76 Comments
In response to questions about career development (K) award policies, NIH issued a Guide Notice NOT-OD-17-094, to clarify percent effort requirements for K award principal investigators (PIs), and acceptable sources of research support. We’d like to provide some additional details to put the recent Guide Notice in context with existing K award policies on percent effort.
For most K award programs, the K award PI (K awardee) must commit at the minimum 9 person months, equivalent to 75% full-time professional effort, directly to their research project and career development activities. The remaining effort (up to 25%) can be devoted to additional research, teaching, clinical work, or other efforts complementary to career development of the K awardee. NIH provides some salary support as part of the K award, and often institutions will supplement the salary of these K award PIs up to a level that is consistent with the institution’s salary scale. NOT-OD-17-094 clarifies that salary supplementation for the K awardee’s time spent devoted to the career development award and directly related to the research project is allowable, but must be from non-Federal sources, which can include institutional sources, and must not require extra duties or responsibilities that would interfere with the goals of the K award. For additional research projects, the effort not directly committed to the K award (commonly up to 25%), K award recipients may devote effort, with compensation, from Federal or non-Federal research projects as principal investigator, or in another role (e.g., co-Investigator), as long the specific aims of the other supporting grant(s) differ from those of the K award (see Figure 1). K awardees may also be compensated for effort devoted to teaching or clinical activities.
Most K programs are mentored career development awards, where a faculty mentor provides guidance to support transition of the K award recipient to independence. On mentored K awards of a 3-5 year duration, NIH policy provides a transitional period to permit the K award PI to apply for and if awarded, lead, an independent research project. If the mentored K awardee successfully becomes a PD/PI of a peer-reviewed research award from NIH or any other Federal agency during the final two years of their K award, they are permitted to reduce the effort devoted to the aims of the K award project from a minimum of 75% to a minimum of 50%. As described in NOT-OD-08-065, at the time the new research grant is awarded, this reduced effort on the K award may be replaced by effort and corresponding salary from the research award, so that the combined total research commitment of the PI remains 75% or more for the duration of the mentored K award (see Figure 2).
Have additional questions about percent effort and K awards for your K award, or for a specific K award PI at your institution? Contact the grants specialist listed on the notice of award for guidance specific to you. General policy questions may be directed to the Division of Biomedical Research Workforce at NIHTrain@mail.nih.gov.
[Note: edited text to clarify that “For most K award programs, the K award PI (K awardee) must commit at the minimum 9 person months, equivalent to 75% full-time professional effort, directly to their research project and career development activities.” 10/12/2017 NIH staff]
Please speak to the concept of subsumed effort on K awards and whether that still exists.
I find the comment
“For most K award programs, the K award PI (K awardee) must commit at the minimum 9 person months, equivalent to 75% full-time professional effort, directly to their research project.”
At odds with the purpose and previous guidance on K Awards since they are so much more than a single research project. (“support and protected time for an intensive, supervised career development experience” for instance) Perhaps that was meant to read:
“For most K award programs, the K award PI (K awardee) must commit at the minimum 9 person months, equivalent to 75% full-time professional effort, directly to the K award.”?
Good catch. We adjusted the text of the article above to read, “For most K award programs, the K award PI (K awardee) must commit at the minimum 9 person months, equivalent to 75% full-time professional effort, directly to their research project and career development activities.”
Please address the % effort regarding a no cost extension for a K awardee. Does the effort need to remain at the 75% full-time professional effort directed at the research project?
Yes. K awardees must continue maintaining 75 percent (or any approved) effort) during a no-cost extension. Similar to any other grant, all terms and conditions of award also apply during a no-cost extension.
If a PI has a K award and received an R01 in the last year of the K and the R01 effort is concurrent with the K, would they be allowed a no cost extension on the K? If so, would their effort on the K have to be 75% or could it be 50%? And lastly, could the R01 effort still be concurrent with the K while the K is on extension?
Question 1: If a PI has a K award and received an R01 in the last year of the K, and the R01 effort is concurrent with the K, would they be allowed a no cost extension on the K?
