Defining the Dual Role of Graduate Students and Postdocs Supported by Research Grants


Back in 2012 I blogged about what kinds of activities are allowable as part of the official duties of postdoctoral fellows supported by NIH research grants. At the time, NIH received a number of inquiries asking us if certain activities such as participating in seminars, attending meetings, or engaging in other activities designed to expand their scientific experience and knowledge or directly prepare postdocs for future employment could be charged to NIH grants. The confusion seemed to arise in part from the fact that postdocs on research grants are often considered  employees of their institution, and White House Office of Management and Budget (OMB) federal-wide cost principles were somewhat ambiguous about the role of students and postdocs on research grants.

The broader research community continued to express concerns about how the cost principles applied to those in training positions.  In order to address this issue, two interagency committees — the Research Business Models working group, which I co-chair with NSF,  and the recently chartered Graduate Working Group of the Federal Coordinating Committee on STEM Education – highlighted the need for further clarification on this topic.  As a result, OMB has published a clarification that both students and postdocs are engaged in training and that recognition of this dual role is critical to the development of a future independent research career.

A new document published by OMB provides frequently asked questions (FAQs) about cost principles related to federal awards. As described in section 200.400-2 of the FAQ document it states:

“For non-Federal entities that educate and engage students in research, the dual role of students as both trainees and employees contributing to the completion of Federal awards for research must be recognized in the application of these principles.” Staff in postdoctoral positions engaged in research, while not generally pursuing an additional degree, are expected to be actively engaged in their training and career development under their research appointments as Post-Docs. This dual role is critical in order to provide Post-Docs with sufficient experience and mentoring for them to successfully pursue independent careers in research and related fields.

I am pleased that OMB has taken this step to clarify as our partner institutions often struggled with how to charge, what are essential career development activities, to research grants.  Also it helps us and our partner grantee institutions fully implement one of the overall objectives of the NIH Biomedical Workforce Working Group: to prepare biomedical PhD students and postdoctoral researchers to participate in a broad-based and evolving economy which has been, in part, implemented through our important BEST program. My office issued a notice in the NIH Guide today to help inform our grantees.


  1. I am interested in this topic as the mom of a new doc, who may or may not decide to become a post-doc, depending on what he needs to do to retire debt. In the case of debt that is owed to an institution rather than to a bank, is there a chance a scribe-like function might serve to get credit when un-tenured docs attendetc.?

  2. Dear Dr. Rockey,

    Could you please provide further clarification about this new dual view of postdocs on research project grants, in particular on specifically what activities these postdocs may now be able to participate in while being supported by their PI’s research grants. For instance, can these postdocs, if they are interested, now teach one course a semester as this could be viewed as part of their training? Does this dual view of postdocs on research grants now pave the way for postdocs on training grants and fellowships to likewise be viewed in this dual capacity, and have the same employment relationship with their universities as postdocs on research grants?

    1. Salaries for postdocs charged to research grants need to be allowable and allocable just like all other costs described in the Code of Federal Regulations, 2 CFR 200.400. In general that means that a person receiving support from a grant would be treated in the same way as a person in a similar role being supported by the institution who is engaged in in similar activities. What kinds of activities are normal and consistent when supported by an institutional salary? It should be exactly the same for the costs charged to a grant. If the institution feels that students and postdocs should have teaching experiences and that should be a normal and reasonable part of the training plan for all students and postdocs, then it is probably an allowable cost. Institutions need to determine what is normal and consistent for individuals in student and postdoc roles. The principles are spelled out at 2 CFR 200.400.

      Individuals supported on Kirschstein-NRSA institutional training grants and fellowships are not considered employees of the institution; and 2 CFR 200.400(h) does not apply. Their compensation is stipends, not salary. Any training activities they participate in must be consistent with those proposed in the individual fellowship application and/or part of the approved training program supported by the institutional training grant.

      1. If a Kirschstein-NRSA institutional trainee’s compensation is a stipend and not salary, does this mean it is not taxable as income?

  3. This is a part of a bigger problem: that the research support does not cover all necessary scientific activities. More and more scientists are currently becoming reliant exclusively on extramural grant support; in many institutions – as a matter of policy. This is true even when their contractual obligations include educational, clinical and administrative activities. At the same time, not only administrative and educational activities are not covered by research funding, but also generation of new preliminary data for future proposals or competitive renewals, and even writing grant applications (as was recently demonstrated in the lawsuit against Columbia University/ICAP).

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