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Preface
This manual has been designed to help you and the NCI manage and administer
T32 Institutional National Research Service Awards as efficiently and accurately
as possible by highlighting the common errors made by grantees when submitting
information to the NCI and showing grantees how to avoid these errors. The
information that you are required to submit and that the NCI is required to
monitor for accuracy is determined by the legislative "payback" provisions
mandated by the Congress of the United States. There are no shortcuts for
submitting this kind of information, so the best way for the grantee and the NCI
to eliminate unnecessary work is to submit the required information correctly
the first time and avoid back-and-forth corrections that take so much of our
time.
Return to T32 Frequently Asked Questions
Table of Contents
- Introduction
- How to
make an Inquiry to the NCI
- Updating Your
"Contact Information Form"
- Common
Errors Made in Submitting Information About Trainees - How to Avoid Them
A. Statement of Appointment (Form PHS 2271)
- Item 4 - Type of Action
- New Appointments
- Reappointments
- Amendments
- Item 5 - Prior Support (Under NRSAs)
- Item 8 - Citizenship (Documenting Residency Status)
- Item 11 - Discipline, Specialty, or Field (For Research Under This NRSA
Support)
- Item 13 - Education
- Date of Degree
- Foreign Degree Equivalency
- Item 17 - Support for Period of Appointment
- Determining Stipend Levels for Postdocs
- Relevant Postdoctoral Experience
- Documenting discrepancies between Education information (Item 5) and basis
for stipend support
B. Notice of Termination (Form PHS 416-7)
- Item 6. Dates of NRSA Support
- Item 7. Total NRSA Stipend Received and Months of Support
- Item 8. Summary of Training Received
- Item 9a. Indicate Post Award Activity
- Item 10a. Mailing Address after Termination
- Items 12, 13, and 14 - Signatures
- Official NIH
"National Research Service Award Guidelines"
- Appendices:
- Extra "Contact Information Forms"
- Example Statement of Appointment (Form PHS 2271) for Reference
- Example Termination Notice (Form PHS 416-7)
- Examples of Acceptable and NON-acceptable Residency certifications
- Example of degree certification when the diploma has not been issued
yet
The Manual is designed to help you and the National Cancer Institute (NCI)
manage T32 Institutional National Research Service Awards (NRSAs) as
efficiently, accurately and easily as possible. Within this manual, we have
highlighted from our experience the areas that contribute the most to reporting
errors and that require continued follow-up effort, and a lot more work,
to correct these errors before the NCI can log in the information required for
the "payback" provision defined in Congressional legislation. It is this payback
requirement that places both the grantee and the NCI in a position of less
flexibility compared to the reporting requirements of other grant forms
sponsored by the NIH. With over 1,700 trainee positions to monitor for
correctness each year, this is an immense administrative task for the NCI. The
burden of reporting the information about trainees can be reduced considerably
if it is submitted correctly at the outset, avoiding time-consuming follow-up by
the NCI.
While we have made every effort to identify the most common errors in
managing T32 institutional NRSAs, we urge you to read the full "National
Research Service Award Guidelines" in Section V. of this manual. This is the
official NIH policy document that governs the management of NRSAs.
With the above in mind, we need your cooperation in implementing a number of
changes in your administration of the T32 Institutional NRSAs:
- Provide us with a timely, updated "Contact Information Form" (See Appendix).
Our ability to communicate quickly and effectively is the key to easy
administration of these grants. While we hold the Principal Investigator (PI)
responsible for the management of T32s, we know that in most cases there is
someone who has been delegated much of the day-to-day administrative tasks. We
need the key contact information for both the PD and the day-to-day
administrator working for the PI. It is essential that we have current e-mail
addresses. E-mail will become our first mode of communication. Phones will
be used only when there are complicated issues to deal with that require
discussion.
You in turn will be provided an "NCI Contact Form" that you can use in making
inquiries. It will contain e-mail contact information for general
administrative inquiries with regard to submitting correct information about
trainees, and the NCI Program Director contact when the PI wishes to discuss
matters dealing with major policy issues or scientific issues.
- When information needs to be corrected, NCI staff will do it unilaterally
when they know the answer or can find the answer easily. They will send you the
corrected document for your institution's records and NCI's records. Corrected
documents will be stamped "NCI Official Copy". When appointment and termination
forms need to be corrected by you, the NCI will expect the corrected version to
be sent back to us within two weeks.