Answer: You may reduce your level of effort on the K to 50%. That said, we recommend consulting with your program officer first as well. Please note that no-cost extensions do not require NIH approval for the first 12 months.
Question 2: If so, would their effort on the K have to be 75% or could it be 50%?
Answer: It could be 50%, but is subject to approval by the funding NIH Institute or Center. Please also keep in mind that all terms and conditions of award apply during a no-cost extension.
Question 3: Could the R01 effort still be concurrent with the K while the K is on extension?
Answer: Yes, the 50% effort could be concurrent on the K award. Please note that we recommend consulting with your program officer and grants management staff first.
Does this mean you may still only PI a R21 or R03 in your 2 final years of a K award? Or may you PI an R21/R03 before then?
The two questions you posed reflect separate NIH policies related to K awardees.
For example, to address your first question, NOT-OD-08-065 indicates that, in the final 2 years of the K award, the recipient must be a named PI on a competing NIH research grant application (e.g. R03 or R21) or a sub-project director on a competing multi-component research or center grant or cooperative agreement application
Regarding the second question, a different NIH policy (NOT-OD-17-094) states that K awardees may supplement their salary, but only with non-Federal sources, during the entire period of the K award. Further, salary supplementation must not require extra duties or responsibilities that would interfere with the K award’s goals. If the effort is not directly committed to the K award, however, the awardee may devote effort, with compensation, on Federal or non-Federal sources as a program director, principal Investigator, or co-Investigator—as long the specific aims of the other supporting grant(s) differ from those of the K award.
For supplement salary from non-Federal sources, is their a limit in effort and salary since 75% is required on the K grant? Or, can the effort and salary decrease as long as the non-federal source does not interfere with the K award goals/work?
Does it constitute overlap when a PI on an R-mechanism gives up his salary on the R because he was awarded a K-award which will now cover the salary (for the first three years since I have a K08)?
Also, when giving up salary on an R, the grantee can request to re-budget funds, but the NIH doesn’t take the salary out of the grant and use it as an offset for next year’s award, right?
Regarding Question 1 (after clarifying activity code is R21): It depends, and we recommend the PI reach out to their program officials for each grant in this situation. If the research under both awards are the same or similar, then the effort devoted to the R21 is subsumed under the minimum effort required by the K08 award (commonly 75 percent). However, the effort devoted to the R cannot exceed the remaining effort (commonly 25%) if the research is clearly different. Please note that if the grantee requested nearly 100% salary on the K award, then the investigator would likely have to give up effort on the R award.
Regarding Question 2: We recommend contacting the grants management specialist at the other funding IC to discuss that issue.
If a PI has a K award and received an R01 in the last year of the K and the R01 effort is concurrent with the K,will they need prior approval or communicate with NIH to devote the 75% effort on the K award and certify no effort to the R01?
If a PI has a K award and received an R01 in the last year of the K and the R01 effort is concurrent with the K, does the PI needs prior approval or communicate with NIH to certify all their effort on the K but zero to the R01
The answer to both of your questions can be found in the NIH Grants Policy Statement Section 12.3.6.2 on Concurrent Support
“Provided they remain in a mentored status, mentored CDA recipients in the final two years of their support period are permitted to reduce the level of effort required for the CDA when they have competed successfully for peer-reviewed research awards from NIH or any Federal agency, if programmatic policy of the other Federal agency allows such an arrangement. Recipients are encouraged to obtain funding from NIH or other Federal sources either as a PD/PI on a competing research grant award or cooperative agreement or as a project leader on a competing multi-project award.
