How to manage your NRSA award without it managing you

Presenters:Kjersten Reich, Senior Grant Administrator,

Massachusetts General HospitalMeaghan Nolette, Research Finance Manager,

Partners HealthCare Glenda A. Bullock, Manager of Business Operations,

Division of Hematology, Washington University

A training grant is an assistance grant awarded to “eligible institutions to develop or enhance research training opportunities for individuals, selected by the institution, who are training for careers in specified areas of biomedical, behavioral and clinical research”

2 What is a Training Grant?

• First woman appointed director of an NIH Institute• Later appointed deputy director and acting director

of the NIH• Her work on polio led to a vaccine that virtually

eliminated the disease• Strong advocate for research training, especially

inclusion of underrepresented individuals in science

3 Who was Ruth L. Kirschstein?

ObjectivesOffer a solid overview of

concepts and terminology involved in NRSA awards

Provide a foundation of information to assist you in managing NRSA awards

Provide resources that will help you find answers as new situations arise

KEY TERMS

Stipends Period of Support

Appointments Postdoc Payback Agreement

X-TrainTermination

Leave Tuition & Fees

Training Related Expenses Trainee TravelRe-budgeting Restrictions Indirect Costs Unliquidated Obligations Closeoutvs. Unobligated Balance

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6 Roles on Training GrantsPI/PD•Responsible for the scientific and programmatic oversight of the training grant

Departmental / Central Admin• Appointed by PI and/or departmental leadership to assist with managing funds, salary distributions, forms, and reports associated with the training grant

Mentors / Preceptors• Selected by PI and/or steering committee for mentoring track record and area of research• Each Trainee will be matched with at least one mentor to complete a training program

Trainees• Pre or Postdoctoral fellows selected by established process to complete a defined training program• Must be U.S. citizens or permanent residents

Training Grant Life Cycle7

NIH issues NOA

Process Appts.

And subcontract

Trai

ning

Sta

rts

Early

Terminations

Progress

Report

Star

tR

e-A

ppoi

ntm

ent

Proc

ess

FFR

Other actions

T32

ChallengesKeeping track of trainee appointments: overlapping

periods and accounting for individual expendituresDetermining stipend levelsPayback AgreementTermination Notices LeaveRebudgeting restrictionsUnliquidated obligations & unobligated balanceCloseoutRenewal

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Quiz Question # 1Do Training Grants have pre-award cost

authority? • Expense policies are those permitted in the

NIH Grants Policy Statement• This would apply to both pre and post award

expenditures of all costs• However, stipends and tuition costs may not

be charged to the grant before the appointment is actually made

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Budget Categories • Direct Costs:

– Stipends– Tuition & Fees– Trainee Travel– Trainee Related Expense (TRE) including Health

Insurance• Indirect Costs:

– 8% x MTDC Base

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Stipends • A Stipend is a subsistence allowance to help defray living

expenses during the period of training• Stipend levels are predefined and are set annually by NIH• Based on 9 - 12-month appointment

– Less than 9 months not allowed unless completing a planned training program

• Stipend payment cannot be changed mid-appointment• Tip: When possible, begin appointments on the first day

of the month. Mid-month appointments are prorated based on the number of days in the month

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Career Level Stipends (for FY 2012)• http://grants.nih.gov/training/nrsa.htm• Predoctoral

$22,032• Postdoctoral – Years of experience

0$39,264

1$41,364

2$44,340

3$46,092

4$47,820

5$49,884

6$51,582

7 or more $54,180

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Determining Stipends• Postdoc graduation date is the equivalent to the date the

degree was conferred• “Relevant Experience” may include:

– Research experience outside the Institution– Clinical duties– Residency– Internship– Teaching assistantship– Time spent in a health related field beyond that of qualifying for a

doctoral degree• The PI determines if experience is relevant, and may have to

justify assessment to the NIH

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• Step 1 – Determine how many years of experience the trainee will have completed before the appointment date– A trainee with a degree date of 06/01/2013 would have

zero years of experience for an appointment date of 07/01/2013

• Step 2: Determine the Fiscal Year stipend level – Stipends will correspond with levels established by NIH for

the fiscal year of the grant’s current budget year– The stipend levels established for FY2012 will be employed

for all budget years starting 10/01/11 or later, until new stipend levels are established

