NIH requirements re: Graduate Student Researchers (GSRs) compensation levels

The purpose of this memo is to provide guidance on the interpretation of NIH requirements related to compensation levels for Graduate Student Researchers (GSRs) working on NIH research grants.

NIH will award funds for the cost of a GSR working on a research project up to the "zero level" NRSA Postdoctoral stipend in effect at the time that the research project is awarded. As of October 2010, the "zero level" NRSA award is $38,496 per year, and NIH will not award funding above that level to compensate a graduate student.

However, NIH does allow PIs to rebudget project funds in order to charge more than this awarded amount for the actual cost of a graduate student. NIH funded compensation to a graduate student may be up to the "amount paid to a first-year postdoctoral scientist at the same institution performing comparable work."

Since compensation for GSRs is defined to include salaries, fringe benefits (including GSHIP), fees and tuition, comparable compensation to a first year postdoc would also include benefits in addition to salary. This total compensation defines the limit that a GSR may be compensated for on an NIH award. For Federal FY2011, the limit is $48,890 ($38,496 annual salary plus $10,394 in fringe benefits at current rate of 27% of salary).

Whenever this amount exceeds this threshold, the overage may NOT be charged to NIH (and, of course, may not be charged to any other sponsored project since the GSR’s effort is on that specific NIH project). The overage will normally have to be paid from departmental or the PI’s unrestricted funds.