Do sub-recipients need to provide their own Data Management and Sharing Plan?
Answered By: Julie Goldman Last Updated: May 16, 2023 Views: 7
No. The DMS Policy expects only one DMS Plan to be submitted with each application and does not expect separate Plans to be developed for individual projects under that application. In multi-component applications, the DMS Plan must be in included in the Overall component. Applicants are encouraged to determine whether and how to coordinate responsibilities with respect to Plans with all Program Directors/Principal Investigators and all Key Personnel on the same application. Therefore, the subrecipient sites' management/sharing of data should be discussed in the DMS Plan.
When Harvard is the Prime:
- The Harvard PI should discuss roles and responsibilities with regards to data management and sharing activities with any subrecipients while preparing the proposal materials
- Share a copy of the final DMSP with the subrecipient and obtain their approval of the final DMSP prior to submission, ideally as part of the institutionally approved subaward proposal package.
When Harvard is the Sub:
- Harvard PI should discuss roles and responsibilities with regards to data management and sharing activities with the Prime PI while preparing the proposal materials
- Harvard PI should request a copy of the final (or near final) DMSP from the Prime PI
- Harvard PI should review with their Grant Manager to ensure that appropriate costs related to data management and sharing activities have been included in the Harvard budget.
Additionally, DMS costs for each subaward must be listed as a single line item on the R&R Budget for the subaward (F. Other Direct Costs, 8-17 Other). If no DMS costs are anticipated on the subaward, the line item is not required. A DMS costs line item must still be listed on the project/parent R&R Budget Form for the parent DMS costs, including $0 if no costs are anticipated for the parent.
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