Determining Stipends 14

Quiz Question # 2• A Postdoc earned her Ph.D. on 12/15/2012 • She will be appointed to a T32 grant on 06/01/2013 • She will be appointed to the budget period 07/01/12-

06/30/13

What is the appropriate stipend level?• Stipend Level = 0

What is the appropriate Fiscal Year?• FY 2012

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Appointments: Other Considerations

• Aggregate NRSA support limitations:– Predoc: 5 year limitation– Postdoc: 3 year limitation

• Effort Reporting: – Trainees are not providing a service to the

institution, and are therefore exempt• Must be 100% effort and 1.0 FTE

– Written requests for part-time training will be considered on a case by case basis (usually due to health or family concerns)

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Supplementation 17

• Grantees are allowed to supplement stipends with non-federal funds

• Supplementation is additional income to the fellow without additional duties– Must be at a level consistent with similar training status– Cannot require additional duties, effort, or obligation from the

fellow– If trainee is moved into a specific job code, the supplementation

income is considered “salary”– *Please refer to your institution's HR department for specific job

code inquiries

Other Compensation • Fellows may receive compensation for services

associated with part-time employment • Requirements:

– Limited, part time– Outside normal training activities– Cannot distract from training program– May not be the same research that is part of the training experience

• *In the case of additional compensation the fellow receives a salary that is not considered stipend supplementation

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Quiz Question # 3

Can a trainee be supported on an NIH researchgrant at the same time they are receiving astipend from a NRSA grant?

– PHS funds cannot supplement stipends– Trainees must devote full time effort to NRSA grant– Separate compensation from NIH must be limited

part-time employment (i.e. – lab assistant)

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What is xTrain? • xTrain is part of eRA Commons• A Web-based program that allows PIs, administrators and

trainees to complete required training grant forms electronically– Create, route and submit the 2271 (Statement of Appointment)– Re-Appointments– Amendments– 416-7 Termination Notices

• Track the status and timing of training actions as well as available slots and the training grant roster

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PHS 2271: Statement of Appointment• Submit PHS 2271 through xTrain for each trainee

• Due on or before start of each appointment period, which is typically one year

• Stipend or other allowances may not be paid until submitted to the NIH

• Delinquent forms (> 30 days) may result in NIH not accepting the appointment

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22 X-Train :: Appointment Form Route

Trainee fills out

personal profile

DA com-pletes 2271,

routes to trainee

PI reviews

2271 and

routes to NIH

DA seeks eRA Commons user name for Trainee

Trainee reviews

2271 and routes to

PI

PHS 2271: Be a Smooth Operator • Verify there is not an existing era Commons

user name for Trainee.• Double check that trainee completes all

pertinent information in personal profile• Triple check PGY level.• Inform Trainee and PI of routing process• Follow up regularly to assure on time

submission

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PHS 2271 : Other Considerations• Read award notice for special guidelines• Change the trainee’s title / job code

within Institution• Trainees may be appointed at any time

during the budget period up until the last day of the budget period

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PHS 6031: Payback Agreements• Required of all new postdoctoral appointees

– Original signature on document; submit by mail– grants.nih.gov/grants/funding/416/phs6031-1.pdf– Scan of Payback Agreements available in xTrain

• Trainees incur payback obligation during their 1st year of NRSA support

• 2nd year of training pays back the 1st year (Inform Trainees)

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Quiz Question # 4 Can I appoint a 1st year Postdoc fellow on the lastyear of a training grant that is not going to continue?• Yes, Payback will still be fulfilled if one of following

conditions are met– By completing a second year of NRSA support on another

training grant or fellowship– Engaging in an equal period of research or health related

activities– Financially

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PHS 416-7:Termination Notices (TN)• Due within 30 days of the end of training experience per

award• Reflects total period of support including total stipends paid

to trainee• Submitted through xTrain:

https://commons.era.nih.gov/commons/• Prorate stipend for early terminations• NIH verifies:

