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NRSA Childcare Costs Guidance

  • Created: July 2023
  • Effective: August 2023
  • Responsible Office: Office for Sponsored Programs

Overview

The National Institutes of Health (NIH) provides childcare cost support to recipients of full-time National Research Service Award (NRSA) fellowships and full-time predoctoral and postdoctoral trainees appointed on NRSA institutional research training awards. This is in recognition of the high cost of childcare that impacts graduate students and post-doctorates funded through NRSA fellowships, and hinders their ability to successfully complete their training and fully participate in the extramural research workforce (NOT-OD-21-074).

This Harvard guidance is divided into two sections: one for NRSA fellowships and one for NRSA training grants. Although there may be similar information in both sections, there is an important distinction to how these funds are awarded to the recipient. Please refer to the Program Announcement (fellowships, training) and utilize the documents in the Resources section below for more information.

For childcare costs on non-NRSA awards, please follow the terms and conditions of the sponsor.

For childcare costs when an individual is in travel status, please refer to the Sponsored Expenditure Guidelines.

NRSA Fellowships (e.g., F30/F31/F32)

Roles and Responsibilities

Department/Local Level Managing Unit (DLLMU)

Local level managing units are responsible for developing proposals and managing awards in compliance with this guidance and NIH Policy. This includes coordination with the PI and OSP/ORA. Local units assume the primary responsibility for posting and retaining related documentation/records in accordance with the terms of the award and Harvard policies. 

Fellows

Individuals participating in pre- or postdoctoral NRSA fellowships (e.g., F30, F31, F32). These individuals are responsible for adhering to their award terms and conditions and following NIH guidance and Harvard University procedures for childcare costs reimbursement. This includes:

  • notifying research administration staff if they are eligible to apply for and be reimbursed for a childcare allowance, and
  • requesting funds for childcare reimbursement in the proposal, the RPPR or a supplement if a proposal has been submitted, and
  • ensuring their childcare facility is properly licensed to be reimbursed.

Idividuals on these awards are stipendees and these types of payments are considered nonqualified (taxable) payments to individuals and must be processed as a fellowship/grant to the individual not as a reimbursement. General Fellowship Information Brochure which explains the tax reporting requirements to the recipient if these are paid as a fellowship/grant.

Office for Sponsored Programs/Office of Research Administration (OSP/ORA) 

The submitting offices are responsible for ensuring costs are appropriately budgeted, and if awarded (via initial request or revision), setting indicators in the GMAS system. ORA and OSP serve as a resource to the local unit.

Defining and charging costs

Childcare costs are permitted for dependent children living in the fellow’s home from birth until the age of 13, or, for children who are disabled, until age 18. A disabled person is defined as those with a physical or mental impairment that substantially limits one or more major life activities, as described in the Americans with Disabilities Act of 1990, as amended. Childcare costs do not apply to elder or non-child dependent care costs.

The NRSA childcare costs are not tied to payback obligations, nor should it be reported as such. Childcare cost reimbursement is considered taxable income.

Childcare must be provided by a licensed childcare provider. Recipients of the childcare allowance (fellow/trainee) must maintain all supporting documentation (e.g., proof provider is licensed) and make it available to NIH officials upon request. NIH does not require recipients to submit this supporting documentation except when specifically requested.

Who is eligible? 

The NRSA childcare costs apply to each full-time predoctoral or postdoctoral appointment with a qualifying child on NRSA mechanisms supporting predoctoral and postdoctoral appointments. Undergraduate appointees and short-term appointees are not eligible for reimbursement.

For households where both parents are NRSA fellows, each parent is eligible to receive $2,500 per budget period.

Applicants and recipients may request the NRSA childcare costs as part of new applications (Type 1), continuation applications (Type 5), or as an administrative supplement request (Type 3).

Re-budgeting

When childcare costs are awarded, they are restricted and cannot be re-budgeted without prior written approval from the NIH Awarding Institute.

For fellowships that terminate early, recipients may not use any unused portion of the childcare costs.

Documentation

These types of payments are considered nonqualified (taxable) payments to individuals (employees or fellow stipendees) and must be processed to meet tax reporting withholding requirements to the individual. These should not be processed as a nonemployee reimbursement, but instead be processed following the Processing Childcare Costs matrix, specifically following the instructions in the rows for nonemployee individuals that are Monthly External Postdocs (stipendee) (MEP), or Monthly Student Stipends (MST) pay groups. For purposes of this guidance, additional documentation for reimbursement must include:

  1. Childcare Costs Reimbursement form
  2. Childcare license number
  3. If reimbursed by a fellowship, provide evidence that the cost is allowable by including a copy of the approved NIH award notice including the costs.

Resources