Postdoctoral Fellows (IRTA/CRTA/VF) Temporary Exceptional Extensions Policy

Current Policy Effective as of August 1, 2022

The NIH IRP recognizes the impact of the pandemic on the scientific progress and career progression of IRTA/CRTA and Visiting Fellow Postdocs. The NIH IRP is committed to encouraging trainees to transition to the next stage of their career as quickly as possible, preferably within the five-year limit that is currently in place. However, the NIH IRP understands the hardships for trainees during the pandemic and would like to protect our trainees and their careers, particularly for those trainees influenced by space-limitations in the research groups, those who lost time due to family-responsibilities, and other reasons outside of their control.

Therefore, during these extraordinary times, the NIH IRP has TEMPORARILY modified the exceptional extension policy to reflect the additional time in our research groups that some trainees will need. This policy will be re-evaluated in June 2024.

Trainees and Principal Investigators should not expect an automatic extension, all extensions must be justified and approved. To reflect the critical need to start the job search process early, the following guidance requires a full-year process. The minimum timeline for these approvals is 9-months, and we recommend starting this paperwork as soon as possible after starting a 5^th year.

Update November 2022: The written justification memo only needs to be prepared once and trainees can ask for a 6^th and 7^th year (if desired) in this memo. The request memo must include a commitment of funds for the full extension period. Before the 7^th year renewal can be processed, the Administrative Officer (AO) will obtain written confirmation (email will suffice) that (1) the PI agrees to a 7^th year, (2) the trainee agrees to the 7^th year, and (3) the OITE has completed an annual progress check and concluded a 7^th year is acceptable from a progress standpoint and that the IC Training Director approves of a 7^th year. Both the AO and the OITE should track 7^th year check-ins. Foreign nationals are subject to visa regulations.

• During This Trial Period
  • Trainees currently in their 5^th year at NIH can request an extension past the 5^th year without incurring the "not remain or return to NIH for 2 years" condition for entering an exceptional 6^th or 7^th year at NIH. However, to remain or return to the NIH IRP before the 2 years elapse after the extended postdoctoral appointment ends, it must be on an FTE position (not contractor). Further, the 8-year rule continues to be in effect and any exceptions must be requested from OIR (c/o Dr. Arlyn Garcia-Perez, Director of Policy and Analysis).
    • Because of individual immigration histories, Visiting Fellows currently in their 5^th year can request an extension past the 5^th year, provided they are eligible based on their immigration status. Extensions of a Visiting Fellow award are dependent upon Division of International Services (DIS) approval per the process below.
    • Visiting Fellows: The NIH Policy for No-Objection Statement (NOS) Waivers, 2-Year Home Country Physical Presence Requirement (212e), remains in effect.

Process for IRTA/CRTAs and Visiting Fellows (VF)

• 9 Months Prior to End Date (IC Approval)
  • The trainee and PI must prepare a "Career Development Plan" memorandum that describes how the extension year will be used to complete work in-progress and to arrange for subsequent employment for the trainee. PIs and postdocs are strongly encouraged to discuss the extension request with IC training office staff and other career mentors (in the OITE or beyond) so that the plan clearly covers both the research and career development needs of the postdoc. The written justification memo must include: (1) a summary of the trainee’s progress, (2) projected timeline for completion, (3) specific dates of the fellowship renewal request, (4) description of work to be done, (5) description of a plan for subsequent employment, (6) reason for extension and how this extension will benefit the trainee and the NIH, (7) copy of the trainee’s CV, and (8) commitment of the PI to the plan to both the scientific and career goals of this trainee, (9) financial commitment to the trainee for the full extension period requested.
  • This plan should be submitted to the Scientific Director (SD) or their delegate for approval within the IC. The SD, or their delegate, will prepare a memo for OIR mentioning the ICs support of an extension for this trainee.
• 6 Months Prior to End Date (IRP/OITE, DIS approval- for VF)
  • IRTA/CRTAs: This SD-approved memo and Career Development Plan must then be sent from the responsible IRP PI to Dr. Arlyn Garcia-Perez, Director of Policy and Analysis, OIR, for her review (GarciaA@OD.NIH.GOV). Copy Dr. Lori Conlan (conlanlo@mail.nih.gov) in the Office of Intramural Training & Education (OITE) on this email. Once Dr. Garcia-Perez performs an initial review of the request, Dr. Conlan, or appropriate OITE staff, will interview the trainee as part of this approval process. OITE will provide a recommendation to Dr. Garcia-Perez and then she will issue her decision (on behalf of the DDIR) on the request.
  • Visiting Fellows: Visiting Fellows currently in their 5^th year can request an extension past the 5^th year provided they are eligible based on their immigration status. Those requests must be filed with DIS directly and include all the documents necessary as outlined on the DIS website. The request should be submitted no later than 6 months from the program end date to the DIS. Late requests will be considered on a case-by-case basis, but requests submitted to DIS less than 3 months from the program end date cannot be processed and will be rejected. DIS will obtain IRP and OITE approval as described in the above bullet for IRTA/CRTAs.

The NIH IRP will carefully document the number of trainees who ask for extensions and monitor their career outcomes. These data will be presented to the SDs followed by a discussion of policy changes as needed in June 2024.

Protection of Trainees

The NIH IRP strongly recommends that if a trainee will be offered an FTE position (Research Fellow (short-term per the 8-year rule), or long-term NIH career tracks such as Staff Scientist, Biologist, etc.) within the NIH IRP, that those trainees be moved into those pay mechanisms as soon as possible, forgoing this extension process. Ideally, an appointment as a Research Fellow, or staff scientist/staff clinician will happen at the end of the 5^th year as a non-FTE, but the NIH appreciates extenuating circumstances may arise.