– The trainee was paid appropriately per the stipend amounts in the Statement of Appointment form(s)

– Any service obligation was fulfilled

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28 xTrain:: Termination Notice Route

Trainee writes

summary, fills out new job

info, routes to PI

DA confirms form is

complete

BO reviews. If accept –able, routes to NIH

DA Initiates Termination Notice, routes to Trainee

PI reviews. If accept -able, routes to Business Official (BO)

For early terminations,

begin with revised 2271

Check with PI for guidelines on

summary

Leaves of Absence• Vacations and Holidays: Trainees may receive the same vacations and

holidays available to individuals in comparable training positions at the grantee or sponsoring institution. Trainee’s will continue to receive stipends.

• Sick Leave: Trainees may receive stipends for up to 15 calendar sick days per year.

• Parental Leave: NRSA fellows may receive stipends for up to 60 calendar days (equivalent to 8 work weeks) of parental leave per year for the adoption or the birth of a child when individuals in comparable training positions at the sponsoring institution have access to this level of paid leave for this purpose. The use of parental leave requires approval by the sponsor.

• Leave of Absence: Approval for leave of absence must be obtained in advance from the awarding institution. Trainees will need to be terminated and reappointed upon return from leave. Stipends are not paid during leave of absence.

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Tuition & Fees • Allowable if costs are required for specific courses as part

of the training program and are applied consistently• Predoctoral calculation:

– 60% up to $16,000– 60% up to $21,000 for dual degree

• Postdoctoral calculation:– 60% up to $4,500– 60% up to $16,000 for additional degree

• Refer course related questions to your Grants Management Specialist or course Director

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Trainee Travel • To attend scientific meetings &

workshops deemed necessary for training experience

• Domestic and International travel are allowable, as long as travel fits within trainee’s training program

• Allowability not uniform across all funding institutes within the NIH

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Training Related Expense (TRE)

• To defray other training expenses such as staff salaries, consultants, equipment, supplies, faculty/staff travel directly related to training

• Standard NRSA TRE for FY 2012– $4,200 per Predoc– $7,850 per Postdoc

• Includes Health Insurance– NIH provides funds to offset a portion of the costs associated with

health insurance (either self-only or family as appropriate)– Trainee Fringe Benefit costs are unallowable on T32s

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Quiz Question # 5Can the salary and benefits of the program director becharged to the training grant?

– Training Related Expenses (TRE) can be used to defray the cost of staff salaries

– Such charges must meet the test of allowability and reasonableness

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Can the cost of pizza and soda served at a seminar ormeeting be charged to the training grant? • Cost of meals may be allowable if they are provided in

conjunction with a meeting where the primary purpose includes the dissemination of technical information

• A portion of such a cost could be charged as Training-related expenses

• See Cost Considerations-The Cost Principles in IIA for specific �guidance on the need for institutional policies on consistent treatment and reasonableness

• 11.3.8.4 Training-Related Expenses in the NIH GPS governs allowability of these expenses

34 Quiz Question # 6

• 8% of MTDC• MTDC includes:

– Stipend– Trainee Travel– Training Related Expenses, including Health Insurance

• MTDC excludes:– Tuition & Fees– Equipment

• *Equipment should be requested and identified under the Training Related Expenses category

35 Indirect Costs Allocation

• Prior approval is required to rebudget stipends and/or tuition & fees into travel or Training Related Expenses (TRE)

• No prior approval required (unless otherwise restricted) to rebudget travel and TRE into all other budget categories.