Budgets for a competing research grant or a subproject on a multi-project grant should request appropriate amounts for the salary and associated costs for the CDA recipient’s effort. At the time the research grant is awarded the effort required on the CDA may be reduced to no less than 6 person months (50% full-time professional effort at the recipient organization) and replaced by effort and corresponding salary from the research award so that the total level of research commitment remains at 9 person months (75% full-time professional effort) or more for the duration of the mentored CDA. This policy applies to the following mentored CDA activity codes: K01, K07 (developmental), K08, K22, K23, and K25, as well as individuals mentored through institutional K12 or KL2 awards. To be eligible for salary support from peer-reviewed research awards from any Federal agency:
• The CDA recipient must be one of the named PD/PIs on a competing NIH research grant application (R01, R03, R15, R21, R34, or equivalent application from another Federal agency) or a sub-project director on a competing multi-component research or center grant or cooperative agreement application (P01, P50, U01, etc. or an equivalent application from another Federal agency).
• The CDA must be active when the competing research grant application is submitted.
• The CDA must be in its final two years before the reduction in effort to 6 person months (50% full-time professional effort) is permitted.
For submissions to NIH, a letter must accompany the research grant application from the chair of the mentored award recipient’s department or other responsible institutional official providing: (1) evidence that the recipient will continue to focus on the development of his/her research career; (2) will continue to have access to his/her mentor; and (3) that the recipient’s total level of research effort will be maintained and protected at a minimum of 9 person months (75% full-time professional effort). For submissions to other Federal agencies, this type of institutional commitment letter is strongly encouraged; however, applicants should check with that agency for guidance on the allowability of such a letter.
When a mentored CDA recipient obtains independent support, as described above, the NIH awarding IC supporting the CDA will adjust the level of effort committed to the CDA to no less than 6 person months (50% effort) consistent with maintaining total research effort at 9 person months or 75% or more of the full-time appointment. NIH may adjust the total salary and fringe benefits amounts awarded to the CDA if consistent with the adjusted level of effort. If necessary, the K award may also be adjusted to avoid any additional budget overlap.”
(CDA = Career Development Award)
If a PI has a K award and is submitting a request for an Administrative Supplement, can the request include additional funding for salary?
Salary limits vary by NIH Institute and Center. Excerpt from Section 12.8.1 of the NIH Grants Policy Statement:
“The amount funded as salary for a CDA is not uniform throughout the NIH participating ICs. Salary limits vary by IC and are noted in the FOA. Note the limit is on salary only; applicable fringe benefits are provided in addition to the salary. The candidate is strongly advised to contact the relevant awarding IC for any distinct guidelines, requirements, and allowable funds. Salary costs charged cannot exceed the applicable legislative salary cap (http://grants.nih.gov/grants/policy/salcap_summary.htm).”
(CDA = Career Development Award)
Can a PI of a K award apply for and receive an R01 in the first 3 years of a 5-year K grant? Can the grants run concurrently before the last two years by taking no salary support from the R01?
The K PI effort not directly committed to the K award (commonly up to 25%), can be devoted to serving as PI or in another role on a Federal or non-Federal grant, as long the specific aims of the other supporting grant(s) differ from those of the K award.
I was under the impression that they could not be the PI of a federal award until the last two years of their K. Is this no longer the case?
K award recipients are encouraged to obtain funding from NIH or other federal sources either as a PD/PI on a competing research grant award or cooperative agreement, or as project leader on a competing multi-project award as described in NOT-OD-08-065. Note that the specific aims of the application need to differ significantly from your current K award. However, during the first 3 years you must commit 75% or more effort to the K award (https://grants.nih.gov/grants/policy/nihgps/html5/section_12/12.3.6_level_of_effort.htm). So while it is allowed, it may not be feasible. Please note that per the GPS, in the last 2 years of the K, the effort can be reduced to 50%.
Investigators are strongly encouraged to discuss future grant applications and/or percent effort with their current program officer.
If a K awardee needs to increase her effort by a small percentage, is it OK to pay that increase form the K funds providing all the extra effort can demonstrably be attributed to activities related to the K research? Would that increase need prior approval?
How is the total effort on the K evaluated at the end of the grant? For example, the awardee in year 1 devoted 8.5m, but in year 2 devoted 9.5m. Would the total level of effort be considerate compliant at the end of the grant?
We recommend contacting the program officer and/or grants management specialist assigned to the K award for clarification related to changing the percent effort, salary, and research costs.
