NRSA Institutional Allowance and Training Related Expenses Guidance

Created: September 2024
Responsible Office: Office for Sponsored Programs 

Overview

The National Institutes of Health (NIH) provides an Institutional Allowance or Training Related Expenses (TRE) to institutions and to predoctoral and postdoctoral trainees appointed on Kirschstein National Research Service Award (NRSA) institutional research training and fellowship awards. These cost categories are meant to defray expenses for the institution and individuals, such as fringe benefits (e.g. health and dental insurance), research supplies, and travel and to otherwise offset, insofar as possible, appropriate administrative costs of training.  

This Harvard guidance addresses questions about allowability of costs under the Institutional Allowance cost category on NRSA individual fellowship awards (Fs) and the Training Related Expenses (TRE) cost category for institutional training grants (Ts). Although there is similar information in both sections, there are a few key differences in which costs are allowable or unallowable for fellowships versus training grants, so each award type has its own section in this document. For information on how to request these costs in a proposal, please refer to the instructions in the NIH application guide and the funding opportunities for the specific award type (fellowships, training grants). Utilize the documents in the Resources section below for more information.

For institutional allowances or training related expenses on non-NRSA awards, please follow the terms and conditions of the sponsor.

Please note this guidance is only applicable to NRSA fellows and trainees.

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/SPA. 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 the use of their Institutional Allowance.

Individuals on these awards are considered non-employee fellows receiving stipends and all payments are considered nonqualified (taxable) payments to individuals and must be processed as a fellowship or grant to the individual, not as a reimbursement. See General Fellowship Information Brochure which explains the tax reporting requirements to the recipient if these are paid as a fellowship or grant.

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

The submitting offices are responsible for ensuring costs are appropriately budgeted. ORA, SPA, and OSP serve as a resource to the local unit. 

Defining and charging costs 

For private, non-profit institutions, the allowance is intended to defray expenses for the fellow and offset appropriate administrative costs of training. The Institutional Allowance is a fixed amount awarded to the institutions. Amounts are periodically updated by NIH and issued through an NIH Notice.

NIH policy outlines the type of expenditures that are appropriate to charge, but the expenditures must be charged according to institutional policy. The Institutional Allowance may be used for the following and may be taxable. Best practice is to pay these costs under stipendee payments for tax reporting purposes. See the Processing Institutional Allowances Matrix for further information.

Research Supplies and Equipment

For non-federal public and private non-profit institutions, the allowance is intended to defray expenses for the individual fellow such as research supplies and equipment.

Travel

Payment for travel to scientific meetings is appropriate when it is necessary for the individual's training and when the costs are incurred within the period of grant-supported training.

Funds may not be expended to cover the costs of travel between the fellow's place of residence and the domestic training institution.

For travel costs under the Institutional Allowance line item, these may have tax implications.  See the Processing Institutional Allowances Matrix for further information.

Health Insurance

Individual or family employer health insurance is an allowable cost for fellows who have families and are eligible for family health insurance coverage. Health insurance can include coverage for costs such as vision and/or dental care.

Costs for co-pays paid by the fellow are not allowed to be reimbursed. 

The assessment for health insurance for stipendee post-doctoral fellows is applied at a different rate.  The Stipendee Post-Doctoral Fringe Assessment breakdown can be found on the Office for Sponsored Programs (OSP) Fringe Benefits Rates website. Only the employer paid healthcare portion of the assessment is allowed as a direct charge under Institutional Allowance. Any portion of the fringe assessment that exceeds the healthcare portion of the assessment cannot be charged to this award.

Since Kirschstein-NRSA fellowships are not provided as a condition of employment with either the Federal government or the sponsoring institution, institutions may not seek funds, or charge individual fellowship awards, for costs that normally would be associated with employee benefits (for example, Federal Insurance Contributions Act (FICA), which funds Social Security and Medicare, workman's compensation, life insurance, union dues, and unemployment insurance). Concerning union dues or other similar costs otherwise paid personally by the fellow; if a fellow requests the institution deduct such a cost from the stipend amount, the institution can provide the fellow such a service. However, in no case can such a deduction from the stipend be made automatically without the approval of the fellow.

Amounts reimbursed cannot exceed actual expenses.

Medical Liability and Other Special Insurance

Medical liability (malpractice) insurance or other special insurance is an allowable cost to NRSA grants only if nature of the research training requires such special insurance. For instance, medical liability would be allowable if the research training experience involves direct contact with patients or human subjects. In all cases, for the cost to be charged to the NRSA grant, it must be consistently required for all in a similar training status, regardless of the source of support.

Special insurances that are routinely offered as optional employee benefits (such as disability insurance, life insurance, or workman's compensation insurance), are not normally allowable charges unless the nature of the research training requires special insurance.  Please refer to the postdoctoral assessment breakdown to ensure these costs are not charged under the Institutional Allowance line item.

If you believe that you have a need for this type of insurance, please contact your school sponsored programs office for additional guidance.

Extraordinary Costs

Extraordinary costs require prior approval from the sponsor. Additional funds may be requested by the institution when the training of a fellow involves extraordinary costs for travel to field sites remote from the sponsoring institution or accommodations for fellows who are disabled, as defined by the Americans with Disabilities Act. The funds requested for extraordinary costs must be reasonable in relationship to the total dollars awarded under a fellowship and must be directly related to the approved research training project. Such additional funds shall be provided only in exceptional circumstances that are fully justified and explained by the institution in the application or as part of a special written request (prior approval).

