The Management Challenges of NIH Training Grants

Penny CookDirector

Grant & Contract Administration(203)785-6475, penny.cook@yale,edu

Dennis J. TitleyAssistant Manager, Education, Training and Outreach

Grant & Contract Financial Administration(203)432-3074, dennis.titley@yale.edu

Today’s Objectives

• Basic Information • Special Considerations• Post Award Management• xTrain

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Authorization & Purpose

• The National Institutes of Health (NIH) institutional research training grants are limited to training and research at public and non-profit private entities.

• Support pre-doctoral and postdoctoral research training to help ensure that a diverse and highly trained workforce is available to assume leadership roles related to the nation’s biomedical, behavioral and clinical research agenda.

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Basic Concepts

• The total amount awarded and the number of awards vary.

• Awards for institutional research training grants may be for project periods up to five years in duration and are renewable. 

• Trainees are required to pursue full-time research training.

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Institutional Requirements

• Only domestic, non-profit, private or public institutions may apply for grants to support institutional research training programs. 

• The applicant institution must have a strong and high quality research program in areas proposed for research training and must have the requisite staff and facilities on site to conduct the proposed research training program.  

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The PI/PD

• The Training PD/PI should be an established basic, behavioral, and/or clinical researcher.

• The PD/PI will be responsible for the selection and appointment of eligible trainees to the training grant, for the overall direction, management and administration of the research training program, program evaluation, and the submission of all required forms in a timely manner.

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Multiple Training PI/PD’s

• More than one Training PD/PI (or multiple PD/PIs), may be designated on an application

• Applications for grants with multiple PD/PIs require additional information.

• Each PD/PI is responsible and accountable to the grantee organization for the proper conduct of the program, including the submission of required reports.

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Past Training Record

• Application must describe the past training record of the program, PI, mentors

• Career advancement of trainees• Evidence of a productive scientific career• Record of publications• Receipt of patents• Promotions• Other accepted measures of trainee success

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Trainee Appointments

• Trainees must commit full-time effort, normally 40 hours per week or as specified by the sponsoring institution, to the program and its related research activities.

• Trainees who are also training as clinicians must devote their time to the proposed research training and must confine clinical duties to those that are an integral part of the research training experience.

• The Training PD/PI should limit appointments to individuals who are committed to a career in research and who plan to remain on the training grant or in a non-NRSA (National Research Service Award) research experience for a cumulative minimum of 2 years. (Note: NIH Institutes may have different policies)

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Stipend Levels

• Stipends for training grants are not compensation for services rendered.– In contrast to Yale’s “stipends” paid on research grants

which are for services rendered.• Stipends are based on the annual NIH stipend levels

at the time of award. • Stipends may be adjusted only at the time of

appointment or reappointment. • For appointments of less than a full year, the stipend

will be based on a monthly or daily pro-ration of the annual amount. 

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Taxability of Stipends

• Degree candidates may exclude from gross income (for tax purposes) any amount used for course tuition and related expenses, such as fees, books, supplies, and equipment, required for courses.

• Non degree candidates are required to report as gross income any monies paid on their behalf for stipends or any course tuition and fees required for attendance.

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Taxability of Stipends

• Stipends are subject to Federal and, sometimes, State taxes.

• Yale may report such income on IRS Form 1099, Statement of Miscellaneous Income in contrast with W-2’s which report income (compensation for services).

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Program Evaluation

• Applications must describe evaluation plan• Quality and effectiveness of training• Include feedback from current and former trainees• Plans for assessing career development• Publications• Post training positions• A program for instruction in the Responsible

Conduct of Research13

Recruitment & Retention

• Applications must submit plan.• Should note efforts to diversify the workforce and

address:– Under represented minorities– Individuals with disabilities– Those within a low income threshold– Those with disadvantaged backgrounds

• Competing applications must include experiences in recruiting.

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Responsible Conduct of Research

• Trainees must receive instruction.• Plan must be described in the application.• No specific curriculum or format• Important components include:

– Conflict of Interest (COI)– Authorship and publication– Peer review– Misconduct– Animals, Human Subjects, Biosafety– Data management, data-sharing – Mentor-mentee relationships

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Federal Citations

• Use of Animals in Research• Human Subjects Protection• Data and Safety Monitoring Plan• Sharing Research Data• Genome-Wide Association Studies• PubMed• Health Insurance Portability and

Accountability Act (HIPAA)16

Budgeting Tuition & Fees

• Yale should apply for full tuition and fees.• The awarding Institute will adjust to 60% of the

level requested by the applicant institution, up to $16,000 per year per predoctoral trainee .

