Some costs do benefit the sponsor and may be offered to meet required cost sharing. In most cases they are not captured in cost sharing because they do not affect organized research base. These may include the:

• difference between full tuition and that charged to a sponsored project
• value of any waived indirect costs or fringe benefits
• value of the indirect costs associated with any direct costs being cost shared

For FAQs on Cost Sharing please visit Brown University Office of Sponsored Projects FAQs on Cost Sharing 

Federal awards: Funds from a federal award may not be utilized as the source of cost sharing except.

Non-federal awards: Per federal regulations funds from non-federal awards may be utilized as the source of cost sharing only if authorized by the non-federal sponsor.

Unless sponsor policies state otherwise, supplemental funding will be considered new funding. Any application for new uncommitted funding, such as a supplement, should incorporate the new rates.

Exception: The National Science Foundation has a policy of funding supplemental support using the negotiated indirect cost rate(s) approved at the time of the initial award, so supplemental proposals to NSF should use the original agreement's rates. See NSF PAPPG Chapter X.D.1.d.

Carryover is subject to the F&A rate in effect when the costs are incurred.

The sponsor should use the F&A rate in place at the time the award is made. In this case, the award should incorporate the lower F&A rate of 58.5% in effect on August 1, 2020 with no change in Direct Costs.

Rates currently in effect on active awards will be continued until the end of the current competitive segment. A competitive segment is a period of years approved by the sponsor at the time of the award. Existing projects will continue with the current rate as indicated in the award document until the end of the current award period or competitive segment.

Example:

Project Period: 07/01/2012 – 06/30/2022
Competitive segment: 07/01/2018 – 06/30/2022
Budget Period: 07/01/2019 – 06/30/2020

F&A rate in Notice of Award for competitive segment: 62.5%

The 62.5% rate as specified in the notice of award for this competitive segment through 6/30/22.

There is a new F&A Information Website dedicated to understanding how the F&A rate change of 2020 will be applied.

F&A FAQs

The OMB issued a clarification memo in 2001 that stated "most Federally-funded research programs should have some level of committed faculty (or senior researcher) effort, paid or unpaid by the Federal government." In addition, The National Institutes of Health (NIH) Grants Policy Statement notes that "...'zero percent' effort or 'as needed effort; is not an acceptable level of involvement for 'key personnel'. These requirements do not apply to:

• equipment/instrumentation awards
• dissertation support, training grants or other awards intended to be student augmentation; and 
• travel awards

• The primary objectives of the mentored K awards, and other Career Development Awards, is to provide training necessary for candidates to become independent investigators. So while the K award PI is an Assistant Professor/junior faculty they have not yet obtained an R01 or equivalent major grant.
• If the proposal is a Career Development Award, as defined by the sponsor, it requires a mentor and the mentor must be named as an Investigator in Coeus. The mentor's role is defined in the funding announcement and is responsible along with the candidate for planning, direction, and execution of the proposed career development program and research project. The URI RI-INBRE Faculty Early Career Development Award proposals are considered Career Awards and have a mentor component.
• Brown University's COI policy further defines an Investigator as PI or any other person (i.e., mentor) who is responsible for the design, conduct or reporting of the research on the project as defined by NIH or NSF for conflict of interest purposes. The PI and any named Investigator is then required to submit the Assurance of Compliance along with the ID&A.
• The Additional Investigator questionnaires are used to identify any additional individuals, other than the PI, who are responsible for the design, conduct, or reporting of research on the project as defined by NIH or NSF for conflict of interest purposes.

