NSF GRFP "outside work" and federal funds question

[alpal14]

Hello! I am writing to see if anyone who is/was an NSF GRFP fellow has experienced a similar sort of question as I am currently facing...

To make a long story short, I am a first year NSF GRFP fellow and have recently been invited to join a research project at another institution (and I really want to participate!). The project would not exceed my weekly hour limitation for "outside work" (25%/10 hours set by my institution); however, the project is a multi-institution initiative funded by NSF. My institution's CO has told me that I would NOT be able to take the position because NSF GRFP fellows are not allowed to accept "stipend supplementation" from federal sources. HOWEVER, the wording in the Administrative Guide for fellows seems to indicate that federal funds are not allowed for "fellowships" that "support the graduate education of individuals." The wording is not geared at all toward paid work. As a research assistant in the project, the funds would not be supporting "graduate education." I would be simply working a job external to my university, paid hourly, very similar to what I am doing now.

Here is a section from the NSF GRFP Administrative Guide about federal funds:

 

"Starting with the 2011-2012 Fellowship year, GRFP Fellowships cannot be concurrently accepted or combined with support from another federal graduate fellowship, irrespective of the Fellow’s status. Federal graduate fellowships are defined as awards that are offered to individuals from the US Government (e.g., Department of Defense, Department of Energy, Environmental Protection Agency, National Institutes of Health, National Oceanic and Atmospheric Administration, Department of Agriculture, and National Aeronautics and Space Administration) to support the graduate education of individuals." 

 

My questions: Has anyone else experienced navigating this nuance and lack of clarity in NSF GRFP guidelines? ***Can I work as a research assistant on this project? How can NSF guidelines be interpreted appropriately in this case? 

[juilletmercredi]

The coordinating official (CO) is the final word on this. There's a section in the Administrative Guide on stipend supplementation:

Each Fellow is expected to devote full time to advanced scientific study or work during the Fellowship Period. However, because it is generally accepted that teaching or similar activity constitutes a valuable part of the education and training of many graduate students and such opportunities may arise during a Tenure year, a Fellow on Tenure may choose to undertake a reasonable amount of such activities without NSF approval. It is expected that furtherance of the Fellow's educational objectives and the gain of substantive teaching or other experience, not service to the institution as such, will govern these activities. Compensation for such activities is determined by the GRFP Institution and is based on the institution’s general employment policies. Fellows are required to check with their GRFP Institution about specific policies pertaining to the GRFP Fellowship and paid activities.

Fellows are permitted to solicit and accept, from NSF or other federal and private sources, support for research expenses, such as laboratory supplies, instrumentation usage fees, field-station usage fees, travel expenses, conference/registration fees, workshop expenses, or subscription fees. For Fellows on Tenure, support for living expenses associated with off-site research activities will require approval by the CO. Fellows are required to check with their GRFP Institution about specific policies pertaining to acceptance of any non-federal fellowships.

If your CO's final decision is that this is not allowed by GRFs, then there's your answer. You can talk to them and show them the Administrative Guide and show that support for living expenses is not necessarily barred if the funding is not technically a federal fellowship. Occasionally, coordinating officials have outdated information or are not aware of updates to the Administrative Guide. (I developed a close relationship with my CO because I was always doing something I maybe wasn't supposed to be doing and was an annoying Rules Lawyer, lol.) But you may be unsuccessful, since the definition of supporting graduate education of individuals is broad, and can definitely include work as a research assistant - particularly if you would be getting research credit for doing it, but even if you're not. Research activities definitely constitute part of graduate education, so an RAship can be interpreted that way.

Arguing that it's simply a "job" or "paid work" that's external to the university is not very likely to work, both because of the nature of the work and because of the NSF's poliices on paid work:

Outside employment is not governed by the NSF. Fellows should check with their CO about specific institution policies.

So basically, we're back to "the CO is the final word on this." They could very well mean that at their institution they don't allow NSF fellows to get stipend supplementation from federal sources. You can always ask if you could pursue the RAship without the pay.