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.
“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.