Who is eligible?  

Institutions that have applied for and received an NIH “F” type award.

Re-budgeting 

Expenditures within the Institutional Allowance cost category are not subject to NIH prior approval requirements. If the Institutional Allowance will not be expended, it can only be re-budgeted into the tuition and fees category when tuition and fees have been awarded. However, if re-budgeting between cost categories of a fellowship award, prior approval from the NIH awarding IC is required.

The institution may spend the full Institutional Allowance award upon activation of the award. However, if the fellow is not in a training status for more than 6 months of the award year, only half of that year’s Institutional Allowance may be charged to the grant. The Notice of Award will be revised, and the stipend and Institutional Allowance balances must be refunded to NIH.

Documentation 

Although we are not required by NIH to account for these expenditures on an actual cost basis, we are required to follow Harvard Policy for payments and reimbursements.  Costs charged to the Institutional Allowance line item should have appropriate evidence of the charge and when it was incurred to ensure the cost is allowable and allocable on fellowship. Amounts reimbursed cannot exceed actual expenses.

NRSA Training Grants (e.g., T32, T34, T35)

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/SPA. Local units assume the primary responsibility for posting and retaining related documentation/records in accordance with the terms of the award and Harvard policies.   

Principal Investigator/Program Director (PI/PD)  

The PI is responsible for working with the local level managing unit to communicate the needs of the project and budget and is responsible for the charges on the federal award.

Trainees 

Individuals participating in a NRSA training grant (e.g., T32). These individuals are responsible for adhering to their award terms and conditions and following NIH guidance and Harvard policies.

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

The submitting offices are responsible for ensuring costs are appropriately budgeted. ORA, OSP, and SPA serve as a resource to the local unit.  

Defining and charging costs 

Training-Related Expenses (TREs) are provided to defray costs such as staff salaries, consultant costs, equipment, research supplies, staff travel, trainee health insurance (self-only or family as applicable), and other expenses directly related to the training program. Funds are requested and awarded as a lump sum based on the predetermined amount per predoctoral and postdoctoral trainee approved for support. 

Many of the costs allowable under Training-Related Expenses may cover global costs for an institutional training program where the Kirschstein-NRSA support covers only some of the participating trainees. Budgetary levels for TRE can be found in an updated NRSA Budgetary Levels Notice on the NIH Notice of Policy Changes webpage.  Applying core cost principles of allocation and consistent treatment must be used when charging TRE costs and may be used for the following:

Health Insurance

Individual or family employer health insurance is an allowable cost for trainees. Health insurance can include coverage for costs such as vision and/or dental care.

Costs for co-pays paid by the fellow are not allowed to be reimbursed. 

Since Kirschstein-NRSA awards are not provided as a condition of employment with either the Federal government or the recipient, institutions may not seek funds, or charge individual Kirschstein-NRSA institutional research training grants, for costs that normally would be associated with employee benefits (for example, Federal Insurance Contributions Act (FICA), which funds Social Security and Medicare, workman's compensation, life insurance, union dues, and unemployment insurance). Concerning union dues or other similar costs otherwise paid personally by the trainee; if a trainee requests the institution deduct such a cost from the stipend amount, the institution can provide the fellow such a service. However, in no case can such a deduction from the stipend be made automatically without the approval of the trainee and institution.

Amounts reimbursed cannot exceed actual expenses.

Medical Liability and Other Special Insurance

Medical liability (malpractice) insurance or other special insurance is an allowable cost to NRSA grants only if nature of the research training requires such special insurance. For instance, medical liability would be allowable if the research training experience involves direct contact with patients or human subjects. In all cases, for the cost to be charged to the NRSA grant, it must be consistently required for all in a similar training status, regardless of the source of support.

Special insurances that are routinely offered as optional employee benefits (such as disability insurance, life insurance, or workman's compensation insurance), are not normally allowable charges unless the nature of the research training requires special insurance. 

If you believe that you have a need for this type of insurance, please contact your tub sponsored programs office for additional guidance.

Staff Salaries

Training programs may qualify as a "major project" where administrative salaries are allowable as a training-related expense. When charging these costs, you must follow cost principles and ensure the cost is allowable, allocable, reasonably reflects benefit to the grant and is consistently assigned as either direct costs or F&A costs.

Speaker Fees

When speakers are part of program required for NSRA-supported trainees, a portion of such a cost could be charged as Training-Related Expenses.

Meals

The cost of meals may be allowable if they are provided in conjunction with a meeting considered an ancillary activity to the training grant. A portion of such a cost could be charged as Training-Related Expenses. When charging these costs, you must follow cost principles and ensure the cost is allowable, allocable, reasonably reflects benefit to the grant and is consistently assigned as either direct costs or F&A costs.

Extraordinary Costs

Under exceptional circumstances, which can include accommodating the disabilities of a trainee, it is possible to request organizational costs above the standard level. Requests for additional costs must be explained in detail and justified in the application. Consultation with NIH program staff in advance is strongly advised.

Who is eligible?  

Institutions awarded an NRSA Training grant or trainees appointed to an NRSA Training grant.

Re-budgeting 

Rebudgeting of funds awarded in a lump sum for Trainee-Related Expenses does not require NIH awarding IC prior approval.

Documentation 

We are required to follow Harvard Policy for payments and reimbursements.  Costs charged to the TRE line item should have appropriate evidence of the charge and when it was incurred to ensure the cost adheres to cost principles. Amounts reimbursed cannot exceed actual expenses.

Resources

See also: