NIH Graduate Student Compensation

Graduate Employee (GE) Appointments 

Definition 

A Graduate Employee (GE) Appointment at the University of Oregon enables Graduate Students to work part-time while pursuing their graduate degree.  A GE is often funded from a Sponsored Award to cover salary for effort spent on the Award, associated fringe benefits, and a portion of tuition and associated fees. This funding for salary, associated fringe and tuition coverage is referred to as Graduate Student Compensation. UO uses the definition as developed by the National Institutes of Health (NIH)

GE appointments are different than funding issued under: 

  • salary received as part of a UO paid staff position. 

University of Oregon Policy generally defines GE appointments as three terms of commitment at .49 FTE and up to 1.0 FTE during the summer term. This is considered a full commitment over 12 months. 

NIH Graduate Student Compensation Limits 

NIH Grants Policy Statement 2.3.7.9. Graduate Student Compensation, limits the maximum amount NIH will award for the support of a graduate student on a research grant or a cooperative agreement. The NIH limit is tied to the National Research Service Award (NRSA) zero-level stipend in effect at the time the grant award is issued on the Federal award date. The reason for this is a graduate student appointment (GSA) should not receive more compensation than a Post Doc doing similar work. For additional information, see NOT-OD-02-017

The “zero-level” limitation can be the cause of confusion between a UO GE and funding on a Training Grant. A UO GE on an NIH Research Grant or Cooperative Agreement is not the same as a UO Trainee appointed to an NIH Training Grant; NIH uses the NRSA stipend level to set the funding (not expenditure, see below) amount for a UO GE. 

While this is a limitation on the amount of funding provided by the NIH, it may not necessarily be a limitation on the amount of compensation actually paid to a GE (see below).  

Budgeting for a GE on an NIH Research Grant or a Cooperative Agreement 

For those proposals where a GE is included on the proposal budget for an NIH research grant or a cooperative agreement, Sponsored Projects Services recommends including additional language in the Budget Justification detailing the amounts budgeted (funding requested) for the GE(s). 

An example of the additional language added to the Budget Justification appears below. 


Graduate Student Compensation: Per NIH Grants Policy Statement 2.3.7.9. Graduate Student Compensation, the maximum amount NIH will award for the support of a graduate student on a research grant or a cooperative agreement is tied to the National Research Service Award (NRSA) zero-level stipend in effect at the time the grant award is issued on the Federal award date. 

University of Oregon Policy generally defines Graduate Employee appointments as three terms of commitment at .49 FTE and up to 1.0 FTE during the summer term. This is considered a full commitment over 12 months. The annual costs requested and budgeted per Graduate Student on this project budget are displayed below: 

  Year 1 Year 2
Annual Salary $26,648 $26,648
Fringe Benefits $11,386 $11,386
Tuition $15,726 $15,726
     
Total $53,760 $53,760

 

 

 

 


If it is anticipated the actual amount paid to a GE will exceed the “zero-level” (see below) and that amount is included in the proposal budget, NIH may reduce the amount of funding by the amount included in the proposal that is in excess of the “zero-level.”

Amounts over the NIH Limitation: In some departments, the minimum pay for a GE may be greater than the “zero-level” amount funded on an NIH award.  In this case, departments may: 

  • Plan to charge the amount over the NIH funded amount to a non-federal funding source (e.g., department funds); or 

  • Re-budget the GE costs as authorized under the terms of the NIH Award (see below). 

Re-Budgeting 

NIH may allow for re-budgeting, without their approval, to accommodate the amount allocated within the budget and paid to a GE under the following conditions: 

  • The amount paid to a GE is “reasonable.” Institutions may continue to re-budget funds to charge more than the awarded amount provided OMB (Uniform Guidance, 2 CFR 200) 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; and 

  • There are sufficient funds in the NIH Award to accommodate the payment to the GE(s) while at the same time ensuring that the terms and objectives of the award will be completed without the need for any additional funding from the NIH. 

Take the following steps to determine if the NIH award allows for Re-budgeting: 

  • Review the terms of the NIH Award to identify any requirements for Re-budgeting or other restrictions on GE funding.  If the Award is silent then, 

  • Review the Program Announcement the Award was issued under.  If the Program Announcement is silent on Re-budgeting or other restrictions on GE funding then, 

  • Review the NIH Grants Policy Statement (GPS) and follow the guidelines for Graduate Student Compensation in section 2.3.7.9 of the NIH Grants Policy Statement.  

NIH Increases in Zero-Level Amount 

If, after an Award with a GE included in the award budget has been issued, the NIH increases the “zero-level” amount, the departments may increase the amount paid to the GE provided there are sufficient funds in the award to cover the increase. Departments may re-budget to allocate the funding to cover the increase assuming that re-budgeting is allowable and the terms and objectives of the award will be completed without the need for any additional funding from the NIH.