During Years 1-3, can I become PI on an R21 or R01 at less than or equal 25%? Where is the policy for salary compensation on years 1-3?
You may apply for an R01 that differs from the K award and be PI on it, but in the first 3 years you MUST retain at least 75% effort on the K award – so it could be tough to have sufficient effort to be PI on R01 so early.
This is the relevant notice: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-17-094.html
In the last 2 years of the K you can apply for R01 and reduce effort to 50%.
from https://grants.nih.gov/grants/policy/nihgps_2011/nihgps_ch12.htm#_Toc271265177
Mentored awardees are allowed to devote complementary effort without salary support on other research grants that include related research between the CDA and the research grant. In such cases where there is scientific overlap, the percent effort on the research grant is subsumed within the required effort of the CDA. However, there should not be significant duplication of the scope of the research supported by the CDA. Further, the related research must be consistent with the goals and objectives of the CDA.
Can you devote time for clinic if this is the place where you will recruit patients and have it count as part of your protected research time because it is where you will be collecting patients ? Curious because I’ve heard someone else suggest this but want to confirm if this is true.
You cannot count clinic time as research time when you are seeing and providing care to patients in the same clinic as the research project but they are not part of the research project.
You may count clinic time as research time if the clinical interaction(s) is part of the research program you have proposed.
Can complementary effort without salary support be devoted on non-federal awards that include related research?
As described in the NIH Grants Policy Statement (section 12.3.6.1), recipients of mentored career development awards are permitted to devote complementary effort without salary support on other federal or non-federal research grants that are related to the career development award. In such cases, the percent effort on the research grant is subsumed within the effort devoted to the career development award. For further details, please consult with your program officer.
If my K award covers 75% of my current salary but I get a salary increase, is it possible to request additional funds to cover the difference? How would this salary change be covered otherwise?
We have the maximum amount (of salary) that each IC will award listed in the Table of IC-specific information for each K program announcement, so if the request exceeds that, it wouldn’t be met. On top of that, many ICs don’t award increases in the noncompeting years (although that varies by IC). We strongly recommend reaching out to your GMO and PO.
If you are the PI on an RO3, where only part of the aims are similar to a K award, can a portion of you effort be subsumed under the K award and the remaining effort be devoted to the RO3 with compensation? (ie.,10% effort RO3; part of the aims are similar to the K award, so 4% subsumed by the K and the remaining 6% devoted to and compensated by the RO3).
In general, NIH normally would not split the aims and effort as proposed (i.e., subsume effort on one grant under 2 mechanisms/provisions), particularly as the effort is for such a small commitment. Since there is a lot more information we would need to know to fully answer your question, we suggest you discuss this in greater detail with your K program officer.
On my K99 budget I stated that I would devote 100% of my effort. I know I can reduce my effort to 75%. My question is, can I automatically reduce my effort? or do I have to communicate it and get approval? If so, what is the maximum effort change I can do without having to request approval?
We strongly suggest contacting your program officer to discuss, particularly if you are planning on reducing effort to below 75%.
Please address which institutes may require less that 75% commitment on a K award based on a which subspecialties?
Is concurrent effort allowed on non-mentored (aka Independent) K award such as K24 or K02 or is it only allowed on mentored K awards?
Generally, an independent (CDA) or leadership awardee may receive additional salary support from other NIH/PHS grants for effort not committed to the CDA and there are no limitations to receiving other salary support. Where applicable, specific policies are noted in the FOA.
Thank you for the response. Would you mind clarifying whether concurrent effort is allowed on independent CDA awards? I was aware that the awardee of independent CDA may receive additional support from other NIH/PHS grants for effort not committed to the CDA, but my question is, is concurrent effort also allowed on these awards or is it only allowed on non-mentored K awards?
We suggest that you raise this question to the designated Institute or Center contact for the type of K award that you’re inquiring about for further details.
Can I be a Co-I (not PI) on an aim of a P01 and maintain eligibility to apply for a K08?
Yes, you would still maintain eligibility. If however you are a PD/PI or Project Lead on the P01, you would lose your K08 eligibility.
