NOT-OD-02-017: GRADUATE STUDENT COMPENSATION

Department of Health
and Human Services (HHS)
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GRADUATE STUDENT COMPENSATION

Release Date:  December 10, 2001

NOTICE:  NOT-OD-02-017

For the latest NRSA stipend  levels, please visit 
the NIH Training website: http://grants.nih.gov/training/nrsa.htm

April 25, 2011  - See Notice NOT-OD-11-067 This Notice supersedes NOT-OD-10-047, 
and establishes new stipend levels for fiscal year (FY) 2011 Kirschstein-NRSA 
awards for undergraduate, predoctoral and postdoctoral trainees and fellows, as 
shown in the table.

National Institutes of Health

INTRODUCTION

This notice establishes a new policy related to the level of 
compensation for graduate students supported by funds from National 
Institutes of Health (NIH) research grants and cooperative agreements.  
This notice supersedes the notice that appeared in the NIH guide for 
Grants and Contracts on December 2, 1998 
(http://grants.nih.gov/grants/guide/notice-files/not98-168.html).  
Under this new policy, the maximum amount awarded by the NIH for the 
support of a graduate student supported on a research grant or a 
cooperative agreement is tied to the zero level National Research 
Service Award (NRSA) stipend in effect at the time the grant award is 
issued.  The schedule for NRSA stipends can be found at 
http://grants.nih.gov/training/nrsa.htm.  Consistent with cost 
principles for educational institutions described in Office of 
Management and Budget (OMB) Circular A-21 at section J.41.b 
(http://www.whitehouse.gov/omb/circulars/a021/a021.html), the 
compensation of graduate students supported by research grants must be 
reasonable.  These operating principles associated with the 
compensation of students performing necessary work on NIH funded 
research projects are described in detail in the NIH Grants Policy 
Statement at http://grants.nih.gov/grants/policy/nihgps_2001/part_iia_4.htm.  
As before, the amount provided for compensation includes salary or wages, 
fringe benefits, and tuition remission.

These guidelines apply to graduate students at the grantee institution 
who are supported by NIH research grants and cooperative agreements and 
not to individuals supported by NRSA training grants and fellowships.  
NIH has separate appropriations to support research training under the 
NRSA authorization at Section 487 of the Public Health Service Act.  
The stipends provided to recipients of NRSA support offset the cost-of-
living during the period of training and are not considered equivalent 
to salaries or other forms of compensation provided to individuals 
supported on research grants.  Nevertheless, the entry-level 
postdoctoral NRSA stipend provides a useful benchmark for an award 
amount that approximates a reasonable rate of compensation for graduate 
students.  Anticipated escalations in NRSA stipends (see 
http://grants.nih.gov/training/nas_report/NIHResponse.htm) in future 
years should permit annual increases in the maximum award amount for 
such individuals.

BACKGROUND

In 1994, the Department of Health and Human Services Inspector General 
reported that three of the four universities reviewed where using 
Federal research grant funds to compensate graduate students at rates 
above amounts paid to first-year postdoctoral employees performing 
comparable work (http://oig.hhs.gov/oas/reports/region1/19404002.pdf).  
Since postdoctoral employees were considered to have more experience 
and training than comparable graduate students in this study, the 
excess compensation for students was considered unreasonable.  With 
encouragement from the OMB, the NIH developed guidelines to establish 
the maximum award for graduate student compensation in 1995 
(http://grants.nih.gov/grants/guide/notice-files/not95-141.html).  The 
maximum award amount was modified in 1996 and again in 1998.  This 
document ties the amount awarded for graduate compensation to an NRSA 
stipend amount that is likely to be adjusted for increases in the cost-
of-living in future years. 

OPERATING GUIDELINES

For all new and competing grant and cooperative agreement awards, the 
NIH will provide reasonable amounts for graduate compensation, 
consistent with the requested budget for the position(s) and up to the 
currently effective NRSA zero postdoctoral stipend level.  For example, 
in FY2002 until a NIH budget is finalized, any competing awards issued 
will use the FY2001 level of $28,260.  Once FY2002 stipend levels are 
established, awards will be issued using the new (yet-to-be-determined) 
higher level.  As in the past, no adjustments will be made to 
noncompeting total cost award levels or future year commitments.  NIH 
staff will review the compensation requested for graduate students on 
competing and cooperative agreement applications for which a detailed 
budget is submitted.  NIH will not request nor accept budgets for those 
applications using a modular budget format solely for the purpose of 
reviewing graduate student compensation.  

Grantees are reminded that when submitting detailed budgets that 
request support for a graduate student, actual institutional-based 
compensation should be requested and information justifying the 
requested compensation level should be provided.  If not provided, this 
information will be obtained from the institution"s business office for 
any request that appears excessive.  NIH institutes and centers will 
review the requested compensation level and, if considered reasonable, 
will award the actual amount requested, up to a maximum equal to the 
NRSA zero level postdoctoral stipend.  Revised budgets submitted solely 
to adjust requested levels for graduate students will not be accepted.  
Institutions may continue to rebudget funds to charge more than the 
awarded amount provided that OMB cost principles requiring reasonable 
compensation are observed.  In general, graduate student compensation 
will not be considered reasonable if in excess of the amount paid to a 
first-year postdoctoral scientist at the same institution performing 
comparable work.  

INQUIRIES

These guidelines are effective immediately with new and competing 
awards issued on or after the date of this announcement.  No 
adjustments will be made to any competing FY2002 awards already issued.  
However, grantees may rebudget to accommodate the higher compensation 
level.  Questions should be referred to the grants management 
specialist identified on the notice of grant award.
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