Recently questions have come up with regard to the use of NIH funding for the support of graduate students as compared to postdoctoral scholars. The purpose of this memo is to provide guidance on the interpretation of NIH requirements related to compensation levels for graduate students working on NIH research grants.
The NIH will award funds for the cost of a graduate student working on a research project (i.e., for an RA) up to the "zero level" NRSA Postdoctoral stipend in effect at the time that the research project is awarded. As of October 2009, the "zero level" NRSA award is $37,740 per year, and the NIH will not award funding above that level to compensate a graduate student.
The NIH, however, allows PIs to rebudget project funds in order to charge more than this amount for the actual cost of a graduate student. The NIH allows its project funds to be used to compensate a graduate student up to the "amount paid to a first-year postdoctoral scientist at the same institution performing comparable work."
Compensation for both graduate students and postdocs is defined to include salaries or wages, fringe benefits and tuition remission. Particularly for graduate students who have not reached TGR status, the combination of wages, benefits and tuition may move the RA's compensation above the level that the NIH defines as allowable, i.e., above the cost for a first-year postdoc doing comparable work. In order to maximize the use of available funds, PIs are expected to use NIH project funds to support grad students up to the maximum allowed by the agency. In no case, however, may a graduate student working as an RA on an NIH project be compensated from that project's funds at a level exceeding what an entry-level postdoc in the same lab or group would cost.
EXAMPLE (using 2010-11 Stanford compensation levels)
- Maximum amount awarded by the NIH for a grad student's support - $37,740 per year (stipend level set annually by the NIH for a "zero-year" NRSA Postdoctoral Fellow).
- Minimum compensation for a first-year postdoc at Stanford - $51,083 per year ($42,223 per year, plus 19.8% fringe benefits, plus $125 per quarter registration fees).
Note that some labs or groups have established a compensation level for first-year postdocs that exceeds this University minimum.
Hence, while the NIH will award a maximum of $37,740 per year for a graduate student, they will allow the rebudgetting of their project funds so that a higher level may be charged for graduate student support. Normally, the NIH will allow a Stanford PI to charge up to the $51,083 amount per year (including salary, benefits and tuition) for a graduate student RA working on an NIH project. However, in labs or groups where the minimum for a first-year postdoc is ABOVE the University minimum, that higher amount (including benefits and registration fee) becomes the compensation limit for a graduate student working as an RA on an NIH project in that department.
The combination of a graduate student RA's salary, benefits, and the chargeable portion of tuition allowance is defined as "grad student compensation." Where this amount exceeds the minimum compensation (salary, benefits and registration fees) for a first-year postdoc in the same lab or group, the overage may NOT be charged to the NIH (and, of course, may not be charged to any sponsored project on which the student is not working). The overage will normally have to be paid from school, department or PI unrestricted funds.
PIs are reminded that, unless other arrangements have been approved in advance, they are generally expected to charge their NIH grants and contracts up to the maximum that the agency will allow, i.e., up to the combined salary, benefits and registration fees for a first-year postdoc in their lab or group. As shown in the example above, this may require rebudgetting of project funds (for non-modular grants) as allowed by the NIH.
If you have any questions about this, contact your Research Process Manager in the School of Medicine, or contact Ann George, Assistant Dean Research and Graduate Policy (firstname.lastname@example.org).