• $21,000 per year for a dual degree program.• For postdoctoral trainees, an amount equal to 60%

of the level requested by the applicant institution, up to $4,500 per year. If individuals are in a formal degree-granting training, the amount provided per trainee will be up to $16,000 per year.

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Budgeting Travel

• Trainee travel to attend scientific meetings and workshops that the institution determines to be necessary for the individual’s research training experience is an allowable trainee expense.

• Support for travel to a research training experience away from the institution may be permitted.

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Training Related Expenses

• FY 2008, $4,200 annually for each pre doctoral trainee and $7,850 annually for each postdoctoral trainee.

• Examples include:– health insurance, staff salaries, consultant

costs, equipment, supplies.

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Facilities and Administrative Costs (F&A)

• F&A costs are charged at 8% MTDC.• Exclusive of:

– Tuition and fees, health insurance (when awarded in the tuition and fees category),

– Expenditures for equipment

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Supplements

• Grantees may supplement stipends from non-Federal funds provided the supplementation is without obligation to the trainee.

• University policies do not usually permit postdocs to receive additional compensation for teaching in addition to a fulltime position and compensation. A waiver for postdocs requesting supplemental teaching appointments will be approved on a case-by-case basis.

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Conditions for Waiver Approval

• If permitted by the award, the teaching must not jeopardize the quality or quantity of time devoted to the research training.

• The course must be relevant to the postdocs training or scientific educator.

• The course would be offered through a regular department or program.

• The posdoc would be eligible as determined by the department or program offering the course.

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Compensation

• Compensation may be paid to trainees only when there is an employer-employee relationship.

• Fellowship sponsor must approve all instances of employment on research grants to verify that circumstances will not detract from or prolong the approved training program.

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Concurrent Benefits

• An individual may not receive support under an institutional training grant concurrently with another federally sponsored fellowship or similar federal award that provides a stipend or otherwise duplicates provisions of the training grant award.

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Pre-award Requirements

• If the application is under consideration for funding, NIH will request "just-in-time" information from the applicant.

• Pre-award costs are not allowable charges for stipends, tuition, or trainee travel on institutional training grants since these costs may not be charged to the grant before the trainee appointment is actually made.

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Post Award Management

• Carryover of Funds

• Appointments

• Unliquidated Obligations

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Carryover of Funds

• The Notice of Award (NOA) for an institutional research training grant specifies whether or not the grantee must obtain the prior approval of the awarding office to carry over funds.

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Trainee Appointments

• Trainees can be appointed at any time during a budget period, for a 12 month period.

• The 12 months stipend and tuition is charged to the current year.

• If an appointment period overlaps budget periods, an unliquidated obligation should be reported on the Yale encumbrance form.

• This form should be submitted to GCFA at the same time as the Financial Status Report (FSR) at the end of each budget period.

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Unexpended Trainee Related Expenses

• Only an actual charge for travel or trainee related expenses that has not cleared before the end of a budget period can be treated as an unliquidated obligation.

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Reporting Requirements

•  An annual FSR is required and must be submitted within 90 days of the end of each budget period.  Continuation support will not be provided until the required form is submitted and accepted.

• A Final Progress Report and FSR are required at the end of the grant project period or upon relinquishment of an award.  

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Educational Loan Programs (LRP)

• Available to trainees– Educational Loans or G.I. Bill– NIH Extramural Loan Repayment Program

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The Loan Repayment Program (LRP)

• Trainee must contractually agree to NIH mission-relevant research for at least 2 years.

• Agree to engage in research for 50% of their work schedule

• The LRP provides repayment of debt up to $35,000 annually.

• Applications accepted 9/1 – 12/132

Examples of the PHS 2271 and PHS 416-7 Forms

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Reporting Requirements

• Statement of Appointment (Form 2271)– Due on or before appointment start date

• Payback Agreement (PHS 6031)– If terminated within the first 12 months

• Permanent Residency Documentation– Required if under conditional permanent residency

• Termination Notice (PHS 416-7)– To GCFA with copy of appointment letter within 30 days

of termination

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Other Reporting Requirements

• Inventions– Reporting not required

• Copyrights– Approval not required if material is developed in

the course of work under the PHS project

• Human Embryonic Stem Cells– Follows NIH policy regarding approved lines

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Publication and Sharing Research Results

• Trainees should make the results and accomplishments available to the research community and to the public at large. 

• Yale will assist trainees in these activities. 

• No restrictions should be placed on the publication of results in a timely manner.

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xTrain

• xTrain– a web based program that allows users to electronically

process appointments and other required paperwork associated with institutional training grants

• PD/PIs, their delegates, and business officials can:– create, route and submit Appointments, Re-Appointments,

Amendments and Termination Notices – track the status and timing of training actions

• NIH is considering mandatory use in 2012

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QUESTIONS?