StipendsTravel

Tuition & Fees TRE

36 Rebudgeting Restrictions

• What is an unliquidated obligation?– An obligation incurred which has not yet been paid for– For example an account payable for items ordered or

received but not yet paid for– Stipend unliquidated obligation example:Budget Period – 7/1/12-6/30/13Trainee Appointed – 8/1/12-7/31/13 @ $44,340

($3,695/month)Trainee Stipend Expense through 6/30/13 = $40,645Trainee Stipend Unliquidated Obligation = $3,695

37 Unliquidated Obligations

• Expenses considered obligations and are allowed to be unliquidated:– Stipend– Tuition & Fees

• Expenses which are considered not obligations and are not allowed to be unliquidated:– Training Related Expenses (TRE)– Trainee Travel

38 Unliquidated Obligations

- Unliquidated obligation : $9,369 + $750 IDC = $10,119- Unspent Travel and TRE cannot be unliquidated and therefore make up the unobligated balance (carry forward requires approval)

39 Y1 Unliquidated ObligationsBalance as

of 6/30/2012 Obligation"Lost"

(Unobligated)Stipend: 9,369 9,369 - Tuition: - - - Travel: 200 - 200

TRE: 550 - 550 Total: 10,119 9,369 750

Indirect: 809 750 60 Total Costs: 10,928 10,119 810

• YR 1 unobligated balance can only be spent as such

40 Year 2 Budget + Year 1 UO NoA Yr 2 07/01/13-06/30/14

UO Yr1

07/01/12-06/30/13 Total Avail.Stipend: 44,340 9,369 53,709 Tuition: 3,000 - 3,000 Travel: 500 - 500

TRE: 4,200 - 4,200 Total: 52,040 9,369 61,409

Indirect: 3,923 750 4,673 Total Costs: 55,963 10,119 66,082

In addition to traditional NIH progress report components, the following components may be required: Description of training received by each appointed trainee with

resulting publications Updated list of IACUC approvals Updated list of IRB approvals Biosketches for new selected preceptors, or mentors Budget may be required Summary of trainees form Inclusion enrollment report (minorities)

41 Non-Competing Progress Reports

• If project period is ending (no competitive renewal) request NCE through the last trainee appointment end date

• Submit all termination notices• Process final closeout adjustments prior to end of adjustment

period• Projected expenditures must have been incurred prior to the

end of the budget period (cannot have any unliquidated obligations on Final Federal Financial Report)

• Final progress report only due at end of grant

42 Closeout Requirements

• Review prior period FFR for total unliquidated obligations reported

• Review GL Expense– Stipends should be expended according to appointed NIH

stipend levels– Ensure any rebudgeting is within the restrictions– Reconcile F&A to correctly account for exclusions – FFR submitted annually

• Work closely with your Research Finance specialist, submitting a T32 FFR is a complex process

43 Closeout Review

44 Sustaining a Productive Training Environment

• Measures to recruit high quality trainees, including Under Represented Minorities

• Success of Trainees in completing their training programs

• Productivity of trainees, in terms of accomplishments and publications

• Ability of trainees to attract research funding• Ability of a program to document all of the

above in table format

What are some of the factors the NIH considers when evaluating competing renewals of training grants?

45 Sustaining a Productive Training Environment How can administrators support a Productive Training Environment?

• Work with faculty to assure a robust program of supporting activities, such as scientific seminars, retreats, and journal clubs, responsible conduct of research programs

• Provide ample training to trainees in the basics of applying for other fellowships and career development awards

• Work with faculty to institute common practices to collect data on recruitment, publications, and performance of all trainees in the training program, even those that are not appointed to the Training Grant

• Glenda Bullock, Washington University

• Hernan Santana, Children’s Hospital

• Wendy Virgadamo, Brown University

• Cora Cheng-Chong, Partners Health Care

• The Unfortunate Trials of The Tyrant Lizard King, By Hugh Murphy at http://trextrying.tumblr.com/

46 We are grateful to the following:

• Ruth L. Kirschstein National Research Service Award policy information, stipend levels, FAQ’s

http://grants.nih.gov/training/nrsa.htm• NIH Forms & Applications

http://grants.nih.gov/grants/forms.htm• xTrain Site

http://era.nih.gov/services_for_applicants/other/xTrain.cfm• eRA Commons

http://commons.era.nih.gov/commons/

47 Resources

Kjersten ReichSenior Grant Administrator

Massachusetts General HospitalTel: (617)-724-3064kreich@partners.org

Meaghan NoletteManager, Research Finance

Partners HealthCareTel: (617)-954-9669

mnolette@partners.org

48 Contact us with any other questions!