In order for the University to fulfill this responsibility it is necessary for PIs to have an appropriate affiliation with the University which satisfies one of the following conditions: 

a. Be employed by the university as a faculty member (all ranks) including "research" faculty.

b. Exempt staff members including technical staff, administrative staff, and research staff, and retired faculty or staff member having emeritus may also apply with the approval of the appropriate department chairperson and senior University officer.

c. Be employed by an affiliated hospital, and hold a full-time appointment in a section of the Program in Biology or in a department of the Program in Medicine. Although generally employed by affiliated hospitals, medical faculty are considered University faculty for the purpose of serving as PIs and submitting proposals for external support. If the proposal requests compensation from the University for released time from an affiliated hospital, the hospital will be asked to concur and to provide the University with an assurance of compliance with AA and EEO regulations during the initial hiring process. Adjunct faculty, visiting as a graduate student at the University and have the proposal approved by the department chairperson and senior University officer.

d. Be enrolled as a graduate student at the University and have the proposal approved by the department chairperson and senior University officer.

e. Be appointed as a post-doctoral fellow, research associate, research fellow, faculty fellow or equivalent. These appointments may allow for sponsorship (financial support) from other sources that either (1) require the involvement of Fellowships, intergovernmental personnel Act Agreements, etc., or (2) do not require any University involvement e.g., Guggenheim or Fulbright Fellowships.

f. Having a "visiting" or "adjunct" appointment at the University which complies with the University's policies on Affirmative Action and Equal employment opportunity. Note: Exceptions to these policies may be made with the approval of the appropriate university officer when such an appointment is without compensation. Individuals so appointed may not receive compensation as a result of a later University action without first complying with AA and EEO requirements.

• Principal Investigators (PI), Co-Principal Investigators (Co-PI), Co-Investigator (Co-I), All Investigators in a Multi-PI proposal submission (Multi-PI) are considered "Investigators" and are entered on the Investigator Tab.
• An "Investigator" means the principal investigator and any other person who is responsible for the design, conduct, or reporting of research.

If more than 5 PIs, science is applicable to Center/Institute and involves cross-divisional investigators, then the Center or Institute is the Administrative Core and responsible for coordinating the submission through the various PI's academic home departments.

Division of Biology & Medicine Proposal Submission Policy

• The Sub-recipient will contribute substantively to the scholarly & scientific conduct of the project and will have responsibility for decision making, and may participate in writing technical progress or final reports. The sub-recipient will provide unique knowledge and expertise to the project and conduct the work independent of Brown's direct supervision. A sub-recipient's performance will be measured in relation to whether objectives of the federal grant were met. The scope of work to be performed utilizes the facilities, employees and resources of the sub recipient.
• A Contractor provides the same goods/ services to others as it will to Brown. A contractor normally operates in a competitive environment and provides goods/services that are ancillary to the operation of the funded project.

Please review this chart for the difference between Other Support for JIT, RPPR, and Biosketch research support sections. 

It is acceptable for senior personnel to commit time and resources to a project without requesting salary. In this case, an aggregated description of the resources that will be provided, should the proposal be funded, should be included in the Facilities, Equipment and Other Resources section of the proposal. That description should be narrative in nature and must not include quantifiable financial information. This is considered voluntary uncommitted cost sharing, which is permissible on NSF proposals. 

Note: Requires BioMed Approval.

The Home department of the PI or majority of PIs of the research performance is the submitting department.

Division of Biology & Medicine Proposal Submission Policy

If less than 5 PIs, then the Home Department of majority of PIs, or Home Department of Administrative Core.

Division of Biology & Medicine Proposal Submission Policy

The total cost of sponsored research includes a combination of direct and facilities and administrative (F&A) costs. Both types of expenditures are key to Brown’s ability to conduct research.

On-campus: Sponsored activities which take place in buildings and facilities owned by Brown and for which the University is bearing the space costs from University funds.

Off-campus: Sponsored activities take place on land, in buildings or facilities (e.g., research vessels) not owned or leased by Brown at locations where Brown’s facilities-related indirect costs do not cover these location costs. For space used for off‐campus research, an external source (typically, a sponsor) provides funding by paying directly for space as a budgeted direct cost, by reimbursing Brown for its costs in renting or leasing or travel costs associated with the space as a budgeted direct cost, or by otherwise directly providing space for research at no charge.