- When you are reporting information about trainees, refer to this manual
to avoid common errors. We will tell you the kinds of errors that are made,
how to avoid them, and provide examples that illustrate correct practices. This
manual provides most of the information and instructions you will need to manage
T32 Institutional NRSAs, ranging from the official guidelines issued in the NIH
Guide to the problems areas highlighted and discussed by the NCI.
- If after looking at everything and you still have a question, please send us
an e-mail to initiate the dialogue rather than a phone call. If it is a simple
solution, we can take care of it by e-mail. If it is more complex, we will call
you.
With regard to the administration of your grant and the correct ways to
submit information about trainees on T32s, please use the following procedure:
- If you don't know the email address of the NCI Grants Technical Assistant
for your grant, then send an e-mail to the following address ctbtraining-r@mail.nih.gov. Provide
your grant number (e.g., T32 CA ________), state the issue or question
that you have, provide your phone number, AND the times of the day that you are
most likely to be available for a phone call.
With regard to major policy issues or scientific issues, make your inquiries
as follows:
- Send an e-mail to the NCI Program Director who is noted on your "NCI
Contact Form". Provide the grant number (e.g., T32 CA ________), state
the issue or question that you have, provide your phone number AND the times of
the day that you are most likely to be available for a phone call. You will be
contacted by either the Program Director or the Chief of the Cancer Training
Branch, depending upon the nature of your inquiry.
A blank copy of the "Contact Information Form" is provided in the Appendix.
We find that a great deal of time is wasted when the PD/P.I.. assigns a new
person to administer and submit the information about trainees and the NCI is
not provided with appropriate contact information. Please make it a part of your
routine procedure to submit immediately an updated "Contact Information
Form" if there is a change in the PI on a temporary or permanent basis or a
change in the individual assisting the PI in administering the grant. Any
breakdowns in our ability to communicate with each other quickly and easily will
cost us needless extra time and effort.
A. Statement of Appointment (Form PHS 2271) - See Appendix for Blank Example
Form
- Item 4 - Type of Action
- New Appointments: All new appointments must be for a 12-month period.
Institions must obligate 12 months of stipend and tuition from the same fiscal
year as the new trainee appointment. You must complete the entire Form 2271. It
is important to be accurate, especially about the date of receipt of a degree
and use of the correct stipend level.
- Reappointments: Reappointments are easy to do. Remember you do not have to
fill in any new information in the shaded portion of Form PHS 2271.
- Amendments: An amendment of information about a trainee concerning a change
of name, change of permanent mailing address, appointment period or support
from this grant cannot become official until it is submitted.
Amendments must be submitted as soon as the change occurs.
All New Appointments, Reappointments, and Admendments MUST be reported to
the NCI as soon as the occur.
- Item 5 - Prior Support
This refers to any prior support only from NRSA grants. This is
vital information in maintaining a record of an individual's payback
obligations. Predocs are allowed by law 5 years of total support from NRSA
grants and Post-docs are allowed by law only three years of total support from
NRSA grants. For example, if a postdoc was supported on a T32 from the National
Institute of General Medical Sciences or the National Aging Institute for one
year at your institution or another institution, they are only eligible for two
more years of support on a T32 from the NCI. The same would hold if they had
been supported from an individual NRSA F32 award for one year.
- Item 8 - Citizenship (Documenting Residency Status)
Many grantees make mistakes in documenting residency status of foreign
nationals. There are only two forms of certification of residency status that
are acceptable: 1) a notarized Alien Registration Receipt Card (I-151 or
I-551); or 2) a passport stamped and dated by the Immigration and Naturalization
Service. Examples of each are provided in Appendix D. A letter from the
Immigration and Naturalization Service is NOT ACCEPTABLE. Using this letter as
evidence of verification of residency status is a common error made by many
grantees.
- Item 11 - Discipline, Specialty, or Field
This refers only to the discipline, speciality or field of the
research of the trainee while being supported on this grant. A common
error is to relate this Item to the Trainee's degree or past experience.
- Item 13 - Education
- Date of Degree
It is important that you include the month and the year that a degree
was officially awarded to a trainee. Many grantees provide only the year and not
the month. We need both to properly calculate and confirm the appropriate
stipend for the trainee and enter the information into the NIH database.
