1. Is an Activation Notice (Form PHS 416-5) required every year?
   
   
2. What are the change of institution requirements for fellowships?
   
   
3. If a fellow moves and we process the award as a T-7, is an activation notice required?
   
   
4. What needs to be done when a fellow terminates early?
   
   
5. In FY97 the NIH began awarding $4,000 as the institutional allowance for fellowships. If a fellowship began prior to FY97 and included only $3,000 in the commitment for future years, should it be revised?
   
   
6. A potential fellow had prior NRSA support from another agency. Are they eligible for an F32 award?
   
   
7. Can a fellow have more than one sponsor?
   
   
8. Can a fellow submit an application if he/she has applied for a green card but hasn’t received it yet?
   
   
9. What are acceptable circumstances for approving a leave-of-absence on a fellowship?
   
   
10. The IRS and Treasury Department recently released final regulations clarifying the student exception to the FICA (Social Security and Medicare) taxes for students employed by a school, college, or university where the student is pursuing a course of study.
    Question: Do these regulations have an impact on Ruth L. Kirschstein National Research Service Awards (NRSA) supported by the NIH?
    
    
    
    

1. Should foreign and federal fellowships submit an Activation Notice (Form PHS 416-5) every year?
   
   
2. Are Payback Agreements required annually for foreign and federal fellows?
   
   
3. What extra steps are needed if a foreign or federal fellow terminates early?
   
   
4. Are there special issues concerning the Termination Notice for direct pay fellows?
   
   
5. Should foreign fellowships have their stipend and travel checks sent to a foreign or domestic bank account?
   
   
6. How is the Institutional Allowance awarded for a foreign fellow?
   
   
7. For Federal fellowships, is health insurance required?
   
   

1. Is an Activation Notice (Form PHS 416-5) required every year?

   No. Unless the fellow is at a foreign or federal sponsoring institution, an activation notice is only required for the –01 year.

2. What are the change of institution requirements for fellowships?

   This can vary somewhat depending on the NIH awarding component so individual Institutes & Centers (ICs) should be consulted for guidance. Some awarding components only allow transfers to "officially" occur on the anniversary date. Even if the physical move occurs mid-year, an arrangement is made for the old institution to continue to award the stipend until the end of the budget period. An application along with staff review and approval is usually required for a mid-year change of institution.

   Other ICs treat fellowship transfers the same as research grants. Therefore, if the move occurs mid-year, a T-7 application is submitted from the new sponsoring institution and an actual T-7 award reflecting the mid-year transfer is issued. Again, the awarding IC should be consulted for advice if a fellow is planning a move.

3. If a fellow moves and we process the award as a T-7, is an activation notice required?

   No. If the award is issued as a T-7, it should include a specific budget period (like a T-5). Thus an activation notice from the new grantee is not required. Like a T-5, the award itself is the authorizing document.

4. What needs to be done when a fellow terminates early?

   A Termination Notice should be submitted immediately upon termination. The Notice of Research Fellowship Award should be revised to reflect the early termination, as well as the amount of stipend actually paid (noted on Termination Notice). In addition, depending on the length of time remaining, adjustments to the Institutional Allowance may also be appropriate. It may be necessary to actually confirm with the sponsoring institution what, if any, amount remains before revising the award.

5. In FY97 the NIH began awarding $4,000 as the institutional allowance for fellowships. If a fellowship began prior to FY97 and included only $3,000 in the commitment for future years, should it be revised?

   No. This policy change did not include a grandfather clause, thus the change in the institutional allowance was effective with awards competing in FY97 and beyond. For these awards, the higher institutional allowance should have already been built into any future years. However, any award that competed and was initially awarded prior to FY97 will continue to be paid at the $3,000 level for the entire life of that grant. Bottom line—pay whatever is built into the commitment.

6. A potential fellow had prior NRSA support from another agency. Are they eligible for an F32 award?

   Postdoctoral fellows may receive up to 3 years of aggregate NRSA support, including any combination of support from institutional training grants and individual fellowship awards. Therefore, if the prior NRSA support was postdoctoral (individual fellowship and/or institutional training grant), they would only be eligible for additional fellowship support up to the 3 year aggregate limit, unless a special waiver is requested by the fellow and approved by the awarding IC. If, however, the prior NRSA support was predoctoral, this would have no impact on the amount of postdoctoral support.

