Some contract and grant sponsors include a budget category called "participant support costs" which are defined as 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 meetings, conferences, symposia, or training projects. These costs are allowable with the prior approval of the awarding agency.
Participant support costs are defined in the Uniform Guidance as 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 (except NIH Kirschstein-NRSA programs). Participant support costs do not include expenses incurred to incent or enable research subjects to participate in studies, such as gift cards, stipends, dependent care costs, parking fees and transportation.
Note that participant support costs are not routinely allowed on research projects. Typically, these expenses are incurred for projects that include an education or outreach component. The funding opportunity announcement (FOA) will indicate when these expenses are allowable as direct costs to the project.
The Uniform Guidance redefined the Modified Total Direct Cost (MTDC) base to exclude participant support costs from Indirect Cost Recovery (ICR). This applies to all Federal and Federal Flow-Through sponsored projects awarded on or after December 26, 2014.
Who is a Participant?
A participant is an individual who is receiving a service or training opportunity from a workshop, conference, seminar, symposium or other short-term instructional or information sharing activity funded by a sponsored award. A participant may be a UC Santa Barbara student/scholar, a student/scholar from another institution, a private sector company representative, a K-12 teacher, or a state or local government agency personnel. A participant may not be a UC Santa Barbara employee. Employees from other UC campuses are eligible if they do not have a role in organizing the event or forwarding the project’s aims.
A participant may be a U.S. citizen, permanent resident, or foreign national. The participant must have a Social Security Number or an Individual Taxpayer Identification Number (ITIN).
A participant is not:
- An employee of UC Santa Barbara
- A student or project staff member receiving compensation directly or indirectly from the grant
- A research subject receiving incentive payments
- A recipient of any compensation from any other federal government source while participating in the project (applies only to federal grants)
A participant does not perform work or services for the project or program other than for their own benefit. The participant is not required to deliver anything or provide any service to the university in return for these support costs.
What are Participant Support Costs?
Participant support costs are direct costs for items such as participant allowance, supplies, per diem, travel expenses, and/or registration fees paid to or on behalf of a participant in connection with a meeting, workshop, conference, symposium or training project conducted under the award. Amounts must be reasonable, based on type and duration of the activity, and outlined in the program solicitation.
Participant support costs may include the following expenses:
- Event registration fees
- Stipend (predetermined amount regardless of actual costs) for housing and subsistence allowance
- Travel costs when the sole purpose of the trip is to participate in the project activity
- Event support costs for lodging and food expenses paid directly to the event facility, only if the payment is made on behalf of, or reimbursed directly to, the participant
- Meals and incidentals when on travel status
- Training materials
All costs that are reimbursed or paid on behalf of the participant must be incurred within the project period and be specifically allowed by the sponsoring agency. Participant support costs are budgeted in a separate line and must be accounted for separately. Funds provided for participant support costs that are not spent cannot be rebudgeted for use in other categories except with the prior written approval of the sponsor. In most cases, unspent participant support funds must be returned to the sponsor.
The following expenses, except when specifically allowed by the award, should not be processed as participant support costs:
- Travel for project PI or staff
- Multi-purpose travel (i.e., to perform research in addition to attending a project related meeting)
- Travel for a consultant who is providing service to the university
- Event support cost (i.e., facility rentals, media equipment rentals, food/refreshments)
- Entertainment/food for non-participants
- Honoraria paid to a guest speaker or lecturer
- Incentive payment to encourage an individual to participate as a research subject
- Subaward to a provider for multiple training events (i.e., an ongoing contract with specific terms and conditions)
- Payments to a participant’s employer for reimburse for the costs related to sending the employee to the project event
- Expenses related to meetings of an administrative nature
Food and Meals for Participants (NSF)
NSF allows for a subsistence allowance or per diem to be paid to Participants to use for meals as Participant Support.
Thus, if a meal is provided to a Participant at the conference or training, it can be provided as Participant Support as long as:
- The per person cost of the meal is less than the Per Diem meal allocation for the meal and location; and
- The Participant is not also receiving a Per Diem allowance OR the amount of the Per Diem allowance is reduced by the meal allocation.
Costs for meals for non-Participants and the portion of the actual meal cost that exceeds the per diem for the Participant(s) is not allowed as Participant Support on NSF Awards. Only the cost of meals for Participants up to the per diem amount are allowable as Participant Support.
For example, the per diem allocation for lunch is $18. There are 10 Participants and two UCSB staff attending a conference. The actual cost for lunch is $20 per person, so the total lunch cost is 12 people x $20 = $240. Of the total cost, only $180 (10 Participants x $18) can be charged to Participant Support.
Most federal sponsors restrict rebudgeting of participant support costs.
Participant Support funds are restricted and require approval of the cognizant NSF program officer to reallocate funds out of the Participant Support sub budget.
Rebudgeting costs into Participant Support does not require NSF approval unless funds are moving into the “other” category of participant support.
Generally, recipients may not rebudget funds from Participant Support to other categories without prior written approval of the sponsor. However, this is not the case for all sponsors. As always, read your award document, along with any applicable terms and conditions or agency specific regulations, for guidance on rebudgeting Participant Support funds.
Documentation must be retained when managing participant support costs and may vary based on scope of work or revisions to the award (prior approval or rebudget requests).
Programmatic documentation should include:
- Sign-in sheets for participant attendance at workshops
- Documentation on supplies that are ordered or distributed to participants and how they support the participant in the project activity
- List of participants the materials are for
- Support for allocating costs as “other” or “fees”
Programmatic documentation should be retained in the award’s administering department.