Allowable Student and Postdoc Activities

Questions about what activities students and postdoctoral scholars can participate in?

Frequently Asked Questions from The Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2CFR 200)

(see .400-2 "Dual Role of Students and Postdoctoral Staff" on page 19 of the PDF)

.400-2 Dual Role of Students and Post-Doctoral Staff

The Uniform Guidance 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.

Does 200.400(f) require recognition of the dual role of postdoctoral staff appointed on research grants as, both trainees and employees, when appointed as a researcher on research grants?

Yes, the Uniform Guidance 200.400(f) requires the recognition of the dual role of all pre and post-doctoral staff, who are appointed to research positions with the intent that the research experience will further their training and support the development of skills critical to pursue careers as independent investigators or other related careers. Neither Pre-Docs or Post-Docs need to be specifically appointed in 'training' positions to require recognition of this dual role. The requirements and expectations of their appointment will support recognition of this dual role per 200.400(f).