NIH Authorship Guidelines: Data Acquisition?

Currently trying to determine whether an undergrad shpuld get middle-authorship according to NIH Authorship Guidelines: https://oir.nih.gov/system/files/media/file/2024-07/guidelines-authorship_contributions.pdf

They only thing they did was ~10% of the experiments that appear in the final paper, which were routine/non-challenging/not requiring expertise.

No writing, analysis, and intellectual contribution beyond that.