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We all know postdocs don’t spend every moment at the bench. I think everyone would agree that attending a professional meeting and presenting research results is a critical part of a postdoc’s expected responsibilities. However, lately we’ve had a number of inquiries about which activities postdoctoral fellows are allowed to perform as part of their official duties supported by NIH grants. It’s possible that the confusion arose from the recent activities surrounding cost principles for government-funded research. I’d like to try to clear up any misconceptions and highlight the NIH policies that address this issue.
Postdocs supported by research grants are employees of the institution. The NIH’s grants policy on salaries and wages follows the Office of Management and Budget’s (OMB’s) Cost Principles Circular A-21, the guidelines that describe what costs educational institutions can and can’t charge to federal grants and contracts. Some Rock Talk readers may recall that OMB recently asked for public comment on proposed reforms to Circular A-21, and some of these proposed reforms include research community feedback collected by the A-21 Task Force I co-chaired with leaders from the Department of Defense and OMB.
So, what constitutes appropriate postdoctoral fellowship activities that can be charged to research project grants and other sponsored agreements? The guidelines allow compensation for all activities that contribute to and are intimately related to the work supported by the award, and that are consistent with the institution’s employment agreements with individuals in comparable positions. So, delivering special lectures, writing reports and articles, participating in seminars, consulting with colleagues and graduate students, and attending meetings and conferences can be supported according to these guidelines.
Postdocs supported by their National Research Service Award (NRSA) receive stipends set by NIH, and they are expected to devote their full time to the proposed research training, as outlined in Section 11 of the NIH Grants Policy Statement. When the stipend levels set by NIH change, revisions are posted in the NIH Guide (see NOT-OD-12-033 for fiscal year 2012 levels). Since the purpose of an NRSA postdoctoral traineeship or fellowship is to continue training for a career in research, all activities that contribute to this goal are permissible under these awards. Such activities might include laboratory research, writing research reports, reviews and journal articles, and attending and presenting at scientific conferences and seminars. Other training-related activities that would enhance a future scientific career might include teaching or overseeing students on projects related to the fellow’s or trainee’s research training experience.
I hope this helps clarify any misconceptions of NIH-supported postdoctoral activities, and allows postdocs to get the most out of their experience in this stage of their careers.
It is absolutely mind-boggling that you have ignored the obviously most-important-by-far practical question:
Can post-docs supported by NIH RPGs devote any of their supported effort to writing competing NIH grant, fellowship, or career award applications? And what about if they are supported on an NRSA?
I’ve wondered about this too. It’s allowable for K awardees under the rationale that “Research independence is achieved through applying for other research support” (http://grants1.nih.gov/grants/guide/notice-files/NOT-OD-11-002.html). Given that research independence is also a primary goal al of the NRSA program it seems that the same should apply there. I’d like for it to be true of postdocs on RPGs also, but then postdocs on RPGs generally do the grunt work and wouldn’t have time for proposal writing.
Good question. The answer differs depending on whether the postdoc is on an RPG or supported by an NRSA.
RPGs: If a post-doc is being supported 100% from the NIH RPG, then 100% of their reimbursed time and effort must be devoted to the research grant and in accordance with the employment agreement with the institution. Depending on the particular employment agreement, devoting time to writing a unique grant application (research, individual fellowship, or career award) may be allowable if it is somehow related to the RPG.
NRSAs: For an individual supported by an NRSA, individuals are considered to be in 100% training status, devoting 100% of their time to activities that contribute to the goal of a career in research training. Therefore, writing a unique grant application (research, individual fellowship, or career award) would be an appropriate activity as long as it is for their own research and not another researcher.
The answers are still beating around the bush on the real questions. Can the postdoc help write the renewal of the RPG? This would seem to be in line with the purpose of the RPG. What if the renewal does not score well, and in the no-cost extension period, the PI decides to submit a new grant. Can the postdoc assist, especially with obtaining preliminary results for the new grant? What if the postdoc wants to soon enter the job market, and needs to write his own proposal for a second postdoc, or for a K99 unrelated to the RPG. If he is not able to write such proposal while funded by an RPG, WHEN EXACTLY CAN HE WRITE SUCH PROPOSALS? What funding source would allow this? What institution wants to pay its postdocs for funds that will be elsewhere? If a postdoc doesn’t get an NRSA the first time around, and must be supported by an RPG, is he forever forbidden from resubmitting his NRSA because he is not allowed to work on it due to the source of his paycheck. This is absurd. Let’s be honest, almost everyone has had a postdoc who has done these things. If NIH finds these are against the rules, it would be nice if they could provide a reasonable scenario in which these activities could be accomplished without RPG funding. Can I write in my RPG that all postdocs will spend 10% of their time writing/assisting with proposals? Can a postdoc help organize meetings? This is not at all what RPGs are about, so this issue really seems to be stretching it, but this was recently promoted by the ASCB president.
“Since the purpose of an NRSA postdoctoral traineeship or fellowship is to continue training for a career in research, all activities that contribute to this goal are permissible under these awards”
But where are the positions for all those trainees after the NRSA supported training? What is the meaning of training a lot people for a job for many years and not have enough positions for them?
I also am interested in the very important question raised above by Comradde PhysioProffe and am equally surprised that it was not addressed in your comments. Can a post doc devoting 100% effort to and being paid on an NIH grant (R01 and the like) be allowed to write an individual post doctoral fellowship?
