Graduate students and postdocs: You now have official permission from the U.S. government to attend that career event.
That’s the message of a recent policy clarification from the Council on Financial Assistance Reform, which was created in 2011 by the U.S. Office of Management and Budget (OMB). The clarification states that graduate students and postdocs hold “dual roles” as both trainees and employees. As a trainee, not just an employee, you are authorized to spend time away from the lab to develop other important skills, even when you are supported by federal funds. We’ve included the OMB language, from this document, in a box at the end of this article, for your reference. Feel free to send a link to your adviser; apparently some advisers still aren’t convinced.
You cannot misunderstand the language. There are no two ways of interpreting it.
Here’s the backstory: University administrators (and doubtless some graduate and postdoctoral advisers) were eager to provide career-development opportunities for their graduate students and postdocs. But some advisers—principal investigators (PIs)—worried that if they allowed their advisees to attend, they’d be breaking the law; in their view, those grant-supported trainees were being paid to do research. To address their concerns, an interagency working group involving the National Institutes of Health (NIH), the National Science Foundation, and several other agencies approached OMB: Would they be willing to clarify the policy? OMB readily agreed, and the statement was released on 29 August.
Beyond the bench
The dual-role clarification is important because training to be a professional scientist—whether you aspire to an academic position or some other kind of job—requires more than just time at the bench. Aspiring academic scientists need to learn to write grants and to teach. Aspiring science journalists need to practice interviewing people for stories. Aspiring tech-transfer specialists, and those who plan to work in industry in business-development roles, must master a large body of knowledge in business and law. You can’t get those skills at the bench.
OMB’s statement “sends a clear signal that NIH is recognizing that this is a training period and that training is more than just doing work in a laboratory or driving a research project forward,” says Naomi Rosenberg, dean of the Sackler School of Graduate Biomedical Sciences at Tufts University, Boston.
Vanderbilt University postdoc Lindsey Morris, who has participated in some of the university’s NIH-funded Broadening Experiences in Scientific Training (BEST) career-development programs, knows first-hand the importance of such training, which she did not receive in graduate school. After finishing her Ph.D., she wanted to work at a pharmaceutical company. She got a few interviews, which she thought went well, but no job offers. So, over the next 6 years, she worked as a research assistant in a diabetes lab, a process engineer at a paper mill, and a research associate in a lab studying diabetes and bone disease. Finally, she returned to academia for a postdoc.
“There are skills that I need that you just don’t get at the bench,” like networking or writing a resume. Without specialized career training, Morris says, “you get to the end of your postdoc, and what do you do? You haven’t spent any time building those really critical career development skills, and you’re left without a job. That’s not good for anyone, including your PI.”
Morris sees the clarification as a positive sign because it “shows that NIH knows this is an issue, that postdocs and grad students are not getting specific instruction in soft skills such that they can transition successfully to their next jobs”—whatever those jobs may be.
Just a piece of the puzzle
The OMB statement doesn’t answer specific questions, such as how much time a trainee can spend on training activities outside the lab, or the types of training that are appropriate. That’s good, says Linda Hyman, associate provost of Boston University’s Division of Graduate Medical Sciences. “It really leaves it open to an individual situation and need. It’s not an unfunded mandate; it’s just a clarification that this is an allowable use of time and effort.”
Still, in principle, the clarification completely takes care of the question whether grant-supported trainees should be allowed to participate in career development opportunities, says Ambika Mathur, dean of the graduate school at Wayne State University in Detroit, Michigan, and a BEST grant PI. Wayne State began its BEST program before the clarification was issued and found that “research faculty mentors were reluctant to allow students to participate … because they were worried it would be violation of rules,” Mathur says. Now, though, the guidelines “say very clearly that trainees are permitted to go and seek these opportunities. … You cannot misunderstand the language. There are no two ways of interpreting it.”
That, apparently, is not enough to convince some PIs, however. Mathur and two other BEST grant PIs—Bill Lindstaedt of the University of California, San Francisco, and Roger Chalkley of Vanderbilt University—say that some faculty members at their institutions remain hesitant to let their trainees participate, even after the clarification. “I don’t see an individual postdoc going to a PI and saying, ‘The government says you have to let me go to this training,’ ” Lindstaedt says. “That’s kind of what the announcement means, but I don’t think it’s likely to happen.”
No one thinks this clarification will revolutionize the graduate student and postdoc experience. “This is one piece, a helpful piece, that people can pay attention to, but we can’t just have that,” Rosenberg says. “If their PI is dissatisfied if they take time away from the lab, this is one way in which a person could try to educate that PI that this is important. But that alone is not going to change our culture.”
“I think that it resonates because it comes from the funding source,” Hyman says. Others echoed this sentiment, emphasizing the role funding will play as a motivating force for PIs who might at first be hesitant to encourage lab members to pursue career development opportunities. Mathur says that study sections should make funding dependent in part upon whether submitted grants include appropriate training plans and opportunities; that would help convince even resistant PIs to at least consider these issues, she says.
“I think it requires a conversation around the interpretation, and I think that as leaders, it is our responsibility to have that conversation with the training faculty,” Hyman says. “I certainly have used it in my conversations with leadership, and with faculty, to demonstrate NIH’s and the federal government’s support of professional development opportunities for trainees.”
Over the next few years, the community will keep a close eye on how the clarification and its implementation play out, to determine if further modifications are needed, says Michelle Bulls, director of the NIH Office of Policy for Extramural Research Administration, who worked on the statement. “While we believe we’ve addressed the concern and tried to leave it at the discretion of the agency and the grantee, OMB is willing to relook at all of the changes and clarifications,” she says. “It will take about 3 years to figure out if this is good, bad, or indifferent.”
*.400-2 Dual Role of Students and Post-Doctoral Staff
The Uniform Guidance states; “For non-Federal entities that educate and engage students in research, the dual role of students as both trainees and employees contributing to the completion of Federal awards for research must be recognized in the application of these principles.” Staff in postdoctoral positions engaged in research, while not generally pursuing an additional degree, are expected to be actively engaged in their training and career development under their research appointments as Post-Docs. This dual role is critical in order to provide Post-Docs with sufficient experience and mentoring for them to successfully pursue independent careers in research and related fields.
Does 200.400(f) require recognition of the dual role of postdoctoral staff appointed on research grants as, both trainees and employees, when appointed as a researcher on research grants?
Yes, the Uniform Guidance 200.400(f) requires the recognition of the dual role of all pre and post-doctoral staff, who are appointed to research positions with the intent that the research experience will further their training and support the development of skills critical to pursue careers as independent investigators or other related careers.
Neither Pre-Docs or Post-Docs need to be specifically appointed in ‘training’ positions to require recognition of this dual role. The requirements and expectations of their appointment will support recognition of this dual role per 200.400(f).