Budgeting: Estimating Costs for Data Management and Sharing Plans

The National Institutes of Health (NIH) provides financial support for essential data management and sharing (DMS) activities.

These activities encompass tasks such as de-identification, documenting datasets, preparing data for deposition in a repository, and covering repository fees.

Suggestion: Review the Overview of 2023 NIH Data Management and Sharing Policy for information on all areas and requirements for submitting an NIH DMS Plan with your grant application.


Generally speaking, any data management costs that are unique to your project are allowable. For example, data storage for your project above what is normally provided by your university could be allowed, but if multiple projects will be using the data storage, it is an infrastructure cost.

Principal investigators (PIs) generally underestimate data management costs. The management cost for a grant will almost never be zero; if nothing else, staff time will go into managing and curating data. When creating your budget, it is prudent to:

  • Contact your chosen repository to discuss any fees they will charge for depositing your data.
  • If you need to consider de-identification, get a quote from your in-house de-identification team or an outside vendor. A reasonable cost estimate for professional de-identification of a clinical trial is around $10,000.

For more details, see NIH's Budgeting for Data Management & Sharing guidance.

Tip: It's important to note that costs must be incurred and allocated during the performance period of the grant. Services that extend beyond the funding period of a particular grant must either be prepaid using that grant's funds or covered by alternative sources of funding.

Allowable Costs

PIs may include costs involved in managing and sharing data according to their DMS Plan, such as  

  • Curating data
  • Developing supporting documentation
  • Formatting data according to accepted community standards or for transmission to and storage at a selected repository for long-term preservation and access
  • De-identifying data
  • Preparing metadata to foster discoverability, interpretation, and reuse
  • Local data management considerations, such as unique and specialized information infrastructure necessary to provide local management and preservation (for example, before deposit into an established repository)
  • Preserving and sharing data through established repositories, such as data deposit fees

Tip: If the DMS Plan proposes deposition to multiple repositories, costs associated with each proposed repository may be included.

Unallowable Costs

  • Infrastructure costs that are included in institutional overhead (for instance, Facilities and Administrative costs
  • Costs associated with the routine conduct of research, including costs associated with collecting or gaining access to research data 
  • Costs that are double charged or inconsistently charged as both direct and indirect costs. For example, if your campus facilities and administration includes working storage up to 5 TB, you can't budget for working storage unless you clearly make the case why your data will be over 5TB and you also set the cost starting at 5, not 0, TB.

Application Process

R&R Budget

Estimated DMS costs must be outlined in the budget justification attachment in a section clearly labeled “Data Management and Sharing Justification.” The recommended length of the justification is no more than half a page. 

See the Application Guide instructions for the R&R Budget Form for additional details.

Modular Budget

Use the Additional Narrative Justification attachment in the PHS 398 Modular Budget Form and include a section clearly labeled "Data Management and Sharing Justification" followed by the requested dollar amount. If no cost will be incurred, enter "0" for the requested dollar amount. Also, include a brief justification of the proposed activities that will incur costs.  

See the Application Guide instructions for the R&R Budget Additional Narrative Justification attachment for additional details. 


Any estimated DMS costs for the subaward must be outlined in the budget justification attachment of the Subaward R&R Budget form in a section clearly labeled “Data Management and Sharing Justification.” The recommended length of the justification is no more than half a page. The Other Direct Costs of the R&R Budget Form is no longer required (NOT-OD-23-161).


October 5, 2023, Change to NIH Budgeting Requirements

Grant applications submitted before October 5, 2023, must request costs to support DMS Plan activities as a single line item on the R&R Budget Form titled “Data Management and Sharing Costs.” This requirement will be rescinded for due dates on or after October 5, 2023 (NOT-OD-23-161).

For grant applications submitted on or after October 5, 2023, DMS costs must be included with other costs in the appropriate cost categories (e.g., personnel, equipment, supplies, other expenses), following standard form instructions. Supporting details, including a breakdown of any personnel effort, and the estimated associated total direct costs must be included in the budget justification.

The application form instructions on the How to Apply – Application Guide page and the Budget/Costs FAQs on the Scientific Data Sharing site have been updated to reflect this change.


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Additional Resources

Related Articles


Bohman, Lena. “LibGuides: SOM NIH Data Management and Sharing Policy,” September 2023. https://libguides.hofstra.edu/c.php?g=1275561&p=9358324.

Martone, Maryann. “Estimating Costs for Data Management and Sharing (OTC-TBI Document).” dkNET. Accessed November 8, 2023. https://dknet.org/about/estimating-costs-for-DMS-OTC-TBI.

National Institutes of Health. “Budgeting for Data Management & Sharing.” sharing.nih.gov. Accessed October 16, 2023. https://sharing.nih.gov/data-management-and-sharing-policy/planning-and-budgeting-for-data-management-and-sharing/budgeting-for-data-management-sharing#after.