Participant Support Cost Overview
According to OMB's Uniform Guidance (Sections 200.68, 200.75, 200.308 and 200.456):
Participant support costs (also known as training allowances) 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 grants.
Participant support costs are allowed universally across all agencies if:
- They are programmatically justified;
- Such costs are explicitly included in the budget and the budget is approved or if prior written approval is received from the Federal awarding agency; and
- The costs are specifically excluded from the MTDC and indirect costs may not be applied to participant support costs for federal projects.
Additionally, the National Science Foundation Proposal & Award Policies & Procedures Guide stipulates:
- Funds provided for participant support may not be used by grantees for other categories of expense without the specific written approval of the cognizant NSF Program Officer. Therefore, awardee organizations must account for participant support costs separately. Consequently, participant support costs should only be used to pay program participants small non-compensatory stipends. Participants are not required to provide deliverables to CUNY and the RF, nor are they disciplined or terminated for their failure to perform.
- Participant support allowances may not be paid to trainees who are receiving compensation, either directly or indirectly from, other Federal government sources while participating in the project. A non-NSF Federal employee may receive participant support allowances from grant funds provided there is no duplication of funding of items and provided no single item of participant cost is divided between his/her parent agency and NSF grant funds.
Consequently, participant support costs should only be used to pay program participants small non-compensatory stipends. Participants are not required to provide deliverables to CUNY and the RF, nor are they disciplined or terminated for their failure to perform.
Participants may include students, national scholars, and scientists, private sector representatives, agency personnel, teachers, and others who attend and participate in the conference, workshop, or training activity. Unless specifically provided for in the award, CUNY/RFCUNY employees may not be participants and are not eligible for participant support.
Participant support costs are:
- Typically identified with NSF awards.
- Awarded by other sponsors (but not necessarily referred to as "participant support costs").
- Accounted for in restricted account (object) codes.
- Excluded from the calculation of facilities and administrative (F&A) costs.
- Not allowed to be re-budgeted from the participant support cost category into other categories without prior sponsor approval.
Participant support costs do not include:
- Honoraria paid to a guest speaker or lecturer.
- Payments made to research subjects as an incentive for recruitment and participation in a research project.
- Conference support costs such as facility rentals, media equipment rentals, or conference food.
- Reimbursements to employers for costs related to sending its employees to a conference or workshop.
- Costs of CUNY/RFCUNY project staff to travel to a conference.
- Costs of bringing collaborators together in one location to work on a project.
- Costs of the principal investigator (PI) to attend a seminar.
- Payments to individuals providing a service for the project.
- Any unexpended participant support costs must be returned to NSF.
To comply with federal regulations, funds provided for participant costs must be separately accounted for as restricted other than personnel service expenditures.
- Review award documents at set up, looking for wording similar to "participant support" or "participant costs awarded" to determine if this issue is applicable to your grant. Although many sponsors are willing to fund stipends, it is important, however, to distinguish individuals who are providing service from individuals who are being paid without any expectation of work. CUNY/RF employment policies prevail over non-federal sponsor expectations. An individual who is being paid for the services he/she provides to the PI should be considered an employee.
- Where participant support costs are allowed include a detailed budget justification describing the purpose of the costs and how they will directly benefit the project.
- Exclude F&A costs on participant support cost expenditures.
- Participant support costs should be identified within the award as an OTPS expenditure. NSF will identify such funds specifically as participant support costs. Other agencies may use another cost category such as stipend.
- Grants & Contracts will establish the appropriate account (object) code based on the project's approved budget.
- Participant support costs cannot be re-budgeted into other categories without prior written sponsor approval.
- Any unexpended participant support costs must be returned to the sponsor.
Distribution logs should be used when supplies, food, transit cards, gift cards or other items of value are distributed or provided to participants (or employees). They should also be utilized to document participant (or employee) attendance to certain events such as, but not limited to, cultural and entertainment activities. Distribution logs are to be submitted to RFCUNY along with invoices to support the procurement and appropriate distribution of items to participants.
The PI is required to be familiar with the specific requirements set forth by the sponsor and is expected to insure that funds are being spent according to these requirements. In addition to the financial restrictions noted in the previous sections, the PI is required to retain:
- Copies of applications of selected participants, with documentation detailing how participants met the selection criteria.
- A complete list of program participants and documentation including dates/times of their participation in the program.