7. Can a fellow have more than one sponsor?

   Yes. Sometimes it is advisable to have a second sponsor, especially if the project involves special expertise.

8. Can a fellow submit an application if he/she has applied for a green card but hasn’t received it yet?

   Yes. Permanent residency requirement for fellowships must be satisfied at the time of award—not application. See the NRSA Guidelines, Section II.A.3.

9. What are acceptable circumstances for approving a leave-of-absence on a fellowship?

   Section II.J.1 of the NRSA Guidelines (see June 20, 1997 NIH Guide for Grants and Contracts) provides information on the various types of acceptable leave. This includes sections on: 1) vacations and holidays; 2) sick leave and other leave; 3) parental leave; and 4) unpaid leave. In most cases, a "leave-of-absence" falls under the unpaid leave category. These are usually unique situations that require prior approval of the awarding IC. That office should be consulted for guidance.

10. The IRS and Treasury Department recently released final regulations clarifying the student exception to the FICA (Social Security and Medicare) taxes for students employed by a school, college, or university where the student is pursuing a course of study. Question: Do these regulations have an impact on Ruth L. Kirschstein National Research Service Awards (NRSA) supported by the NIH?

    Our understanding is that these final regulations do not apply to or impact Kirschstein-NRSA programs or awards. An NRSA stipend is provided by the NIH as a subsistence allowance for Kirschstein-NRSA fellows and trainees to help defray living expenses during the research training experience. NRSA recipients are not considered employees of the Federal government or the grantee institution for purposes of the award. We must note that NIH takes no position on the status of a particular taxpayer, nor does it have the authority to dispense tax advice. The interpretation and implementation of the tax laws are the domain of the IRS.

1. Should foreign and federal fellowships submit an Activation Notice (Form PHS 416-5) every year?

   Yes. For foreign and federal fellows, an Activation Notice is mailed by the awarding component annually along with each award, or may be obtained from NIH Forms and Applications page at http://grants.nih.gov/grants/forms.htm#training. The fellow must complete it and return it immediately to the awarding component (note the Activation Notice includes a block where the awarding component indicates the return address). Upon receipt, the awarding component must complete the bottom section of the form and then forward it to the Office of Financial Management (OFM), NIH. Since OFM uses the processed copy of the activation notice to authorize the payments, the fellow cannot get paid until OFM receives a copy of this form.

2. Are Payback Agreements required annually for foreign and federal fellows?

   No. A Payback Agreement is required only for the initial 12 months of postdoctoral NRSA support regardless of where the NRSA training takes place.

3. What extra steps are needed if a foreign or federal fellow terminates early?

   As soon notification is received that a direct pay fellow is terminating early, OFM should be contacted so that they can withhold further payments. Once a Termination Notice is received, the awarding component should revise the Notice of Research Fellowship Award to reflect the early termination, and forward a copy of the revised award and termination notice to OFM.

4. Are there special issues concerning the Termination Notice for direct pay fellows?

   Yes. Since we pay these fellows directly, no business official signature is required. Also, direct pay fellows are required to report to the IRS all money paid directly to them by government check; i.e., for foreign fellows, they must include any travel funds awarded.

5. Should foreign fellowships have their stipend and travel checks sent to a foreign or domestic bank account?

   While the NIH cannot require one or the other, fellows should be strongly encouraged to open a domestic bank account. This will avoid considerable delays encountered using foreign mail delivery.

6. How is the Institutional Allowance awarded for a foreign fellow?

   For Foreign fellows, two awards are issued. An –01 award reflecting stipend (and any travel funds) is issued to the fellow, using the fellow’s social security number as the EIN. After the –01 award is released, an –01X1 award is issued to the sponsoring institution for only the Institutional Allowance. The institution’s EIN is used on the -01X1 award.

7. For Federal fellowships, is health insurance required?

   Yes, Federal fellows are required to obtain health insurance either from the Foundation for Advanced Education in the Sciences (FAES) or from a private company. If the fellow elects coverage from FAES, the funds are provided separately from the Institutional Allowance in the "Other Expenses" category. If the fellow elects coverage through a private company, the allowable premium is provided in addition to the stipend level in the stipend category.

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