Thanks All.  I have a couple of variations of my original question

Does anyone use funds from an NIH research grant to supplement a
NON-Federal fellowship - assuming the person's effort is on the research
grant?

Would you allow funds from an NIH research grant to supplement any other
Federal fellowships (Army, DOE, NSF) - assuming the person's effort is
on the research grant?

Aull, Robert M wrote:
> Rich,
>
> You can't use PHS funds to SUPPLEMENT a stipend, but you may use them for COMPENSATION of the fellow (see pages 177-178 of the NIH Grants Policy Statement below).  Supplementation = no additional obligation, and you can't pay someone funds from a research grant with no obligation of service.
>
> Note that the grants from which compensation could be paid must not involve the same research making up the fellow's training experience (for then there would be no additional obligation).
>
> Stipend Supplementation
>
> Kirschstein-NRSA fellows receive stipends to defray living expenses. Stipends may be supplemented by an institution from non-Federal funds provided this supplementation does not require any additional obligation from the fellow. An institution can determine the amount of stipend supplementation, if any, it will provide according to its own formally established policies governing stipend support. These policies must be consistently applied to all individuals in a similar status regardless of the source of funds. Federal funds may not be used for stipend supplementation unless specifically authorized under the terms of the program from which funds are derived. Under no circumstances may PHS funds be used for supplementation.
>
> An individual may use Federal educational loan funds or VA benefits when permitted by those programs as described in this subsection.
>
> Compensation
>
> NIH recognizes that Kirschstein-NRSA fellows may seek part-time employment incidental to their training program to offset further their expenses. Funds characterized as compensation may be paid to fellows only when there is an employer-employee relationship, the payments are for services rendered, and the situation otherwise meets the conditions for compensation of students as detailed in "Cost Considerations-Selected Items of Cost-Salaries and Wages-Compensation of Students." In addition, compensation must be in accordance with organizational policies applied consistently to both federally and non-federally supported activities and must be supported by acceptable accounting records that reflect the employer-employee relationship agreement. Under these conditions, the funds provided as compensation (salary, fringe benefits, and/or tuition remission) for services rendered, such as teaching or laboratory assistance, are not considered stipend supplementation; they are allowabl!
>  e charges to Federal grants, including PHS research grants. However, NIH expects that compensation from research grants will be for limited part-time employment apart from the normal training activities. Compensation may not be paid from a research grant that supports the same research that is part of the fellow's planned training experience as approved in the Kirschstein-NRSA individual fellowship application.
>
> Under no circumstances may the conditions of stipend supplementation or the services provided for compensation interfere with, detract from, or prolong the fellow's approved Kirschstein-NRSA training program. Fellowship sponsors must approve all instances of employment on research grants to verify that the circumstances will not detract from or prolong the approved training program.
>
> Robert Aull
> Indiana University School of Medicine
>
> -----Original Message-----
> From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Brenner Hill, Sandra
> Sent: Tuesday, June 10, 2008 11:45 AM
> To: xxxxxx@hrinet.org
> Subject: Re: [RESADM-L] NRSA stipend supplements
>
> I do not think you can use Federal funds to supplement federal funds when there is an established salary cap. You need to use either hard funds or Industrial funds.
>
> I am sure someone will correct me if I am mistaken (that's what I love about this list).
> Sandy
>
> Sandy Brenner-Hill, MPM, CRA
> University of Pittsburgh
> Research Administrator
> Department of Medicine
> 3347 Forbes Avenue First Floor
> xxxxxx@pitt.edu
> Phone: 412-383-1437
> Fax: 412-383-1663
> -----Original Message-----
> From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Rich Chiriatti
> Sent: Tuesday, June 10, 2008 11:35 AM
> To: xxxxxx@hrinet.org
> Subject: [RESADM-L] NRSA stipend supplements
>
> Do any of your Institutions supplement NRSA (F32) stipends with funds
> from other NIH grants (R01, P01, etc.)?   If so, under what
> circumstances do you reason it is allowable?
>
> --
>
>
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--
Richard Chiriatti, CRA
Associate Director
Office of Sponsored Programs
Whitehead Institute for Biomedical Research
5 Cambridge Center, Room 780
Cambridge, MA  02142-1493
Phone: (617) 258-5018
Fax: (617) 258-6184
E-mail: xxxxxx@wi.mit.edu

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 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
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