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Updated April 20, 2019
This guidance addresses fundamental concepts related to participant support costs and offers some examples. Please contact Post Awards with questions. Participant support costs are allowed by a number of Federal agencies and other sponsors. Participant support costs are defined by the Uniform Guidance in §200.75:
Participant support costs means direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects.
Participant support costs are typically incurred for projects that include an education or outreach component. These types of costs are most commonly included in National Science Foundation (NSF) grants, such as the Research Experience for Undergraduates (REU) or Research Experiences for Teachers (RET) program. NIH indicates that participant support costs are allowable only if specified in the Funding Opportunity Announcement.
Funds provided for participant support costs that are not spent cannot be rebudgeted for use in other categories unless prior written approval has been obtained from the sponsor.
Participant support costs are budgeted in a separate category in the application budget and must be accounted for separately. Participant support costs are excluded from the MTDC base when calculating F&A costs. A separate object code under the award to isolate participant support costs and to ensure that F&A is not applied against these costs is used.
Participant support costs are costs to support individuals who are receiving a training opportunity as part of a workshop, conference, seminar, symposium or other short-term instructional or information sharing activity funded by a sponsored award. Costs may include stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants (not employees). Also see #3 and #4 below.
A participant does not perform work or service for the project or program. The participant is not required to deliver anything or provide any service to the university in return for these support costs.
Projects with an educational or outreach component may include participant support costs. For example, a project may be in support of professional development and continuing education activities for secondary school teachers/educational professionals. Participant support costs for this project may include registration fees for the event, transportation to/from and lodging during the event, as well as a per diem allowance to cover meals and incidental expenses.
Participant support costs do NOT include the following types of payments:
cover the costs to travel to and attend the workshop. Travel costs, as well as lodging/meals during the event, would be considered participant support costs.
Some examples that would not be considered participant support costs:
Participant support costs are allowable with prior sponsor approval, per the Uniform Guidance. In addition, individual agencies may have specific policies restricting the use and allowability of participant support costs. NSF has historically allowed participant support costs, for instance, in the REU and RET programs. NIH only allows participant support costs if they are explicitly identified in the Funding Opportunity Announcement. Other Federal and non-Federal sponsors may allow participant support costs under some circumstances. Review the funding solicitation for specific instructions and contact Office of Sponsored Programs (OSP) with any questions prior to proposal submission.
Yes, participant support costs must be explicitly identified in the budget and budget justification. For instance, the NSF budget form has a section specifically for participant support costs. If the budget form you are using does not have such a section, but you plan to include participant support costs, please explicitly identify any participant support costs in the budget and budget justification. Participant support costs are excluded from the MTDC base when calculating F&A costs. Identifying participant support costs will help ensure prior sponsor approval is requested and, if awarded, that Post Awards sets up a separate object code with appropriate F&A.
Maybe. Generally, it is not allowable to rebudget from the participant support costs category into other budget categories unless prior written approval has been obtained from the sponsor. If approval is obtained from the sponsor and funds are moved from participant support costs into other budget categories, F&A costs will be applied to the rebudgeted funds as appropriate.
Maybe. Adding a participant support component to the project will need prior approval from the sponsor.
With the sponsor’s approval, one option to fund this new component would be to rebudget unused funds into participant support costs. OSP can assist with submitting a prior approval request to rebudget funds for this purpose. The other option would be for the PI to request a supplement for participant support costs. A supplemental proposal would need to be submitted.
If approval were obtained for participant support costs, Post Awards would set up a new object code under the award in order to separately account for these costs and apply a 0% F&A rate as required by the Uniform Guidance.
Similar to other award-related expenses, a department must maintain back-up documentation for all participant support costs. This would include a list of program participants and evidence of attendance of participants, such as a daily log or similar documentation. Maintain official agendas held for all meetings and conferences. The department should maintain official agreements/contacts with speakers and presenters of meeting and conferences. Flyers and advertising materials for meetings and conferences should reference the appropriate awarding agency. For example: NSF as the sponsor for the S-STEM.
Yes. Previously, in A-21, the definition of Modified Total Direct Costs (MTDC) did not address participant support costs. In the Uniform Guidance, the definition of MTDC addresses participant support costs. This means, for awards from any agency that are made under the Uniform Guidance, participant support costs (similar to equipment) should be excluded from the base used to calculate F&A costs.
Stipend payments to participants should be made on a Departmental Scholarship and Stipend Award Form. The account code used will be either 5811 or 5831, depending on whether the payment is a stipend or other student award.
No. A payment to an individual who agrees to participate as a human subject in a research project is not a participant support cost and should be budgeted as Other Direct Costs in the project proposal.
The answer depends on the sponsor. Generally, costs for training grant programs are not considered participant support costs. Training grant programs are not typically short-term experiences and are not consistent with the types of experiences considered to be participant support activities. Trainees are also actively engaged in the scope of work, where participants do not perform work or service for the project or program.
It depends. If Gallaudet University has determined that student hourly employee is the appropriate role, then a compelling justification should be sent to the sponsoring agency representative about why that determination was made. Guidance from the National Science Foundation is that the institution determines whether a student hourly employee or participant is appropriate for the project.
However, for the NSF REU program, any student involved would be considered a participant. The NSF REU program is intended to provide a practical educational experience for undergraduate students, to develop their research skills while being mentored. Given the goals of the NSF REU program, it is not possible to have both student hourly employees and participants – all students on an NSF REU project should be considered participants.
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