External Students on Federal Awards

Compliance Guidance

When a PI wishes to engage a student enrolled at another institution to work on a federally funded project at New York Tech, several compliance requirements must be met. This guidance provides a step-by-step reference for faculty and researchers and aligns with New York Tech’s External Student Engagement Agreement.

Engaging External Student Workers

  • External students are not hired as New York Tech employees through payroll.
  • Engagement may occur through:
    • A direct student engagement agreement (short-term, supervised project work).
    • A subaward to the student’s home institution if the contribution is substantial and ongoing.
  • Independent contractor classification should be used only in rare cases where the student provides specialized, self-directed services outside the scope of research training.

  • Costs must be reasonable, allocable, and allowable under sponsor rules and Uniform Guidance (2 CFR 200).
  • The student’s work must directly benefit the sponsored project.
  • No voluntary cost-sharing should be expected of the student.

  • Ensure the student is not receiving double compensation on federal projects.
  • Confirm whether the student’s home institution requires notification or approval.
  • For significant contributions, a subaward may be the appropriate mechanism.

  • Responsible Conduct of Research (RCR) Training: Required for NSF, NIH, and USDA student participants.
  • Financial Conflict of Interest (FCOI) Disclosure: Required if student is engaged in NSF or NIH projects.
  • IRB/IACUC training:  Required if the project involves human or animal subjects.
  • Export control compliance: Required if research involves restricted data or technologies.

PI is responsible for oversight, ensuring the student’s work aligns with the project scope and that documentation supports audit compliance. The PI must maintain: 

  • Engagement agreement or subaward documents.
  • Job/contract description or scope of work.
  • Timesheets (if hourly) or deliverables (if stipend).
  • RCR/FCOI/IRB/IACUC training certifications.
  • Any home institution approvals.

Questions?

Contact the Office of Sponsored Programs and Research (OSPAR) at grants@nyit.edu before proceeding with any external student engagement on federally funded projects.