Often a trainee's official month and date for receiving a degree is when they
received their diploma. Since the receipt of a diploma often is delayed from the
time that the trainee completes all requirements for a degree, you can obtain
confirmation in a letter from the degree awarding institution before the trainee
officially receives a diploma. The letter must show the exact date that the
trainee completed all requirements for the degree. An example of an appropriate
letter is provided in Appendix E. It is should be clear on the Statement of
Appointment that the appointment date of the postdoc is on or after his/her
official completion of all requirements for the doctoral level degree. A letter
from a thesis advisor is not acceptable. It should be a an official letter from
the institution (e.g., Registrar or Dean of the Graduate School).
- Foreign Degree Equivalency
Many trainee's come from foreign countries in which their degree is not
comparable to the usual standards accepted in the U.S. It is the
institution's responsibility to determine degree equivalency. The NCI
will not adjudicate any disputes in this area.
- Item 17 - Support for Period of Appointment
- Determining Stipend Levels** for Postdocs
This is one of the most common areas for error. The stipend levels that you
use are determined by the Congressional language for each fiscal year that your
grant was awarded**. The Federal Fiscal Year begins October 1 and ends September
30. Thus, fiscal year FY99 extended from October 1, 1998 to September 30, 1999.
Below are illustrated a few extreme examples to illustrate how to choose the
correct stipends.
**Updated stipend levels are always provided at the following website
address: http://grants.nih.gov/training/nrsa.htm
Example A: Your T32 was awarded September 30, 1998, the last day
of Fiscal Year FY98. This means that any appointees that you make from September
30, 1998 to September 29, 1999 are under the stipends in effect in FY 98. You
cannot take advantage of the higher stipends offered in FY99 starting October 1,
1999 because your grant was awarded in FY98. The common error is to
believe that when you appoint a trainee, for example, in December that you can
use FY99 stipend levels.
Example B: Your T32 was awarded July 1, 1998 and you want to make
appointments to the grant between July 1, 1998 and June 30, 1999. In this case
you must use FY98 stipend levels until you receive your next award July 1, 1999,
at which time you can employ FY99 stipend levels.
Remember, the stipend levels you can use are determined by the fiscal year in
which your grant was awarded and are in place for an entire one-year grant
period. We are all legally bound to use the correct stipends; it is just as
important to not overpay a trainee as it is to not underpay a trainee.
- Relevant Postdoctoral Experience:
This relates to anything in which your degree and training were essential to
the postdoctoral experience. It does not relate only to research experiences but
to non-research experiences (e.g., teaching, health practice, relevant
education). It is very important to consider all relevant experience (research
and non-research when determining the stipend level of a postdoc).
- Documenting discrepancies Between Education Information (Item 5) and the
basis for stipend support.
Often grantees present a date for receiving a doctoral level degree that
doesn't match up with the stipend level chosen. For example, an individual
received a Ph.D. on a certain month and day of 1994 but the stipend level
requested (in 1999) is for 3 years of postdoctoral experience rather than for 5
years. The NCI is obligated to follow up on these discrepancies. If you have
this kind of discrepancy, either correct it because it is inaccurate
or explain it. The ONLY reason a discrepancy like this can be true is if
the trainee took personal time off from their professional career. If this is
the case, you must provide a note of explanation with the Form PHS
2271.
B. Notice of Termination (Form PHS 416-7)
- Item 6 - Dates of NRSA Support
Please make sure that this matches with the dates requested on your
Statements of Appointment. Otherwise, the NCI will have to follow up on this
discrepancy and it will cost us all a lot of time to make the corrections.
- Item 7. Total NRSA Stipends Received and Months of Support
This information must also correspond exactly with what was requested
and accepted by the NCI on the Statements of Appointment for trainees. This is
critical information that must be in the NIH tracking system in order to
accurately determine a trainee's payback obligation. Always ensure that
the stipend information on the Statements of Appointment are exactly comparable
to the stipend information presented in the Termination Notice.
- Item 8. Summary of Training Experience.
This must be completed in detail. A few sentences are not adequate and
will force NCI staff to request more information. We expect a substantive
paragraph or two along with a list of all of the publications that resulted
during the training experience.
- Item 9a. Indicate Post Award Activity
Many Notices of Termination leave this information out. It must be
included or we will have to ask for the information and delay the clearance of
the trainees termination.
- Item 10a. Mailing Address after Termination
This must be provided. If the trainee has a payback obligation, there
must be a way to contact the trainee. It is a legal obligation to provide this
information.
- Items 12, 13 and 14. Signatures
All three signatures are necessary to make the Termination Notice official.
The Trainee (line 12), the Program Director (line 13), the institutional
Business Official (line 14) must all sign in the appropriate places
provided.
Official NIH
"National Research Service Award Guidelines
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