Procedure Library

Under current 2 CFR §200.455(c), data and evaluation costs are generally allowable when necessary to support project objectives. Examples include expenditures needed to gather, store, track, manage, analyze, secure, share, publish, or otherwise use data. Allowable data costs may include data systems, personnel, dashboards, cybersecurity, repository costs, and integrated data systems. Evaluation costs may include evidence reviews, evaluation planning, conducting evaluations, and dissemination of evaluation results.

Under current 2 CFR §200.461, publication costs, printing costs, page charges, article processing charges (APCs), and open access fees are generally allowable when they meet applicable federal requirements. Publication costs associated with sharing research results may also be charged during award closeout under certain circumstances. Read about Anticipated Changes below.

Evaluation Costs

Examples may include:

• Needs assessments
• Evaluation planning
• Logic model development
• External evaluators
• Evidence reviews
• Outcome measurement
• Survey administration
• Evaluation reporting
• Dissemination of evaluation findings

Personnel Costs

Examples may include:

• Research coordinators
• Data managers
• Data analysts
• Data curators
• Information technology support
• Evaluation specialists

Consider whether project personnel, institutional resources, or external vendors will be needed to support required data management or evaluation activities.

---

NIH-Specific Considerations

For projects subject to the NIH Data Management and Sharing Policy, investigators should:

• Identify anticipated data management and sharing costs during proposal development
• Include appropriate cost estimates in the budget and budget justification
• Coordinate budget development with the Data Management and Sharing Plan (DMSP)
• Identify repository costs, curation costs, and personnel effort needed to implement the DMSP

NIH-specific guidance:

• Budgeting for Data Management and Sharing
• Allowable Costs
• Unallowable Costs
• Requesting and Justifying Costs
• Assessment of Budget

---

Anticipated Federal Regulatory Changes

Important: The following information reflects proposed federal regulatory changes that have not been finalized. Current requirements remain in effect unless and until federal agencies formally implement revised regulations. 

The May 2026 OMB proposed revisions to 2 CFR Part 200 would revise allowability for several cost categories if finalized. Proposed changes include restrictions affecting:

• Publication costs
• Academic and professional subscriptions
• Technical periodicals
• Public relations costs
• Conference costs
• Certain fundraising-related costs

Under the proposal, publication costs could become unallowable unless specifically authorized by statute or approved by the awarding agency. These provisions are not currently in effect and should be monitored for future implementation.

Investigators and research administrators should verify allowability requirements against:

1. Current sponsor guidance
2. Award terms and conditions
3. Agency implementation notices
4. Institutional procedures

before including these costs in proposal budgets.

---

Recommended Note for Research Administrators

Cost allowability for data management, dissemination, publication, evaluation, and related activities continues to evolve across federal sponsors. Proposal budgets should be developed based on current regulations and sponsor guidance in effect at the time of submission while remaining attentive to future regulatory changes that may affect awarded projects.