Hi,
I am a K award recipient looking to apply for an R01 through an RFA which mandates that 50% of my time is reserved for the R01 project. If the proposal gets funded I will be in my year 3 of the K award. While I understand I can reduce my effort for year 4,5 of K-award, is it feasible to get approval for reducing effort for K-award in year 3. This would be contingent upon approval of the R01 proposal for funding.
Thanks
We would strongly advise reaching out to your Program Officer and/or the scientific contact for that RFA.
Is it possible for a PI in Year 1 of their K01 award to also be listed as a Co-I or investigator on a federal award that does NOT overlap with the aims of the K01? Or is this not allowable to receive concurrent federal support until the final 2 years of the K01?
I have seen the frequently asked question and answer below on several university websites. Is is correct?
Question: Do you need prior approval from the NIH’s GMS for subsumed effort on a K award?
Answer: No, subsumed effort is complementary effort and does not require prior approval but you do need approval for concurrent support.
We recommend reaching out to your program officer to make this determination.
During Phase I of a K22, a postdoc may dedicate 75% of their effort to the grant. However, dedicating the same level of effort when someone is hired as an associate professor is more difficult given the commitments of the position. For example, for research institutions that have 9-month academic appointments where associate professors need to dedicate 1/3 of their appointment to research (3 months), 1/3 to service to the university (3 months), and 1/3 to teaching (3 months), is it even possible to hold a K22 that requires 9 Person Months of effort? And, is it possible to have additional grants besides the K22 where effort may be required?
First, K22’s are geared towards post-doctoral fellows and early stage faculty and, generally speaking, not an appropriate program for associate professors. We would encourage associate professors to consider R01eq or RPG and if possible some non-NIH sources of support either through your institution or a relevant private foundation.
To your second question, it is not possible to serve as PI on a K22 with less than 9 person months of effort.
Finally, it would not be possible to be a PI on a K22 and another grant requiring effort.
Can a portion of effort dedicated to a non-federal grant (with salary paid from that non-federal grant) be counted towards meeting the requirement of minimum 75% effort on the K award?
Can I become PI on an R21 while still in the K-phase of a K99, or would that make me reach “independence” and cancel my K99?
What about if I am in the R-phase of the K99?
We recommend reaching out to the Program Officer, as there may be some IC-specific practices. If you are in the R00 phase of the K99/R00, receiving an R21 award would not cancel your award.
When having effort on a K08 award, if effort for two months is 70% but the remaining 10 months is 85% will the effort over the 12 months be considered (so average for the year is 83%) as on R01’s, or is this different for mentored awards?
Yes, calculating effort on a K award follows the same procedures as for other types of NIH grants. Note that we currently use “person months of effort” rather than percent effort (https://nexus.od.nih.gov/all/2017/03/31/what-is-a-person-month-how-do-i-calculate-it/).
If a PI has a K award and received an R01 in year 4 of the K and the R01 effort is concurrent with the K, would the PI be allowed to reduce the effort to no less than 50% on the K, and keep the reduced effort toward no cost extension on the K?
Is there a requirement that Institutions will supplement the salary of the award recipient? If the institution is demanding a salary deduction for recipients rather than provide supplements, are there rules to avoid such kinds of agreements?
There is no requirement that institutions supplement the salary of K award recipients, although many do so. Note that K awardees may be compensated for other work outside of the nine months of professional effort (75% effort) required to be devoted to the K award. We suggest reaching out to your Grants Management Specialist regarding salary deductions.
1. Can I apply to R-awards if I am in part-time position but with a plan to move to a full time position at time of award?
2. Same question for a K01 award (assuming the position is a non-tenured track position)?
If a faculty member normally has a full-time 9-month appointment, can they request summer salary from a K01, or do they need to complete the minimum 9 months of effort during their regular (9-month) appointment?