Projects Conducted Partially Off-Campus: The on- or off-campus determination is based on the preponderance of project effort as expressed in the budget. For clarity, the determination is not solely based on the Principal Investigator’s effort. When 50 percent or more of budgeted Brown personnel time and effort is performed on‐campus, the on‐campus indirect cost rate applies; when more than 50 percent of budgeted Brown personnel time and effort is performed off‐campus, the off‐campus indirect cost rate (currently 26%) applies.

Note that any subaward or vendor service costs such as consultants are not included in the determination of on or off-campus rates.

Lastly, sponsored projects will not be subject to more than one type of indirect cost rate – a project is either “on” or “off” campus. Current rates for federal awards are found here. Foundations and corporate sponsors publish their own rates.

Cost of Research Infographic

Reminders regarding attachments for Grants.gov submissions:

• Attachments must have unique filename. For example, applications that include subawards  must use different names for the Brown budget justification and the subaward budget justification. They can’t both be named “Budget_Justification”.
• Please limit file names to 50 or fewer characters.
• Please use only the following UTF-8 characters when naming your attachments: A-Z, a-z, 0-9, underscore, hyphen, space, period, parenthesis, curly braces, square brackets, ampersand, tilde, exclamation point, comma, semi colon, apostrophe, at sign, number sign, dollar sign, percent sign, plus sign, and equal sign.
• Attachments should be flat ( not live) pdf files unless otherwise noted in the FOA

Attachments that do not follow these rules may cause the entire application to be rejected or cause issues during processing.

• The Program Director/Principal Investigator (PD/PI) and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they request salaries or compensation under the grant.
• Typically these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level should be included if their involvement meets the definition of key personnel.
• Consultants and those with a postdoctoral role should also be included if they meet the same definition.
• NOTE: Senior/key Personnel must devote measurable effort (described in person months) to the project, whether or not salaries are requested. "Effort of zero person months” or “as needed” are not acceptable levels of involvement for those designated as Senior/Key Personnel.

Total project costs.

In the interest of full transparency, recipients should err on the side of disclosure. Researchers should consult with their institutional officials for guidance to ensure compliance with institutional and NIH policies. NIH requires complete and accurate reporting of all sources of research support, financial interests and affiliations, both foreign and domestic.

• For an active project, the NIH grant application states that the level of effort (even if unsalaried) as approved for the current budget period should be listed.
• For pending projects, the NIH grant application states that the level of effort as proposed for the initial budget period should be listed.
• For grants that did not require submission of a stated percent effort or do not contain an “approved” level of effort, the actual/expected effort percentage should be shown.
• The percent effort on “Other Support” pages should be consistent with the percent effort shown on “Effort Reports” for purposes of salary allocation, unless there is a reasonable explanation for why the percent efforts are different.

NIH takes the issue of protecting the integrity of U.S. biomedical research seriously. When issues of noncompliance are identified, NIH will take action as outlined in the NIH Grants Policy Statement, Section 8.5. This may include withdrawing approval of the Program Director/Principal Investigator or other researchers contributing to the NIH award, imposing specific award conditions, disallowing costs, withholding future awards including the possibility of suspending or terminating the award.

NIH scientific program and grants management staff review Other Support information to ensure that:

• All resources, domestic or foreign, directly supporting the individual’s research endeavors have been reported
• Sufficient levels of effort are committed to the project
• There is no scientific, budgetary, or commitment overlap
• Only funds necessary to the approved project are included in the award

No. Other Support includes ALL financial resources received in direct support of research (including pass-through funding). This includes grants for which the individual does not receive salary support under the grant.

No. If an individual receives funding for a grant in which that individual will or may expend some research effort, even if a percent effort is not submitted to the sponsor, the grant must be listed as Other Support.

Yes. Other Support includes domestic research collaborations that directly benefit the researcher’s research endeavors. 

