Clarification and Correction on My Uniform Guidance Post

After talking more yesterday with my university’s compliance person about the new Uniform Guidance, I realize that I misinterpreted the “new” part of the guidance relating to data, A-81 section 200.430, in my last post. Having now read through the guidance several more times (don’t you just love long, dry government documents?), I want to correct my comments on this section.

For clarity, here is the section in question:

(i) Allowable activities. Charges to Federal awards may include reasonable amounts for activities contributing and directly related to work under an agreement, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, developing and maintaining protocols (human, animals, etc.), managing substances/chemicals, managing and securing project-specific data, coordinating research subjects, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences. [emphasis mine]

While I originally interpreted this as meaning all data management expenses can be charged to a federal grant (if you’re at an institute of higher education), really it is only people’s time spent managing data that is allowable. This is part of a larger expansion of allowable personnel charges, such as for administrative staff, under the new Uniform Guidance. My fault for not reading more carefully that this section applies to only people’s time.

Do note that this does not supersede any individual funders’ stipulations that allow a wider variety of data management expenses (eg. storage infrastructure, preservation in a repository, etc.) to be charge to a grant.

While I’m obviously disappointed that my original interpretation is not correct, it is still nice to see the cost of data management explicitly being allowed to be paid for by a federal grant. Because data management certainly requires people’s time to perform. That said, it also usually requires infrastructure and I’d like to see funders do more to cover the total cost of taking care of research data.

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