Total salary for K01 is based on a full-time, staff appointment requiring the candidate to devote a minimum of 75% effort to conduct informatics research. The remaining 25% can be divided among other research, clinical, and teaching activities (if consistent with the goal of the K award). Salary supplementation is allowable if from a non-Federal source unless explicitly authorized by the federal program from which such funds are derived (as described in Section 12.8.1 of the NIH Grants Policy Statement). To find IC-specific information regarding allowable salary, see Mentored Research Scientist Development Award (Parent K01 – Independent Clinical Trial Not Allowed) (PA-20-190) | grants.nih.gov
Hoping you can help with trying to determine, if in the below example the $27,500 not direct charged to the K award would be voluntary uncommitted cost share or voluntary committed cost share. I can argue voluntary committed cost share since we need to report that 75% effort was expended on the grant.
If a faculty member must commit 75% effort to a Federal K award, but the Federal K award instructions only allow payment up to $85,000 (which only covers part of the faculty member’s salary), is the amount paid over $85,000 committed cost sharing? For example, the award will only pay $85,000 for 75% effort but the faculty member has a University salary of $150,000 (75% of which would equate to $112,500). The amount of $27,500 not covered by the Federal K award ($112,500-$85,000 = $27,500)
We suggest reaching out to your NIH grants management specialist for guidance.
NIH defines matching or cost sharing as “the portion of project costs not paid by Federal funds (unless otherwise authorized by Federal statute). This may include the value of allowable third party in-kind contributions, as well as expenditures by the recipient.” In the example provided, the portion of salary provided by the institution to reach the investigators 75% effort salary equivalent could be considered cost sharing since it is for work on the project, but any additional funds to reach 100% would not be since they do not relate to time on the project. NIH would generally consider this salary supplementation, per GPS 12.8.1 rather than cost sharing. Regarding voluntary committed versus voluntary uncommitted cost sharing, NIH does not use the terms voluntary committed or voluntary uncommitted. Committed cost sharing would be in cases where the award/FOA requires cost sharing/matching which would not be applicable for K awards and voluntary cost sharing would inherently be uncommitted since it is not a requirement of the award.
Hi Kim, I have the same issue, which you have. Can you please let me know how you resolved your issue?
Is there a definitive answer on whether an investigator holding a K award can be paid from another NIH award (regardless of effort level on the other award)? We have tried reaching out to grants management specialists and seem to have received some inconsistent feedback, so we wonder if this is an institute-by-institute (eg, NICHD, NIDDK, NIDA, etc…) matter? thanks
Hi, Does the PI needs to maintain the minimum effort during the entire period of the no cost extension even if there’s not enough money to cover the entire project period?
When the PI of a K01 receives permission to subsume a research project under the effort of the K01:
1) Is the K01 PI still considered to have effort on the research? If not, does that impact their status a “key” personnel.
2) Should the research project be listed on the K01 PI’s other support?
Does a prior “independent-PI” (non-mentored) foundation award prohibit application for a K (mentored) award?
What if the Faculty member is only a 0.75 FTE at the institution and not a 1.0 FTE. How would that affect how to budget/report effort? In addition, the NIH would come into play.
Can K08 grantee carryover the unspent salary? or rebudgeted?
Thank you for reaching out. We suggest asking the NIH Grants Policy office (grantspolicy@od.nih.gov).
Hello,
Is it permissible for a PI holding a K22 to have a different percent allocated to salary support, while maintaining 75% effort on research projects?
Many thanks.
Can a K grant awardee receive compensation from a source outside of their primary institution? For an example, as part of your contract with your primary institution you devote 75% of your time to your K award and 25% of your time to clinical duties/teaching. Can you also be compensated from external sources for things like consulting, moonlighting, independent contractor work etc?
Hello,
If a K01 (PAR-18-490) contribute up to $ 95,000 being 75% of salary. This allow me to go up to $126,666 for a 100% salary. It is possible to have a compensation of $150K or above $126,666? Thx
Just to clarify – the NIH K01 requires 75% effort but only pays a certain amount of dollars for salary, even if that doesn’t reach 75% of the applicant’s salary?
I have the same question as Hector and Evelyn. If the upper limit of the NIH K01 award can only cover 60% of my salary but the award requires 75% effort, how should this be managed?