Yes. While the researcher is not receiving monetary compensation, the lab space, materials, and staff are resources made available to them in support of and/or related to their research efforts. Other payments, such as travel or living expenses must also be reported. As outlined in NOT-OD-19-114 this appointment must be reported as Other Support. NIH requires applicants to list all positions and scientific appointments both domestic and foreign held by senior/key personnel that are relevant to an application including affiliations with foreign entities or governments. This includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time, or voluntary (including adjunct, visiting, or honorary). 

Upload Other Support to the JIT link in Commons and notify BMRA pre-award staff who will review and arrange for submission to NIH.

No. NOT-OD-19-114 is a reminder for the extramural community of NIH’s Other Support policy, and its applicability.

No, subsumed effort is complementary effort and does not require prior approval but you do need approval for concurrent effort. For more information go here: https://grants.nih.gov/grants/policy/nihgps/HTML5/section_12/12.3.6_level_of_effort.htm ( see 12.3.6.1 and 12.3.6.2)

Yes. Available resources in support of and/or related to an investigator’s research endeavors should be disclosed even if they relate to work that is performed outside of a researcher’s appointment period. 

The total costs for the whole project.  If this is a large project grant (for example a P50), list only projects/core that the faculty member work on, list the total costs for the project/core.

Overlap Sample Statements:

• There is commitment overlap for Dr. XYZ between 5R01AG123456-01 and the application under consideration. If this application is funded Dr. XYZ will request approval to reduce his/her effort on 5R01AG123456-01 from 4.80 calendar months to 2.40 calendar months. If other pending applications are funded, Dr. XYZ will reduce his/her effort appropriately. 
• There is scientific overlap commitment overlap for Dr. XYZ  between aim 1 of 5R01AG123456-01 and aim 2 of the application under consideration. If this application is funded, Dr. XYZ’s effort will be adjusted on 5R01AG123456-01 to remove the overlap.  

Resolution of overlap occurs at the time of award in conjunction with applicant institution officials, the principal investigator, and awarding agency staff. NIH staff continue to monitor changes to other support information throughout the project as part of the annual progress reviews.

The NRSA fellow is not entitled to keep computers purchased with the Institutional Allowance (IA). IA is under the direct administrative control of the sponsoring institution, which has sole spending authority on behalf of the fellow and in accordance with its policies. However, you may negotiate with the institution if you wish to keep a piece of equipment. NIH is not involved in those decisions.

See here.

Yes – the cost of meals for subject participants is allowable on a Federal Grant.

Note – be careful to only include necessary Brown University staff in this event. While it may be necessary to have staff on hand for the event, we should not charge the grant for unnecessary Brown University participants. 

Yes – the cost of meals/refreshments during a Conference/Seminar/Meeting with a formal agenda and participants from different locations is allowable.

Note: It is not allowable to charge the grant for Brown University staff/faculty meals when taking the out of town participants to dinner following the all day meeting.

Yes - The cost of meals for subject participants is allowable on a Federal Grant. 

Yes – the cost of meals/refreshments during a Conference/Seminar/Meeting with a formal agenda and participants from different locations are allowable.

Yes and No - the cost of the meal for the candidate may be charged to the grant, but the cost of the meal for the PI is not allowable.

No – the cost of meals/refreshments for routine lab meetings are not allowable.

No – the cost of refreshments/meals for routine training sessions and meetings of Brown University students/trainees/faculty/staff are not allowable.

Provided there is not a change in objective or scope, or reallocation of funds that were previously approved for participant support, NSF grants awardees the authorization to transfer funds from one budget category to another for allowable expenditures including funds for faculty salary. No prior approval from NSF is necessary. 

Yes, purchases in the final months of an award are an area of interest to auditors. 

