Clarification on Classification of Researchers

1. Clarification on Classification of Researchers • In the past, Dartmouth has occasionally classified certain post-doctoral fellows as “research fellows” or “training fellows”, resulting in their being paid with a set stipend, considered non-employees of the College (and thus ineligible for most of the College’s regular employee benefits plans), and also not subject to FICA withholding. This practice was consistent with what was then known about Federal law regarding the topic. • On October 30, 2009, the Office of Chief Counsel of the Internal Revenue Service issued Memorandum No. 200944207, which addressed certain questions raised by an unnamed state university. The factual situation set forth in that Memorandum closely paralleled the treatment that Dartmouth has been according some of its post-docs, as noted above. Following a lengthy analysis, the IRS concluded that post-doctoral fellows who are supported by National Research Service Awards (NRSA) grants are not university employees and thus not subject to FICA; however, all other grant-supported post-doc fellows are employees, and should be treated as such. http://www.us.kpmg.com/microsite/taxnewsflash/Exempt/2009/CCA200944027.pdf Dartmouth College Payroll, November 10, 2010

2. Researcher Classifications Dartmouth College Payroll, November 10, 2010