Extension Exceptions for Non-FTE Trainees for COVID-19

Last Revised on February 7, 2023

Due to the extended nature of the SARS-Cov-2/COVID-19 pandemic the Office of Intramural Research has modified the extension policy for trainees including IRTAs, CRTAs, Visiting Fellows, Research Fellows and Clinical Fellows. This policy is effective immediately. In general, pre-existing mechanisms will be used for requesting extensions with the understanding that requests may require rapid turnaround given these unique circumstances.

General Procedural Notes

• Renewals should be processed remotely during this telework period; trainees can also complete their health insurance re-enrollment process remotely.

Extensions for Postbac IRTA/CRTAs

• No approval is needed to extend a second-year postbac for an additional three months beyond their termination date.
• Postbacs seeking a third-year exceptional extension should follow guidance at the OIR Sourcebook Renewals section. For more details on this process, please reference this document on the OIR Sourcebook. Questions about this process should be directed to OITE.

For Predoc IRTA/CRTAs and Visiting Fellows

• Guidance is provided at the OIR Sourcebook in the Renewals sections for Predoc-IRTA/CRTAs and Predoc Visiting Fellows, with the following change – interviews will not be required for extensions of 6-months or less. Questions about this process should be directed to Dr. Philip Wang.

For Postdoc IRTA/CRTAs and Visiting Fellows

Current Policy Effective as of August 1, 2022 (Please see the Postdoctoral Fellows (IRTA/CRTA/VF) Temporary Exceptional Extensions Policy for additional information)

• IRTA/CRTAs currently in their 4^th to 5^th year at NIH may request a 6-month extension past the 5^th year without incurring the “no remain or return to NIH for 2 years” condition for entering an exceptional 6^th year at NIH. Those requests must be in a memo from the responsible IRP PI, approved by the SD, and sent to Dr. Arlyn Garcia-Perez, who will review, decide and document the decision.
• IRTAs/CRTAs who wish to have a full 6^th year must follow existing rules requiring “no remain or return to NIH for 2 years” and these will be processed as they are now.
• Because of individual immigration histories, Visiting Fellows currently in their 4^th to 5^th year may request a 6-month extension past the 5^th year, provided they are eligible for a G7 J1 visa, without incurring the “no remain or return to NIH for 2 years” condition for entering an exceptional 6^th year at NIH. Those requests must be filed with Division of International Services (DIS) directly and include all the documents necessary as outlined on the DIS website. The request should be submitted 6-months, but no later than 3-months, from the program end date to the DIS.
• IRTA/CRTAs who are already on an exceptional terminal 6^th year at NIH may be considered to receive a further extension up to a full 7^th year. This may be granted by the IC Scientific Director with no further delegations. The 2-year no remain/no return condition remains, but it is pushed to after the new NTE date. Requests for truly exceptional situations beyond a 7^th year as a non-FTE (such as for a K99 recipient or change in employment start date as a result of the current situation) may be sent in a memo from the IRP-responsible PI and approved by the SD. The memo should be sent to Dr. Arlyn Garcia-Perez who will consult the DDIR and OITE as necessary for a final decision.
• Visiting Fellows who are already on an exceptional terminal 6^th year at NIH may be considered to receive a further extension up to a full 7^th year (provided the individual’s immigration situation allows). The 2-year no remain/no return condition remains, but it is pushed to after the new NTE date. These exceptional extensions continue to require approval by DIS and OIR. Requests for truly exceptional situations beyond a 7^th year as a non-FTE (such as for a K99 recipient) may be sent in a memo from the IRP-responsible PI, approved by the SD, to DIS with other required documents as outlined on the DIS website. The request should be submitted 6-months, but no later than 3-months, from the program end date to the DIS.
• For postdoctoral fellows now on their 3^rd year or less at NIH, the pandemic impact on their research timeline will be taken into consideration when the time comes (at the end of their 4^th year or in their 5^th year), for a terminal up to 6-month extension without incurring the 2-year no remain/no return condition. This exception will be on a case-by-case basis and will need to be endorsed by the Scientific Director and evaluated for approval by OIR for IRTA/CRTA and by DIS and OIR for VFs. For VFs that require the terminal up to 6-month extension in the G-7 program, the request should be submitted 6-months, but no later than 3-months, from the program end date to the DIS.
• During the pandemic and some recovery period, a waiver of the 2-year no remain/no return condition (incurred by IRTAs/CRTAs who have received >6 months beyond their 5^th year as a non-FTE postdoctoral fellow) may be granted by OIR only for individuals for whom the IC has an FTE position (Research Fellow and above). The waiver request should be a memo from the IRP responsible PI, approved by the SD, and sent to Dr. Arlyn Garcia-Perez. The same consideration will be granted to VFs provided their immigration situation allows. For these VFs, the waiver request should be sent in a memo from the IRP responsible PI, approved by the SD, to DIS with other required documents as outlined on the DIS website. The waiver request must be submitted 8-months in advance of program end date or as far in advance as possible to avoid or limit a potential pay gap.