Below are examples of unacceptable direct costing practices

• End of award: purchasing items to exhaust unobligated balances 
• Assigning charges on the basis of the remaining balance to resolve availability of funding issues or to avoid loss of carry-forward balances 
• Assign charges to an award before the cost is incurred 
• Charge an expense exclusively to a single award when the expense clearly has supported other activities 
• Rotate charges among sponsored projects without establishing the direct benefit to each project 
• Assign charges to the sponsored projects with the largest remaining balance 
• Assign charges to the sponsored project on the basis of ability to pay (i.e. largest budget) 
• Charge the budgeted amount rather than the amount based on actual usage 
• Describe a cost as something other than what it is (e.g. describing office supplies as lab supplies) 
• Below is an example of recent audit findings at The University of Florida :

Inappropriately Allocated Purchases Near Grant Expiration

• UF inappropriately charged five NSF awards a total of $35,648 in expenses associated with purchases near the awards’ expiration dates, when UF had little to no time to use the purchases to benefit the awards.

*In December 2016, UF charged NSF Award for $4,502 in costs incurred to purchase lab supplies. Because UF purchased the supplies during the final month of the award’s 5-year POP, UF does not appear to have allocated the cost of these items to this award based on the relative benefits received.

*In February 2018, UF charged NSF Award No.  for $8,900 in costs incurred to purchase materials for specimen testing. UF purchased the materials during the last five days of the award’s nearly 6-year POP and does not appear to have received the materials before the grant’s expiration date. As such, UF does not appear to have allocated the costs of these materials to this award based on the relative benefits received.

• UF agreed to reimburse NSF for these expenses.

The cost of the dinner for the consultant would be allowable to charge to the grant as the consultant is in travel status. The cost of the dinner for the PI or any other Brown University faculty/staff attending the dinner would NOT be allowable as they are not in travel status.

• If you are trying to complete a PAA and receive an error message regarding an outstanding ECR then you must first complete the outstanding ECR before submitting the PAA.
• In addition if there is an outstanding PAA that has not been processed, then an ECR cannot be run. All PAAs need to be processed for an ECR to run.

If an employee is being terminated then a paper form will need to be completed. A Semi-Annual should not run for the employee the next time around, if it does contact ECM to fix.

No, the comments section cannot be changed once they are there. If you type comments and then go back to the first page the comments cannot be changed. If you have a complicated ECR which requires many comments and would like some guidance you can send comments to the ECM via email for review and guidance.

The department corrects costing on the ECR, adds a line to the effort report using FD120, Grant Worktag, and Expense Purpose Code, then processes PAA to reflect the change on revised ECR. A new ECR is not needed. The revised ECR is the report of record along with the supporting documentation that is added to the effort report.

If there is no payroll data then an Effort Report is not generated. The ECP needs to process a PAA to reflect costing change. The ECP needs to process PAA using FD120, Grant Worktag, and Expense Purpose Code and reduce FD100 line. Once PAA is processed then contact the ECM so an effort report can be generated. Any supporting documentation should be added to these effort reports.

Please visit NIH FAQ on NIH No-Cost Extension and Effort.

NIH FAQ

Summer salary is defined as any compensation paid during the summer period to a faculty member in excess of his or her academic-year salary. The summer period is defined to be the period outside Institutional Base Salary of the academic year appointment.

A faculty member may work on more than one sponsored program and receive summer salary from each one, but no more than 100% effort is committed each month to the combination of the sponsored programs. In addition, the faculty member must include in the cumulative total of effort any other university responsibilities during the summer (e.g., departmental administration, student advising, curriculum review, professional development).

Certain agencies place caps on summer salary that can be paid to faculty members working on sponsored programs. If applicable, agency salary caps supersede university regulations (i.e., NSF and NIH). The National Institutes of Health (NIH) allows summer salary but the total amount the faculty member can charge during the year is limited to “Executive Level I of the Federal Executive Pay scale.”

