Appointing Trainees on
Training Grants
TED MORDHORST
ASSISTANT DIRECTOR FOR POST AWARD
FINANCIAL COMPLIANCE
RESEARCH ACCOUNTING AND ANALYSIS
Compliance
NIH TRAINEES/FELLOWS APPOINTED AS AN
EMPLOYEE UNDER ON A TRAINING GRANT MAY
RESULT IN UNALLOWABLE COSTS.
CREATES SIGNIFICANT ADMINISTRATIVE BURDEN TO
CORRECT.
MAY SIGNIFICANTLY IMPACT THE TRAINEE’S
EDUCATION AND FINANCIAL CONDITION
Trainees are NOT Employees
 NIH Grants Policy Statement:
Trainees …receive a stipend as a subsistence allowance to
help defray living expenses during the research training
experience.
 The stipend is not “salary” and is not provided as a
condition of employment with either the Federal
government or the grantee organization.
 Funds characterized as compensation may be paid to
fellows only when there is an employer-employee
relationship…(part time employment)

Trainees are NOT Employees
 Trainees may be paid on the training grant under
one of the following object codes.


01-5X “Post-doctoral research trainee salaries”
01-9X “pre-doctoral research trainee salaries”


Be sure the Job Code results in payment from one of these object
codes.
08-02 Stipend

(For trainees who do not qualify or want the UW health
Insurance.)
Trainees are NOT Employees
 Trainees are generally appointed to the training
position full time. (typically defined as no less than
40 hours per week)
 Trainees effort during this time may not be directed
away from the objectives of their training program.
 They are not to be assigned other work for the
university during this time.