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<html lang="en-US">
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<HEAD>
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<TITLE>NIH Guide: GRADUATE STUDENT COMPENSATION </TITLE>
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<META NAME="Title" CONTENT="GRADUATE STUDENT COMPENSATION ">
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<META NAME="Publication_Date" CONTENT="March 15, 1996">
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<META NAME="Volume" CONTENT="25">
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<META NAME="Number" CONTENT="8">
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<META NAME="Keywords" CONTENT="GrantsAdministration/Policy+">
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</HEAD>
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<BODY BGCOLOR="#FFFFFF" TEXT="#000000">
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<PRE>
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GRADUATE STUDENT COMPENSATION
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NIH GUIDE, Volume 25, Number 8, March 15, 1996
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P.T. 34
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Keywords:
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Grants Administration/Policy+
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National Institutes of Health
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This notice supersedes the one that appeared in the NIH Guide for
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Grants and Contracts, Vol. 24, No. 18, May 19, 1995, about the
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compensation of graduate students with funds from National Institutes
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of Health (NIH) research grants, and also one published by the
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National Institute of General Medical Sciences (NIGMS) in the NIH
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Guide, Vol. 25, No. 1, January 26, 1996.
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In October 1994, the Department of Health and Human Services
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Inspector General reported that three of the four universities
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reviewed were using Federal research grant funds to support graduate
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students at total compensation rates that were considered
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unreasonably high. The compensation levels were deemed unreasonable
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because they exceeded amounts paid to first-year postdoctoral
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employees who were performing comparable work. Although the salary
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and fringe benefits portions of the compensation were found to be
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within these guidelines, the addition of tuition remission raised
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some compensation rates to levels deemed unreasonable.
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The Inspector General concluded that compensation paid to graduate
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students at rates greater than those by which individuals with more
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relevant skills and experience were paid were unreasonable. The
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findings of the audit were submitted to the Office of Management and
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Budget (OMB) with the suggestion that OMB Circular A-21, Cost
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Principles for Educational Institutions be revised to define
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reasonable compensation for graduate students. The Public Health
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Service has instructed NIH to issue interim guidance on this matter.
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There is a long-standing requirement in the cost principles that all
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costs applicable to grants, contracts, and other Federal agreements
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must be allowable, allocable, reasonable, necessary, and treated
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consistently. The May 19, 1995, notice in the NIH Guide did not
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establish new policy, but attempted to define the limits of
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reasonableness as required by existing policy. Further, it was
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expected that the guidelines would impact only those universities
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where total compensation for graduate students was at an excessive
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level. The following points and implementation guidance should
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assist those institutions where modifications to their compensation
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policies are necessary.
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o In accordance with PHS policy, tuition remission is an allowable
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cost when paid as a form of or in lieu of salary or wages to students
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performing necessary work, provided that:
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a. there is a bona fide employer-employee relationship between the
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student and the institution for the work performed;
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b. the tuition remission or other payments are reasonable
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compensation for the work performed and are conditioned explicitly
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upon the performance of necessary work; and
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c. it is the institution~s practice to similarly compensate students
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in non-sponsored as well as sponsored activities.
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o Total compensation includes salary or wages, fringe benefits, and
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tuition remission.
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o Consistent with OMB Circular A-21, costs that are unreasonable may
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not be charged to a Federal award.
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These guidelines apply to individuals who are employees of the
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grantee institution, not to individuals in a training status. NIH
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has a separate appropriation under the authorization of the National
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Research Service Act to award institutional research training grants
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and individual fellowships to support research training.
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OPERATING GUIDELINES
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NIH staff will review the compensation requested for graduate
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students on competing grant and cooperative agreement applications
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and those noncompeting applications for which a budget is submitted.
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NIH will not request budgets for those applications submitted using
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the streamlined noncompeting award process solely for the purpose of
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reviewing graduate student compensation. However, this does not
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eliminate the requirement that institutions take immediate action to
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ensure that reasonable rates of compensation are being charged to NIH
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research grants.
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When requesting support for a graduate student, the applicant
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institution should provide in the budget justification section of the
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application the basis for the compensation level. If not provided,
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this information will be obtained from the institution's business
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office for any request that appears excessive. NIH institutes and
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centers will review the requested compensation level and, if it is
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reasonable, will award the actual amount requested, up to a maximum
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of $23,000. Institutions may rebudget funds to charge more than
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$23,000 to the grant award, provided it is in accordance with OMB
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Circular A-21 requirements for reasonable compensation (e.g., does
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not exceed the amount paid to a first-year postdoctoral employee at
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the same institution performing comparable work).
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INQUIRIES
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These guidelines are effective immediately. Questions about these
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guidelines should be referred to the grants management specialist
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identified on the notice of grant award.
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.
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</pre> <P> <HR> <P> <P> <A HREF="/grants/guide/YearlyIndex/SelectedYear.cfm?theYear=1996">Return to 1996 Index</A><P><A HREF="/grants/guide/index.html">Return to NIH Guide Main Index</A>
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