Participant Support Costs

Participant Support Costs Guidance

This guidance applies to federal funding and individuals that are in the role of receiving instruction or training from a federal award.

Definition

Participant Support Costs (PSC) as defined are 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. (2 CFR §200.75)

• Participant support costs are allowable with prior approval from the Federal awarding agency. (2 CFR §200.456)

• Participant support costs are excluded from modified total direct costs. (2 CFR §200.68)

• The transfer of funds budgeted for participant support costs to other budget categories requires the approval from the Federal awarding agency. (2 CFR §200.308)

Participant support costs are a restricted budget category frequently proposed on National Science Foundation (NSF) awards, however, participant support is provided by a number of other federal agencies and sponsors, as well. Other sponsors may vary slightly in their definitions and restrictions for participant support costs.

**Note that participant support costs do not apply to NIH training grants.

Roles and Responsibilities

Department/Managing Unit

Departments are responsible for developing proposals and managing awards in compliance with this guidance and the guidance provided by the sponsor regarding Participant Support Costs. This includes coordination with the PI and OSP. Departments assume the primary responsibility for posting relevant Participant Support Costs and retaining related documentation/records in accordance with the terms of the award and Brown University policies.

Principal Investigator (PI)

The Principal Investigator is responsible for working with their managing department to communicate the needs of the project and budget, and is ultimately responsible for the charges on the federal award.

The Office for Sponsored Projects (OSP)

Our central office is responsible for ensuring participant support costs are appropriately budgeted and if awarded (via initial request or revision), setting up a separate account in the Workday system, which will be excluded from F&A. OSP also services as a resource to the department and PI and submits prior approvals to the sponsor, if necessary.

Who can be a participant?

A participant is defined as a non-employee, who is the recipient, not the provider, of a service or training opportunity as part of a workshop, conference, seminar, symposium, or other short-term instructional or information sharing activity funded by a sponsored award. Participants are not required to provide any deliverable to the University, and they are not subject to human resources policies (e.g., they cannot be terminated for failure to perform).

Participants may be, but are not limited to, students, scholars, scientists from other institutions, or teachers.

A participant is not:

• An employee of the University;

• An intern, who while receiving training is also providing a service;

• A student or project staff member receiving compensation;

• A research subject/participant in a clinical trial, receiving incentive payments;

• Anyone who has a deliverable or is primarily providing a service to the research outlined in the project’s scope of work.

What types of sponsored projects may include participant support costs?

Participant support costs are typically incurred for projects that include an education or outreach component. Participant support costs are allowable with prior sponsor approval, per the Uniform Guidance. These types of costs are most commonly included in National Science Foundation (NSF) grants, such as the following programs:

• Research Experiences for Undergraduates (REU)

• Research Experiences for Teachers (RET)

• National Research Traineeship (NRT)

• Research Training Groups (RTG) in Mathematical Sciences

• Integrative Graduate Education and Research Traineeship Program (IGERT)

While NSF has historically allowed participant support costs, NIH only allows participant support costs if they are explicitly identified in the Funding Opportunity Announcement. Other Federal sponsors that may allow participant support include EPA, NASA, USDA NIFA or NRCS, NOAA, and others. Non-Federal sponsors may allow participant support costs under some circumstances. Review the funding solicitation for specific instructions and contact your pre-award contact in OSP with any questions prior to proposal submission.

Some examples of what might be considered participant support costs:

An NSF project has been awarded with an Research Experience for Undergraduates (REU) supplement. The REU supplement enables 4 undergraduate students to participant in a summer research project at Brown University. The students will be paid a stipend and provided room and board over an 8-week period. The students travel to Brown, stipends and room/board are considered participant support costs.
NSF provides an award to Brown University that includes a Research Experience for Teachers (RET) activity. The PI will host a teacher over the course of the summer who will gain research experience, and then use that knowledge to develop educational materials and activities. The teacher will pilot the activities with students and present the materials at regional conferences with fellow teachers. The teacher’s summer stipend, supplies for the activities, and travel to regional conferences would be considered participant support costs.
Brown University is awarded a grant from a Federal agency to host an education workshop in Chicago, IL. Individuals (the audience is primarily postdoctoral fellows from around the country) will apply for financial support to attend the conference. The financial support will cover the costs to travel to and attend the workshop. Travel reimbursement costs, lodging/per diem during the event, and registration fees would be considered participant support costs. However, the costs of hosting the event, such as room rental, AV equipment rental, or catering, would not be allowable as participant support costs and would need to be charged to the non-PSC account on the project.

What costs may be included as participant support costs?

Participant support costs include expenditures for items such as the following:

Stipend: A stipend is a set amount of money to be paid directly to the participant in connection with a short-term training activity. Note that short-term means the appointment period approved by the sponsor. The payment may be one-time or recurring payments. Individuals receiving stipends under participant support costs must be paid as a stipendee and not an employee.
Travel: Travel includes the costs of transportation and associated costs and must follow sponsor guidelines (e.g., US flag carrier, coach class, most direct route) as well as Brown University’s travel policies and guidelines. The sole purpose of the trip must be to participate in the project activity.
Subsistence Allowance: The cost of a participant’s housing and per diem expenses necessary for the individual to participate in the conference or training activity are generally allowed, provided these expenses are reasonable and limited to the days of attendance. This includes registration fees. Although they may participate in meals and snacks provided at the meeting or conference, participants who live in the local area are not entitled to subsistence payments.
Fees: The fees paid by or on behalf of a participant in connection with meetings, conferences, symposia, or training projects are generally allowable costs. Additionally, these fees may include laboratory fees, and passport or visa fees for foreign participants.
Other: Certain costs in support of the participant’s involvement may be allowable, including training materials, printing costs for presentation materials to be distributed at a conference, laboratory supplies and services that can be tied to specific participants. Check the funding announcement for additional guidance.

