National Institutes of Health (NIH) Grants Policy Statement 220.127.116.11 permits use of federal research grants to provide additional salary under certain conditions for fellows supported by the Ruth L. Kirschstein National Research Service Award (NRSA), including T32 institutional NRSAs and F32 individual NRSAs. Since NRSA stipends are often insufficient to cover the full salary of trainees, this NIH policy permits the use of NIH and other Federal grants to provide additional salary support when NRSA scholars are also involved in research programs that are “incidental to their training program.”
A completed and authorized Additional Compensation for T32/F32 Postdoctoral Fellows from Federal Funds Form is required when requesting approval for additional compensation for those NRSA Fellows that meet the UCSF requirements allowed under NIH Policy Statement 18.104.22.168 for salary support up to 25% salary (10 hours per week) from federal research grants under certain circumstances. This additional salary and effort must NOT be associated with work related to the NRSA research project.
All questions regarding the NRSA Fellows Additional Compensation process should be directed to CGA Compliance.
Procedure for Requesting Additional Compensation for NRSA Fellows
- Prior to the commencement of any additional work for compensation, a trainee wishing to take on additional work for compensation must submit a completed and signed Additional Compensation for T32/F32 Postdoctoral Fellows from Federal Funds Form following the routing process outlined in the form instructions.
- The mentor and the T32 Program Director have the discretion to decide whether the proposed activity is compliant with NIH policy and compatible with the training requirements of the training program. The mentor/Program Director may permit, prohibit, limit, or revoke permission for the additional work as s/he deems appropriate. Factors to be considered include the current level and academic standing of the postdoc, as well as the potential interference with the trainee’s ability to achieve the goals and objectives of his/her approved training program.
Essentials of the NIH policy include:
… NRSA fellows may seek part-time employment incidental to their training program to offset further their expenses. Fellows and trainees may spend on average, an additional 25% of their time (e.g., 10 hours per week) in part time research, teaching, or clinical employment, so long as those activities do not interfere with, or lengthen, the duration of their NRSA training… NIH expects that compensation from research grants will be for limited part-time employment apart from the normal full-time training activities. Compensation may not be paid from a research grant that supports the same research that is part of the fellow's planned training experience as approved in the Kirschstein-NRSA individual fellowship application.
NRSA fellows and mentors and research grant Principal Investigators (PIs) are strongly encouraged to review the complete NIH policy and to consult with NIH program officers as needed to ensure compliance with NIH rules. Our understanding is that publications should not be reported in progress reports of both the NRSA and the research grant as this would indicate that the arrangement is not consistent with NIH policy.
- The Program Director must indicate his/her approval of a trainee’s request by completing the appropriate section of the Additional Compensation for T32/F32 Postdoctoral Fellows from Federal Funds Form. If approved, the form will be forwarded to the PI of the federal research grant that is providing the additional compensation for their signature. If the mentor/Program Director denies the request, no additional work may be undertaken. The mentor/Program Director’s decision to deny a request is final and not subject to review.
- If the mentor/T32 Program Director is the PI or other key personnel of the grant funding and benefiting from the additional work, then the Additional Compensation for T32/F32 Postdoctoral Fellows from Federal Funds Form must be approved and signed by the School's Vice or Associate Dean of Research of the PI's home department. The Vice/Associate Dean will review the “Description of Additional Duties” portion of the form to determine whether there is no overlap between the assigned additional work and the trainee’s training program.
Procedure to Request Extension
If the fellow wishes to extend their additional work beyond the date indicated on the Additional Compensation for T32/F32 Postdoctoral Fellows from Federal Funds Form, a new form must be completed and submitted. Note: The additional work and supplemental pay cannot extend past the Postdoctoral Scholar’s Fellowship appointment end date.