Definition

A Graduate Student Appointment (GSA) enables Graduate Students to work part-time while pursuing their graduate degree.  A GSA is often funded from a Sponsored Award to cover salary for effort spent on the Award, associated fringe benefits, and a portion of tuition and associated fees.

This funding for salary, associated fringe and tuition coverage is referred to as Graduate Student Compensation.

UW uses the GSA definition as developed by the National Institutes of Health (NIH).

These appointments are different than funding issued under:

GSAs can only be appointed at 50% full-time effort (FTE) However, they are considered full time appointments.  The reason for this is that it is expected that a GSA will use the remainder of his/her effort for their academic studies.

 

Limitations

On Federal Awards, tuition is not an allowable expense unless under a GSA or Training or Fellowship Grant (reference 2 CFR 200.446).   

The tuition payments for GSAs are limited to the portion of tuition and fees that are covered under a state-sponsored tuition waiver. This is to ensure that tuition waivers are the same for all GSA appointments, regardless of the source of the waiver.

Information on state-sponsored waivers can be found here.

The amount of funding and the effort expended can also be limited by the sponsor. Review the award and sponsor regulations for specific requirements.

 

National Institutes of Health (NIH) GSA Limitations

Reference:

NIH Grants Policy Statement (GPS) Section 2.3.7.9. Graduate Student Compensation

There are a few key concepts to keep in mind when applying the NIH regulations to GSAs:

  • NIH does not want to fund GSA’s at a higher level than the compensation rate for a Post Doc doing similar research;
  • GSA compensation funding includes salary, fringe benefits, and tuition.  Post Doc compensation includes salary and fringe benefits (not tuition); and
  • GSA appointments are for 50% FTE; Post Doc appointments are for 100% FTE.

 

NIH Funding Limitation

NIH limits the GSA compensation funding level on their research grants to the National Research Service Award (NRSA) zero-level stipend for a Post-Doc Trainee. The reason for this is a GSA should not receive more compensation than a Post Doc doing similar work.

While this is a limitation on the amount of funding provided by the NIH, it may not necessarily be a limitation on the amount of compensation actually paid to a GSA (see below). 

For example:  the NIH “zero-level” is $40,000 (a fictitious number, just used for these examples); the amount that can be funded for a GSA cannot exceed $40,000:

      “Zero-level” Post Doc Stipend Amount

                                   GSA

$40,000

Salary

$20,000

Fringe @ 10%

$2,000

Tuition

$18,000

Total

$40,000

 

The “zero-level” limitation can be the cause of confusion between a GSA and funding on a Training Grant. Again, GSAs are not the same as Trainees appointed to Training Grants; NIH uses the NRSA stipend level to set the funding (not expenditure, see below) amount for a GSA.

It is understood that a full GSA appointment is 50% FTE and a Training Grant Post Doc is 100% FTE.  An adjustment to the funding level on a GSA or Post Doc cannot be made based on this difference.

 

Budgeting for an NIH GSA

GSA appointments are typically identified in a proposal and the funding is allocated by Object or Account Code as follows:

Object/Account Code

Description

01-40

Salary

07-03

Fringe Benefits

08-05

Tuition

 

If it is anticipated that the actual amount paid to a GSA will exceed the “zero-level” (see below) and that amount is included in the proposal budget, NIH will reduce the amount of funding by the amount included in the proposal that is in excess of the “zero-level.”

Amounts over the NIH Limitation

In some departments, the minimum pay for a GSA may be greater than the “zero-level” amount funded on an NIH award.  In this case, departments have two options:

  • Charge the amount over the NIH funded amount to a non-federal funding source (e.g., department funds); or
  • If Re-budgeting is authorized under the terms of the NIH Award, increase the amount charged to the NIH award via Re-Budgeting (see below).

 

Re-Budgeting

NIH may allow for re-budgeting, without their approval, to increase the amount allocated within the budget and paid to a GSA under the following conditions:

  • The amount paid to a GSA is “reasonable,” which is defined by NIH as the minimum amount (and associated benefits) set by the department for a first year Post Doc position (GSAs cannot be paid more than a Post Doc); and
  • There are sufficient funds in the NIH Award to allow for the increase payment to the GSA(s) while at the same time ensuring that the terms and objectives of the award will be completed without the need for any additional funding from the NIH.

Take the following steps to determine if the NIH award allows for Re-budgeting:

  • Review the terms of the NIH Award to identify any requirements for Re-Budgeting or other restrictions on GSA funding.  If the Award is silent then,
  • Review the Program Announcement that the Award was issued under.  If the Program Announcement is silent on Re-budgeting or other restrictions on GSA funding then,
  • Review the NIH Grants Policy Statement (GPS) and follow the guidelines for GSAs.  As of July 2016, information on GSAs can be found in section 2.3.7.9. 

Re-Budgeting Examples:

  • The amount funded by NIH for a GSA is (for example) $48,000.  The department’s minimum pay for a GSA is $55,000.  The award allows for re-budgeting and the department has identified $7,000 ($55,000 – $48,000) available in the award that can be allocated to a GSA.  The department re-budgets the $7,000 to the GSA and charges the total $55,000 to the NIH award.
  • The department budgeted for and the NIH funded one GSA for $48,000.  After the award was issued, the department identified the need for another GSA.  The department determined that Re-budgeting was allowable and identified sufficient funds in the award to fund a second GSA without impacting the terms and objectives of the award.  The department re-budgeting $48,000 for the second GSA and charged $96,000 for two GSAs to the award.

Increases in “Zero-Level” Amount

If, after an Award with GSAs has been issued, the NIH increases the “zero-level” amount, the departments may increase the amount paid to the GSA to the new level provided that there are sufficient funds in the Award to cover the increase. Departments can Re-budget to allocate the necessary amount of funding to cover the increase assuming that Re-budgeting is allowable and that the terms and objectives of the award will be completed without the need for any additional funding from the NIH.