What costs cannot be included as participant support costs?

Costs for a guest speaker or lecturer, such as honoraria or travel
Costs for a consultant or trainer providing services to the sponsored project, such as fees or travel
Costs for PI or project staff, such as salary, wages, fringe, or travel
Conference/workshop support costs such as facility rental, catering, supplies, or media equipment rental
Costs for collaborators, such as travel
Human subject payments for participating in a research project. These types of costs should be on the primary project budget, not the participant support budget.

How should stipends be paid to participants?

Stipend payments to participants should be made according to the individual’s status as a Brown student or non-Brown student. The guidance below reflects typical payment protocol. Deviation from the following instructions may be necessary per the program solicitation or in extenuating circumstances. Please contact your OSP post-award accountant with questions.

For Activity Pay payments through UFunds, please contact Financial Operations within the Office of Financial Strategy and Planning (OFSP) by emailing Sarah Peri at [email protected]. Sarah and her team will assist in setting up the appropriate UFunds application for the department.

Brown Undergraduate Students

Payment via Activity Pay through UFunds

Posts to Ledger Account 65050: Other Undergraduate Aid and Undergraduate Fellowship (5360) spend category

Brown Graduate Student

Payment via Activity Pay through UFunds

Posts to Ledger Account 65350: Other Student Aid and Other Student Aid (5310) spend category

Non-Brown Undergraduate & Graduate Students

Teachers/Faculty (RETs)

Payment via Miscellaneous Payment (attach Visiting Researcher/Scholar Form)

Posts to Ledger Account 80000: Other Expenses and Visiting Researcher/Scholar (9665) spend category

Expense Allowability

For a direct cost to be charged to a sponsored award, the cost must comply with terms and conditions of the award, federal regulations, and Brown University Policy.

For participant support costs to be allowable:

The costs must be programmatically justified;
The costs must be explicitly included in the budget and the budget is approved or prior written approval is received from the Federal awarding agency; and
The expense does not take indirect costs.

For costs to be classified as participant support costs, they must support the participant’s engagement in the activity. The project may incur costs that are allowable on the award, but do not qualify as participant support costs; these costs should be budgeted and expensed on accounts bearing full overhead.

The “other” category under participant support costs must be specific and justified to be allowable. For NSF, costs included under this subcategory may be related to community building activities, lab supplies and services.

It is not appropriate for a person to be a participant on the project and perform work on the same project at the same time. Participants do not perform work or services. An individual cannot be classified as a participant and an employee in the same budget period. If the project spans years, it is possible that the participant’s role may evolve as the scope of work shifts in the later years of the project. If this happens, the change must be documented and justified. Example: An undergrad from another University may participate in a Summer REU program at Brown University on an NSF award. The following year they’re accepted to Brown’s graduate program and begin work on the same project.

Example of Budgeting for Participant Support Costs
Participant Support Project Budget	Primary Project Budget
Stipend	Faculty/Staff Salaries & Fringe
Travel – transportation, airfare & lodging	Room rental (for conferences)
Subsistence – per diem (housing/per diems)	Supplies
Other – (specific) Laboratory fees/Registration Fees	AV/Media Equipment rental (for conferences)
No F&A	Catering & Supplies (for conferences)
	F&A

Rebudgeting Participant Support Costs

Rebudgeting may be allowed, but in most cases requires prior approval from the sponsor. Rebudgeting requests should be processed during the life of the award.

Can I rebudget funds from my PSC grant account to a non-PSC grant account within the same award?

It is not allowable to move funds from the PSC grant account to a non-PSC grant account unless prior approval has been obtained from the sponsor. If approval is obtained and funds are moved from participant support costs into a non-PSC grant account, F&A costs will be applied to the rebudgeted funds, as appropriate.

Can I rebudget funds from a non-PSC grant account into a PSC grant account?

If a participant support project was approved as part of the original award, then funds can be rebudgeted from the non-PSC grant account in accordance with the terms and conditions of the award. If the award did not already include a participant support project, then adding a participant support component to the award would need the sponsor’s prior approval.

If participant support costs were not included in the original award, can I add a participant support component to my project.

Adding a participant support component to the project requires prior approval from the sponsor. With the sponsor’s approval, it may be possible to fund the new component by rebudgeting unused funds from the current project into participant support costs. Another option is to request a supplement for participant support costs. A supplemental proposal would need to be submitted, but first discussed with the program officer. If an approval for participant support costs were obtained, OSP would set up a new PSC child account under the award to separately account for these costs and apply a 0% F&A rate, as required by Uniform Guidance.

Can I rebudget funds within different participant support costs budget categories?

Rebudgeting within different participant support cost categories is allowable. There is an exception for NSF awards. If the intent were to rebudget funds into the ‘Other’ category, then that action may need NSF prior approval. Given that NSF closely scrutinizes costs in the ‘Other’ category, please contact your pre- and post-award OSP contacts with questions.

How do I make a prior approval request?

Please work with your OSP pre- and post-award contacts to determine sponsor requirements for submitting a prior approval request. Note that NSF prior approval requests must be initiated by the PI in Research.gov.

Importance of Documentation

Please note that some sponsors, such as NSF, will explicitly list Participant Support Costs in the notice of award budget. Other sponsors may not be as explicit. Therefore, it is crucial to maintain all communication and other documentation that would support the inclusion of PSC on the award. Procuring these documents and providing context in cases of audit or review is largely the responsibility of the department. Maintaining such documentation at the department level is important to compensate for portfolio changes and employee turnover.

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