In general, participant support funding is provided to enable and encourage individuals to attend conferences or training programs without undo financial burden. Participant support costs (PSC) are those costs paid to (or on behalf of) participants or trainees (not employees) for participation in meetings, conferences, symposia, and workshops or other training activities. They can include fellowships, scholarships, and other forms of student financial aid. These activities are not intended to benefit the university or contribute to any research outcome and should only benefit the participant.
A participant is defined as a non-employee who is the recipient, not the provider, of a service or training associated with a workshop, conference, seminar, symposium, or other short-term instructional or information sharing activity. Participants are not required to provide any deliverable, other than meeting the program requirements (e.g. attendance, testing, etc.).
Examples of a participant:
Examples of what a participant is not:
Participant support can be categorized by three types. Each award clearly defines the type of support and the specific requirement for each award.
Participant support costs for a project may include registration fees for the event, transportation to/from and lodging during the event, stipend, as well as a per diem allowance to cover meals and incidental expenses.
Participant support costs do not include the following types of expenses:
If your area of concern is not addressed in this FAQ, please reach out to your area accountant to discuss further.
*Project staff include those individuals who are listed in the Senior/Key Person or Other Personnel sections of the project budget. These individuals generally have an employment relationship with the university and are engaged in accomplishing the project’s scope of work or deliverables.
Federal regulations state that participant support must be kept in a separate account and tracked for better internal controls.
There are no restrictions on transferring funds to a participant project from an existing non-participant project within the same award. However, transferring funds from a participant project to a non-participant project within the same award requires prior sponsor approval. If an award does not already include a participant project, then adding a participant component to the award would also require the sponsor’s prior approval.
It should be noted that any participant support funds moved into a non-participant project will then have F&A applied as appropriate.
Can I rebudget funds within the different participant support cost categories?
Generally speaking, rebudgeting within different participant support cost categories is allowable. An exception would be if the intent were to rebudget funds into the “Other” category. That action may need agency prior approval given that NSF closely scrutinizes costs in the “Other” category. Please contact your Grant Accountant with questions in this scenario.
How would I make a prior approval request?
Please work with your respective OCG officer to submit a prior approval request to the sponsor. Instructions and more information can be found on OCG's Subaward and Participant Support Reallocation page.
Like 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.
No. Participant support costs are exempt from F&A in federally sponsored projects as stated by the Uniform Guidance. For Non-Federal awards, specific guidelines within each award should be utilized to determine if F&A is allowable on the participant support costs. For any award made under Uniform Guidance, participant support costs (similar to equipment) should be excluded from the base used to calculate F&A costs.
In general, only stipends may be charged to a participant support project. Stipends denote participant is not an employee of the university.
With every participant support project, the list of participants must be provided within the documentation of the fiscal files in Research Financial Services. This allows retention of documentation that is often requested by the sponsoring agency for audit purposes.
No, the participant support category is for the support of participants or trainees only. Speakers and trainers are not considered participants and should not be included in this section of the budget.
Yes. While NSF does provide rebudgeting authority for many categories, you must receive the approval of the cognizant NSF program officer to reallocate funds out of the participant support category. You may, however, rebudget funds into this category without prior NSF approval.
A student cannot be compensated partially as an employee and as a participant. It is up to the proposing organization to determine whether they should be a student employee or a participant based on the role of the student in the project. Student employees are compensated for services rendered and their level of compensation is tied to the number of hours worked. Participant support costs should be used to defray the costs of students participating in a conference or training activity related to the project.
No, the participant support cost line in the NSF budget should not be used for such costs.
Participants from the submitting institution and other institution(s) could be considered participants.
No, the participant support cost section of the budget may not be used to provide incentive payments to research subjects. Human subject payments should be included on line G6 of the NSF budget under “Other Direct Costs”, and indirect costs should be calculated on the payments in accordance with the organization’s federally negotiated indirect cost rate.
A Research Experience for Undergraduates (REU) program is aimed at developing the students’ research skills and providing a high-quality mentoring experience. Based on this role, an REU student is considered a participant in a training activity, and funds for their support should be included as a stipend in the participant support cost section of the budget. The goal is to provide a practical educational experience for the undergrad student, rather than simply a job. Below are two resources that further explain the REU guidelines:
Similar to other award-related expenses, a department must maintain back-up documentation for all participant support costs. In addition to a list of participants, evidence of attendance of these participants, such as an agenda or similar documentation should be kept on file.
The participant cannot be an employee of the university.
If travel of participants is budgeted for, and sole purpose of the trip is to participate in the project activity, the travel expenses may be paid for directly or as a reimbursement made to the individual.
No. The account under which an award cost is budgeted is the account that should be charged. Participant support costs should not generate F&A, while the main project often does.
A stipend for an undergraduate student, paid with a PA, would be charged to account code 495302.
Catering is not a permissible participant support cost. Cost of meals, however, if expenses are for participants, in place of a meal per diem, are eligible participant support costs. These costs must be budgeted or have prior sponsor approval.
Catering: Food costs related to an NSF-sponsored conference. A vendor is secured through a service agreement/contract and provides food service for university sponsored projects on property owned or leased by the university, is both licensed and insured, and prepares, transports, set outs and/or serves the food. Catering should be budgeted on line G.6., “Other Direct Costs” to ensure appropriate allocation of indirect costs.
Meal: Purchased food, such as pre-packaged box lunches, sandwiches, cheese trays, pizza, cookies, fruit, etc. Only the participant’s portion of the meal is allowable.
Fellowship or stipend payments can be paid through the payroll system, but since these payments are not made because of an employment relationship, payments to recipients who are U.S. citizens and resident aliens are not subject to federal and state income tax withholding and payroll taxes (i.e., FICA and Medicare taxes). The university has no tax reporting requirement for these payments, although recipients should be aware that these payments may be taxable income. The interpretation and implementation of the tax laws are the domain of the IRS and the courts.
Nonresident alien recipients of fellowship or stipend payments are subject to federal tax withholding, and the university is required to report the information annually to the recipient and the Internal Revenue Service (IRS) on federal Form 1042-S.
A major deviation to the budget should be sent to OCG. They will send your request to the sponsor.