Written by Tricia Callahan
THEN & NOW
There has always been a fair amount of ambiguity regarding what constitutes participant support costs. Until addressed in Uniform Guidance (specifically in 2 CFR 200.75), the National Science Foundation (NSF) had the most restrictive policy governing budgeting, expending, and reporting of these funds. Then, and now, participant support is intended to be used for direct costs paid to or on behalf of participants in connection with Federally-funded workshops, conferences, meetings, symposia, or training projects.
NEW POLICIES, CLEARER DEFINITIONS
According to 2 CFR 200.75, participant support costs are direct costs for items such as stipends, subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (not employees) in connection with conferences or training projects. Probably the best distinction for determining what constitutes participant support, is what is not considered participant support: payments to employees, payments for conference speakers, incentive payments to human subjects, and costs for room rental fees, catering, supplies, etc. related to a sponsored conference or training project.
AWARDS WITH PARTICIPANT SUPPORT
Types of projects that might request participant support costs include:
- Project with a participant portion, like a summer workshop
- Awards for sponsored conferences, workshops, symposia or training projects
- NSF Research Experiences for Undergraduates (REU) where the primary intent of the program is to provide an educational experience for the student
Like all costs in a budget, it is important to properly categorize costs at the proposal stage. Costs awarded as participant support are restricted and may not be allocated to other budget categories without prior written approval of the sponsoring agency. Additionally, participant support costs are excluded from calculating indirect costs when using a Modified Total Direct Costs (MTDC) base, so mis-budgeting or re-budgeting these costs have a direct impact on indirect cost recovery.
Colorado State University’s current guidance on participant support costs mirrors that of the NSF. To appropriately track and manage participant support activity, a separate child “53” account is created and coded to not incur indirect (aka, F&A) costs. Budget in these accounts are restricted and may not be reallocated to other budget categories without prior written consent of the sponsoring agency. Unexpended balances left in a participant support account at the end of a project become de-obligated and cannot be used to offset expenses in the parent or other related child accounts.
RESOURCES AND REMINDERS
Still uncertain about participant support? Check out the NSF guidance decision tree regarding these costs:
Remember that the information shared above is specific to NSF and to processes at the University of Texas-Dallas. These resources are meant to be guides as there are a number of agencies who have a broader interpretation of what should, and should not, be counted as participant support.
As with all Federal programs, Uniform Guidance (UG) is guidance to the Federal-granting agencies. How each agency/program chooses to interpret and apply UG may vary. Check your agency rules, program guidelines, and institutional policies and follow the order of precedence when making a determination.
Post written by Tricia Callahan, Senior Research Education & Information Officer, Office of Sponsored Programs, Colorado State University