Data Access

CRE Analysis

9. Won't the Data Access provisions place considerable administrative burdens and costs upon grantee researchers?

Comment by American Association of Engineering Societies

CRE Response:

Basic costs associated with maintaining good data management practices necessary to respond to agency requests for research data should be built into the budget of the research entity, similar to the costs of good laboratory practices. Researchers already have an obligation to maintain their data in a format accessible to the awarding agency.

The revisions to Circular A-110 should assure that incremental costs of the researcher to respond to the FOIA request will be reimbursed whenever possible. Researchers should not need a new paper-handling bureaucracy, however, because the existing Circular A-110 requires research institutions to have a records management system (including for data) in place already. To the extent that major new equipment or data retrieval systems are required to respond to FOIA requests, these costs should be borne by the FOIA requester, and OMB should provide guidance to the agencies in determining fair allocation of these costs among the awardee and the requester(s).

The responding researcher or institution would be required to produce for disclosure any particular data set only once. Thereafter, additional requests for the same data would be handled by the awarding agency.

After an adjustment period, the scientific process will become more efficient on the part of individual investigators. Investigators will perform data collection with the possibility of subsequent requests for access in mind, therefore improving the initial management of data. Increased efficiency will undoubtedly decrease the cost of data management, as well as minimize the required cost of responding to requests for access.