Compensation Policy for Graduate Student Researchers (GSRs)

The National Institutes of Health (NIH) Notice NOT-OD-0217 defines Graduate Student Researcher (GSR) compensation for those GSRs funded by NIH research grants and cooperative agreements. The compensation level is tied to the National Research Service Award (NRSA) Postdoctoral stipend level 0 that is in effect at the time the grant award is issued. GSR compensation includes total salary or wages, fringe benefits and tuition remission from all NIH sources. UCSF policy allows for a GSR to be supported by other sources to help defray the costs of their education. Compliance to the NIH Grants Policy Statement: 11.2.10.2 Compensation for Graduate Student Researchers who seek part-time employment (incidental to their training program), begins during the proposal preparation process. If you are including a Graduate Student Researcher (title code 3282) on an NIH application the following must hold true:

  • Compensation from the research grant(s) is limited to part-time employment and apart from normal full-time training (education) activities
  • Activities must be required by the research award
  • Effort on the research award is up to 50% while school is in session and 100% during intersession
  • There will be an employer-employee relationship
  • Total compensation may not exceed an amount equal to the zero-level Kirschstein-NRSA stipend in effect when NIH issues the research award and is inclusive of all NIH sources
  • Compensation must be provided in accordance with University policies, supported by acceptable accounting records, and applied consistently to both federally and non-federally supported activities
  • Compensation may not be paid from a research grant that supports the same research that is part of the graduate student’s planned training experience as approved in the Kirschstein-NRSA individual fellowship application
  • The work performed on a research grant may in no way interfere with, detract from, or prolong the graduate student’s approved Kirschstein-NRSA training program

Compensation is not considered stipend supplementation if the above criteria is met and, therefore, is allowable under the NIH policy.

For those GSRs currently funded by NIH research grants or cooperative agreements, a review is being completed annually to ensure adherence to this policy. Any compensation over the policy limit will need to be absorbed by a non-NIH funding source. Please take active measures to review all compensation for GSRs that are working in your departments. Your review should be completed using the Award Year of the funding.

For more information, please refer to the Graduate Student Researcher Compensation Guidance.  If you have questions about GSR compensation, contact CGA Compliance.