• Effective January 5, 2020 Federal FY20 Cap: $197,300 or $16,441.67/month total two month cap = $32,883.33        

No, Brown University adheres to federal regulations, which specifically prohibit the use of sponsored program funds to “increase or supplement faculty salaries above the institutional scale for an individual’s salary.”

The payment of summer salary obligates the faculty member to provide the proposed percentage of effort work on the sponsored program for the full period for which compensation is paid. A faculty member who requests summer salary for 100% effort* on sponsored program activities for all 2 months of the summer must forego vacation entirely during the two summer months.   *Requires prior approval

• No, Federal regulations stipulate that summer salary from sponsored programs “must be for actual work performed on the sponsored program from which the funds are paid and must be paid for personal services performed during the period stipulated.” In particular, a faculty member cannot be paid in the summer period for work that was done on a sponsored program in the previous 10-month academic year, nor can the faculty member be paid for work that will be done in the following 10-month academic year. Grant and contract sponsors require written Certification of Effort reports signed by the faculty member that document the time and effort spent on a sponsored program during the period in which the grant work was carried out and for which an individual is being compensated.

• Example: Professor Smith’s IBS for the 10-month academic year is $100,000 and she proposes to devote 40% effort to a sponsored project during one month of the upcoming summer. The summer salary to be charged to the sponsor for Professor Smith’s work/effort on the project will be paid at the rate of 1/10th of $100,000 or $10,000 for each month of the summer. Because her percent effort on the project will be 40% during one summer month, a total of $10,000 x 0.40 or $4,000 will be allocated for Professor Smith’s summer salary.

Federal regulations stipulate that summer salary (Per Uniform Guidance Summer Salary is referred to as “period outside of the academic year pay”) supported by sponsored programs must be “computed and paid at a percent effort rate not in excess of the faculty member’s official Institutional Base Salary (IBS) divided by the number of months in the period for which that IBS is paid.” Therefore, the summer salary for full-time 10-month faculty members working in the summer must be paid at a rate not to exceed 1/10th of the annual IBS of the academic year for each of the two months of the summer period. Summer salary is limited in each case by the terms of the supporting grant or contract and must be in accordance with granting agency policy.

• Note: Academic year salary paid over 10 months – 2 months academic year paid in summer
• Note: Academic pay over 12 months is not summer salary and cannot be costed in the summer on grants

Answers to more Pre- and Post-Award Frequently Asked Questions for Ruth L. Kirschstein NRSA Predoctoral Institutional Research Training Grants (T32) can be found on the NIH website.

NIH T32 Frequently Asked Questions

Qualified research or training activities for minimum of 20 hours/week for 12 consecutive months. Patient care or activity unrelated to biomedical or health‐related research or teaching does not qualify.

• xTrain is a Web based program part of eRA Commons. Allows PIs, administrators and trainees to create, route, submit and track completed required training grant forms electronically. Fellow must have a eRA Commons to be appointed.
• 2271 Statement of Appointment, Re-Appointments, & Amendments
• 416 Termination Notices

A Trainee must be 100% effort and 1.0 FTE. Written requests for part-time training will be considered on a case by case basis (usually due to health or family concerns).

• Post doc graduation date = degree conferred
• “Relevant Experience” may include:
• Research experience outside the Institution
• Clinical duties
• Residency
• Internship
• Teaching assistantship
• Time spent in a health related field beyond that of qualifying for a doctoral degree.
• The PI determines if experience is relevant, and may have to justify assessment to the NIH.

Trainee-Related Expenses GPS 11.3.8.4

A fixed amount of funds are provided to cover costs associated with the trainee and program. These funds can be used for any expenses that support the trainee and are allowable on federal awards. Some examples of costs include staff salaries, consultant costs, equipment, Trainee lab supplies, staff travel and other expenses directly related to the training program.