” The guidelines allow compensation for all activities that contribute to and are intimately related to the work supported by the award, and that are consistent with the institution’s employment agreements with individuals in comparable positions”
What is a comparable position? If one were a postdoc in a lab on April 1 and then started their NRSA fellowship on April 2, would the position on April 1 be considered equal to the job the fellow is doing on April 2?
And if so, what is considered compensation? Is insurance considered a method of compensation?
The postdoc supported on a research grant is considered an employee providing service to the employer. They are compensated based on the employment agreement established with the employing institution. The individual supported on the NRSA fellowship is NOT an employee. They are considered to be 100% in a research-training status now, devoting full-time to the individual’s research training.
Compensation is different for each. The employee receives salary and applicable fringe benefits in accord with the employee agreement at the institution. The NRSA trainee/fellow receives a subsistence allowance (stipend) to help defray living expenses while in training. Certain other costs such as health insurance are also allowable costs to the NRSA if in accordance with institutional policy.
The list of appropriate activities for postdocs supported on research grants and those supported on training grants differs in at least one aspect – teaching. Teaching is included as an appropriate training-related activity for postdocs on training grants, but not for postdocs on research grants. Is this distinction made purposely?
Above all one needs to consider the time devoted to transitioning from a temporary position to a permanent position. Does the NIH support post-docs in that effort as part of the condition of their employment/training. This would include applications and interviews. Given the low probability of currently obtaining a permanent position this activity must be requiring considerable resources and time for all parties involved.
I’m curious about this too. I am on a NRSA and my current advisor has made it clear that he doesn’t want me to apply for jobs even though he doesn’t have guaranteed funding for me for next year. Truth is he is hoping that a grant we wrote gets funded so that I can stay because I am a critical team member. He threw out the old “job applications should be done on [my] own time and interviews should be done using vacation time” line as an obstacle. Is there such a thing as my own time when I’m a postdoc? I always feel like I have work I could be doing be it at home, in the office, on a bus… this is not a 40 hour/week position. Never could find information to clarify NIH position on this for trainees.
It’s a catch-22 here. How will a postdoc ever be able to get an NRSA or a K99 award in the first place, which often in practice relies on getting some preliminary data for the project, if they are supported initially by the PI’s R01 in order to be able to get their data?
My concern is about where to apply for Postdoctoral fellowships?
The funding opportunities for postdocs who are not American citizen are very hard to find.
DOD offers postdoc fellowships open to any nationality in prostate, ovarian and breast cancer research, including few other research disciplines. However, one should have less than 3 years of postdoc experience in order to qualify. If one is not working in cancer research or in DOD’s research interest fields, you lose the opportunity. NIH postdoc fellowships require the applicant to be a US citizen in order to qualify. Therefore, the only NIH mechanism left out is the K99 and unfortunately, not every international postdoc gets an opportunity to apply. Although I am not sure, the general opinion is that the percent of K99 obtained by international postdocs are significantly lower compared to that obtained by US citizens.
Many of the private and research society funding resources excluding the American Heart Association have limitations for applicants: 1. Applicant must be a US citizen. 2. Applicant should have less than 3 years of postdoc experience or 3. Applicant should be considered as a faculty in the department. There is big percent of international postdocs between 3 to 7 years of experience having no opportunity to become a faculty of the Department.
Therefore, it has become seemingly difficult to identify the right funding source for non-US citizens. I personally feel that the limitations for postdoc fellowship applications for non-US citizens is the major rate limiting factor for international postdocs timely transition to a faculty position.
Does NIH have any agenda to increase the funding opportunity for non-US citizens? With the majority of postdocs in the country being non-US citizens, it is appropriate to increase the funding opportunity for them.
The article was minimally useful, mostly reinforcing the obvious. The readers’ comments raise a few of the more subtle, important and interesting issues.
Perhaps the article would have been more useful if it had provided a list of examples of things that would NOT be considered appropriate for trainees funded by an NRSA fellowship to do, and also compare and contrast this with postdoc fellows funded as personnel on RO1 or other types of grants awarded to institutions and directed by PIs.
However, I think that the last thing we need is a code of rules stating allowable activities for postdoctoral fellows (all of whom should really be considered trainees) that specifies different provisions these based on what type of NIH funding mechanism provides the stipend or support. That has the potential to evolve into something as byzantine as the IRS tax code!
As in most things, it is far better to rely on the best judgement of responsible people (in this case, faculty and principle investigators, with some slight guidance from local administrators), and apply corrective actions if practices that violate the intent of NIH funding become significantly prevalent.
OK, I realize I am a hopeless, retrograde dreamer who pines for simpler times when we actually could spend a majority of our time working on things that actually mattered to scientists!
What I, as a post-doc, am wanting to know is what does the NIH post-doc contract specifically state regarding holding a second job or part-time job, and how is that tracked? “100% of our time” should mean 40hours/week (although we all know that we work more, often with strange extra hours in the lab, and are not compensated for that). Am I not allowed to have a part-time job, let’s say, for example, bartending on off-hours (not ever allowing it to interfere with my post-doc responsibilities) to make extra money? Is this also not allowed? How is this tracked? I ask this because throughout graduate school and my post-doc, I am constantly under financial strain, living as a fully-independent single adult, maintaining healthy habits and lifestyle.