OMB Clarifies Guidance on the Dual Role of Student and Postdoctoral Researchers

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Release Date: October 10, 2014  

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National Institutes of Health (NIH)


The Council on Financial Assistance Reform (COFAR) and the Office of Management and Budget (OMB) issued a clarification related to the role of graduate student and postdoctoral researchers engaged in federally funded research projects on August 29, 2014.  The clarification appears within a set of Frequently Asked Questions related to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) which appear in the Code of Federal Regulations at 2 CFR 200.  The provisions of the Uniform Guidance will be in place for all federal awards beginning on December 26, 2014.

The clarification covers section 200.400-2 and states:

The Uniform Guidance states; ”For non-Federal entities that educate and engage students in research, the dual role of students as both trainees and employees contributing to the completion of Federal awards for research must be recognized in the application of these principles.” Staff in postdoctoral positions engaged in research, while not generally pursuing an additional degree, are expected to be actively engaged in their training and career development under their research appointments as Post-Docs. This dual role is critical in order to provide Post-Docs with sufficient experience and mentoring for them to successfully pursue independent careers in research and related fields.

Does 200.400(f) require recognition of the dual role of postdoctoral staff appointed on research grants as, both trainees and employees, when appointed as a researcher on research grants?

Yes, the Uniform Guidance 200.400(f) requires the recognition of the dual role of all pre and post-doctoral staff, who are appointed to research positions with the intent that the research experience will further their training and support the development of skills critical to pursue careers as independent investigators or other related careers.  Neither Pre-Docs nor Post-Docs need to be specifically appointed in ‘training’ positions to require recognition of this dual role. The requirements and expectations of their appointment will support recognition of this dual role per 200.400(f).  

This clarification applies to all NIH awards.


Office of Policy for Extramural Research Administration
Office of Extramural Research
National Institutes of Health
Telephone: 301-435-0949

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