and Technology Policy (OSTP) August 2022 memo written by Dr. Alondra Nelson (aka the Nelson memo): 

  •  For NIH guidance on their new Data Management and Sharing Policy, including writing and budgeting for plans, please see: 

  •  For NSF general guidance as well as more specific guidance from NSF directorates on data management plans, please see: 

  •  NDA Data Submission Cost Estimation Tool 

  •  National Academies of Sciences, Engineering, and Medicine Assessing Research Data Costs – A Checklist for Administrators at Research Institutes 

  •  National Academies of Sciences, Engineering, and Medicine workbook and video on cost drivers for data management and sharing video 

  • National Council of University Research Administrators YouTube Video ‘NIH Data Management and Sharing (DMS) Policy 

NIH’s Data Management and Sharing (DMS) Policy (NOT-OD-21-013) – YouTube 

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