My interpretation of the instructions were that a Resource Sharing Plan was not required unless the proposal was requesting more than $500K in direct costs, had a model organism or utilized genomic data. Has that changed? Would the total DC include the consortium F&A for this?
A Data Sharing plan is required if total direct costs requested in one year (including subrecipient DC) is >$500,000.
However, a plan for Sharing Model Organisms is required regardless of the requested costs if development of model organisms is anticipated.
Similarly, a Genomic Data Sharing plan is required if applicable regardless of the requested costs.
Here is a helpful NIH resource: grants.nih.gov/grants/peer/guidelines_general/Resource_sharing_plans.pdf