Time well spent: tending to your career and professional development
“I’m a postdoc being paid by an NIH training grant. Can I take time out of the lab to participate in this ASPIRE module?”
“I’m paid by my PI’s research grant. I’ve heard people say that means I have to spend 100% of my time doing research and I can’t go to the Career Symposium. Is this true?”
“Am I able to do this ASPIRE internship if I have an NRSA fellowship?”
These are questions we sometimes hear from graduate students and postdoctoral fellows who want to participate in career and professional development activities, especially the more time-intensive ones like ASPIRE modules or ASPIRE internships.
The answer to these questions is “yes” and “no” and “yes.” YES you can participate in ASPIRE modules if you are supported an NIH training grant. NO, it’s not true that you have to spend 100% of your time in the lab doing research if you are paid by your advisor’s federal grant. YES you can do an ASPIRE internship if you have an NRSA fellowship. In fact, the federal government wants you to participate in activities that contribute to your training for research- and research-related careers, even if those activities occur outside the lab. Below are the grant policies that address acceptable activities for graduate students and postdoctoral fellows who are paid by a federal grant. (Yes, this is in the weeds on policy, but stay with me here!)
The Ruth L. Kirschstein National Research Service Award (NRSA) Institutional Training Grant
Many graduate students and postdoctoral fellows at Vanderbilt are appointed to NIH institutional training grant NRSAs (T32 grants) at some point during their training. According to the program announcement (PA-20-142), the NIH NRSA programs:
- are “designed to train individuals to conduct research and to prepare for research careers.”
- are expected to provide training in “professional development skills such as communication, management, leadership, and teamwork.”
- “should make available structured, career development advising and learning opportunities (e.g., workshops, discussions, Individual Development Plans). Through such opportunities, trainees are expected to obtain a working knowledge of various potential career paths that would make strong use of the knowledge and skills gained during research training and the steps required to transition successfully to the next stage of their chosen career.” “The career outcomes of individuals supported by NRSA training programs include both research-intensive careers in academia and industry and research-related careers in various sectors, e.g., academic institutions, government agencies, for-profit businesses, and private foundations.”
So, as you can see, based on the guidance provided in the program announcement for the NIH NRSA Institutional Training Grant, the NIH clearly expects career and professional development to be an integral part of graduate and postdoctoral training. ASPIRE is designed to provide such career and professional development opportunities to all Vanderbilt graduate students and postdoctoral fellows, including those supported by NRSAs.
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
These guidelines describe how PIs and institutions should manage their federal research grants, including exactly which items can – and can’t – be paid for from a federal grant. Reagents or supplies for your grant-funded research, like cell culture media or pipet tips? Yes! These are allowable charges. A round of drinks for everyone in your lab to celebrate publishing a paper related to the grant? No. This is not an allowable charge.
The salary of an individual who works directly on grant-related objectives is an allowable charge to a grant. But, if an individual does some work for the grant (e.g. designing and executing experiments) and some work not related to the grant (e.g. administrative or teaching work for the university), only the portion of the individual’s salary that is spent on grant-related activities can be charged to the grant. This is where the concept of “percent effort” is derived. If a faculty member spends 80% effort on their grant-funded research, 10% effort running a recruitment program for the department, and 10% effort teaching, then only 80% of their salary can be charged to the grant.
Section 2 CFR 200.400(f) of the Uniform Requirements makes it clear that these guidelines apply to grad students and postdocs who are paid by a research grant to conduct grant-related research. This section states, “For non-Federal entities that educate and engage students in research, the dual role of students as both trainees and employees (including pre- and post-doctoral staff) contributing to the completion of Federal awards for research must be recognized in the application of these principles.” Based on 2 CFR 200.400(f), some institutions and PIs were left wondering whether grad students and postdocs could spend any time in non-lab based activities relating to their training in science, like seminars, conferences, or career development activities, if a student or postdoc was paid off a federal research grant.
Because of the confusion over whether students and postdocs paid from research grants could participate in career development activities, the government issued an FAQ in 2014 to underscore that graduate students and postdocs can and should participate in training-related activities. The clarification was deemed so important by the NIH that they issued an office Notice to underscore that the FAQ applies to all NIH awards (NOT-OD-15-008). Excerpts of the Notice are below in italics.
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 nor 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).
For more on the Uniform Requirements and its companion FAQ, read Yes, You Can Attend that Career Event from ScienceCareers and this blog post, Defining the Dual Role of Graduate Students and Postdocs Supported by Research Grants, from Sally Rockey, former deputy director for extramural research at the NIH.
NIH Grants Policy Statement
The NIH Grants Policy Statement contains language pertinent to graduate students and postdoctoral fellows paid stipends as part of their National Ruth Kirschstein Award (NRSA) Training. The policy is pertinent to trainees supported by either individual fellowships (F awards) or institutional training grants (T awards). In either case, NRSA trainees are required to pursue their research training full-time, which NIH recognizes is generally at least 40-hours per week (Section 11.2.7) BUT the NIH does allow NRSA trainees to hold part-time employment, up to 10 hours per week, as long as that employment does not extend the length of NRSA training.These guidelines were used in the design of the ASPIRE internship program. ASPIRE facilitates part-time internship opportunities for trainees. Most internships are 6-8 hours/week, and we set a cap of 8-10 hours/week, based on guidance provided for NRSA recipients by the NIH Grants Policy Statement. We expect that trainees participating in ASPIRE internship activities will be able to maintain their full-time research effort while conducting an ASPIRE internship. The applicable policy language from the NIH Grants Policy Statement is below, and reiterated in NOT-OD-095 from the NIH.
From Section 11.2.7, Full-Time and Part-Time Training
All fellows are required to pursue their research training full time. Full-time is generally defined as devoting at least 40 hours per week to research training activities or as specified by the sponsoring institution in accordance with its own policies.
From Section 11.2.10.2, Compensation
NIH recognizes that Kirschstein-NRSA fellows may seek part-time employment incidental to their training program to offset further their expenses. Fellows and trainees may spend on average, an additional 25% of their time (e.g., 10 hours per week) in part time research, teaching, or clinical employment, so long as those activities do not interfere with, or lengthen, the duration of their NRSA training.
What if I’m an international student or postdoctoral fellow? Can I participate in ASPIRE activities or internships?
Yes, you can participate in ASPIRE activities. Your ability to do an internship through ASPIRE or other programs depends on the type of visa you have and the type of internship you wish to do. Please contact our office so we can discuss your specific circumstances.
What if I have a fellowship from a private foundation? Can I participate in ASPIRE activities or internships?
In general, pre- and postdoctoral fellowships awarded by foundations are intended to fund training of individuals who plan to pursue research careers studying a particular disease area. As such, you can almost always participate in career and professional development activities that will help prepare you for a career in that field. However, we recommend you read the program announcement or RFA for your specific funding mechanism and talk to the grant program officer at your funding organization before applying for an ASPIRE internship.