E-mail or fax a notarized statement certifying that you are in possession of a Permanent Resident card (green card) USCIS Form I-551 to your grants management specialist with a copy to BMRA. You need to do this before your fellowship can begin. If your green card is being approved for renewal, you can submit a notarized statement certifying that you are in possession of Form 1-90, which was provided to you when you filed for your new green card. Once you have received your new green card, you must send a notarized statement certifying that you have your green card to Grants Management Specialist. Sample Letter

Yes. Depending on the size of the training program, PI/PD is expected to spend between 5 and 10% of their effort on the training program. Review Table of Institute/Center information for institute specific requirements. In the Division of Biology and Medicine salary associated with PI/PD effort will not be charged to the T32 award . A complete cost-share form is needed at proposal stage to document approval of mandatory program director effort and associated salary and fringe. ​ See T32 Parent FOA for Institute specific requirements.

Yes, to attend scientific meetings & workshops deemed necessary for training experience. However, allowability not uniform across institutes so check award notice.

The aggregate NRSA support limitations are:

• Predoc: 5 year limitation
• Postdoc: 3 year limitation

From grantsmanship perspective, trainees should remain on a T32 for a minimum of 2 years

By completing a second year of NRSA support, or engaging in an equal period of research or health related activities; or financially.

The Statement of Appointment (Form PHS 2271) should be submitted at the time of the trainee's appointment and is required for new appointments, re-appointments and amended appointments. Grantees must submit the PHS2271 data electronically using the xTrain system. The Termination Notice (Form PHS 416-7, also submitted via xTrain), is due within 30 days of the end of training grant support and is required for all students terminating from a training grant. The necessary forms can be found at fellow_and_trainees forms.htm. 

Not as a general rule. An unliquidated obligation is a cost that has been incurred but not yet paid or recorded. Although stipends and tuition are obligated for the full 12-month appointment from the budget period in which the appointment is initiated, this is not true for trainee travel or training related expenses. Charges from these categories are only made to the grant when actual expenditures are incurred. Therefore, only an actual charge for travel or training related expenses that has not cleared before the end of a budget period can be treated as an unliquidated obligation.

Excerpt from the NIH Grants Policy Statement: "Project funds may not be used for a prospective trainee's travel costs to or from the grantee institution for the purpose of recruitment. However, other costs incurred in connection with recruitment under training or manpower programs, e.g., advertising, may be allocated to a grant-supported project according to the provisions of the applicable cost principles concerning recruitment costs."

No. Described in this manner, these would be considered entertainment costs and as such are unallowable.

Public Health Service funds may not be used to supplement an NRSA stipend. Trainees are required to devote fulltime effort to the training program. However trainees may receive separate salary from an NIH grant when employed for services, such as laboratory technical assistance, on a limited part-time basis. Part-time is considered up to 25% time ( e.g., 10 hours per week). Compensation may not be paid from a research grant that supports the same research that is part of the trainee’s planned training experience. Under no circumstances may the employment interfere with, detract from, or prolong the trainee’s approved NRSA training program.

Training PD/PIs must approve all instances of employment on research grants to verify that the circumstances will not detract from or prolong the approved training program.

For additional information see the NIH Grants Policy Statement, Section 11.3.10.2 Compensation. 

Trainees can be appointed at any time during a budget period, for an entire 12-month period. In doing so, the entire 12-month stipend and tuition is charged to the current year. Thus, an appointment period can technically overlap into the next budget period. Since the entire 12-months stipend and tuition is charged at the time of the appointment, that amount not yet expended at the end of the budget should be reported as an unliquidated obligation on the FSR.

• No, Trainees are not providing a service to the institution, and are therefore exempt from effort reporting.
• Stipend Supplementation is certifiable

NIH does not encourage such an appointment because of the limited training experiences a new trainee would receive as well as the difficulties it poses to the trainee in fulfilling payback requirements. However, reappointments of current trainees to the full extent of the remaining budget is possible. Some institutes require pre-docs have a higher priority than post-docs if the budget is limited during the no-cost extension phase because post-docs have more flexibility to move elsewhere.