In 1994 the Department of Health and Human Services (DHHS) Inspector General reported that several universities were using federal research grant funds to support graduate students at compensation rates that were determined as unreasonably high. The salary and fringe benefit portions of the compensation were within the guidelines, but the addition of tuition remission raised some of the compensation rates to unreasonable levels. Since then, the cost principles in OMB Circular A-21 have been clarified. The treatment of costs must be consistent, and compensation (as a cost) must be allowable, allocable, reasonable, and necessary.
The graduate student employee salary limit is $39,264. This reflects a $768 increase from the previous limit of $38,496. As with the previous salary limit, this amount includes salary or wages, fringe benefits, and tuition remission. The new compensation allows compensation at "0" National Research Service Award (NRSA) stipend level. Connecting the research compensation levels to the NRSA stipend schedule provides the potential for annual cost of living increases, which did not occur under the former policy.
The salary limitation:
For modular grant submissions, the requirements include
Note: Institutions may continue to rebudget funds to charge more than the awarded amount provided that OMB Circular A-21 cost principles requiring reasonable compensation are observed. In general, graduate student compensation will not be considered reasonable if in excess of the amount paid to a first-year postdoctoral scientist at the same institution performing comparable work.
NIH Guide, December 10, 2001, Graduate Student Compensation (http://grants.nih.gov/grants/guide/notice-files/not-od-02-017.html).
Notice Number: NOT-OD-12-033 Ruth L. Kirschstein National Research Service Award (NRSA) Stipends, Tuition/Fees and Other Budgetary Levels Effective for Fiscal Year 2012.
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