Participant Support Costs Guidance
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 per code 2 CFR 200.75 as explained on the Code of Federal regulations website.
Participants are recipients, not providers, of a service or training associated with a sponsored workshop, conference, symposium, or other training activity. Participants (aka trainees) often include students, scholars, and individuals from the public or private sector such as teachers.
Unlike employees on a sponsored award, participants do not have an obligation to meet the scope of work or produce an outcome. Employees, trainers, conference speakers and organizers have an obligation to deliver, therefore the Grants and Contracts Administrator will budget under ‘Personnel’ or ‘Other’ and not under ‘Participant Support.’
Participant support costs should not include:
- payments to employees on the same award,
- payments for conference organizers, facilitators, and speakers,
- general collaborators including non-UMass Lowell (UML) co-PIs,
- incentive payments to human subjects,
- costs for room rental fees, catering, supplies, etc. related to a sponsored conference or training project.
Costs for participant support should be budgeted under the 'Participant Support' category and exempt from indirect costs.
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. When using a Modified Total Direct Costs (MTDC) base, participant support costs don’t incur indirect costs so mis-budgeting or re-budgeting these costs have a direct impact on indirect cost recovery.
To appropriately track and manage participant support activity, Financial Research Administration will create a separate account in PeopleSoft that will not incur indirect costs. Budgets in these accounts are restricted and may not be reallocated out of the separate account without prior written consent of the sponsoring agency. Unexpended balances in a participant support account at the end of a project become de-obligated and cannot offset expenses in the parent or other related project accounts.
Any rebudgeting from Participant Supports Costs to another budget category requires the approval of the Federal agency. Please use the re-budgeting tool on the Office of Research Administration website to initiate the request. For Non-Federal sponsors, please review award specific guidelines before rebudgeting Participant Support Costs.
National Science Foundation Research Experiences for Undergraduate Supplements
Investigators with an active National Science Foundation (NSF) research award may request supplemental funding to involve an undergraduate in an existing project under the Research Experiences for Undergraduate (REU) program. Because the program is funded by NSF as “Participant Support Costs” it is often recommended by NSF program managers as a cost-effective way to support students. The REU experience is a research training experience paid via a stipend, not employment (work) paid with a salary or wage. In this case, the student's training consists of closely mentored independent research. For administrative convenience, organizations may choose to issue payments to REU students using their normal payroll system.
However, not all student support is eligible for funding under this program.
- The REU student supported must be a U.S. Citizen, national, or Permanent Resident.
- The student must be an undergraduate student.
- The student cannot also be a UML employee.
Facilities and Administrative (F&A) Costs and Participant Support Costs
The Uniform Guidance states that Participant Support Costs are exempt from F&A on federally sponsored projects.
For Non-Federal awards, sponsor-specific and/or award-specific guidelines should be utilized to determine if F&A is allowable on the Participant Support Costs. If there is no sponsor‐specific or award‐specific guidance, then the full F&A rate for the award should be applied.
If a subaward is issued where participant support has been budgeted, the Principal Investigator (PI) must monitor sub awardee invoices to ensure that the Participant Support Costs are being accounted for separately, and that these costs are allowable and allocable.
Participant (Human Subject) Incentives
Participants incentives are payments to individuals to motivate them to participate in research or service. Investigators offer incentives to help improve subject recruitment and retention. Incentives may be in the form of a gift card, or in unusual circumstances, cash, as allowed by UML and the sponsor. Gift card incentives should not exceed $100 per incentive or $599 during a calendar year.
Costs for participant incentives (aka human subject incentive payments) are budgeted under ‘Other’ and should be included in the human subject protocol that is approved by UML’s Office of Research Integrity. Unlike participant support payments, participant incentives do incur indirect costs.
The table below shows a side-by-side comparison of participant support and incentive costs.
|Participant (Trainee) Support||Participant (Human Subject) Incentives|
|Award benefits the participant||Award motivates the participant|
|Primarily non-UML employees||May include UML employees and non-employees|
|No F&A incurred||Incurs F&A|
|Generally allowable with sponsor approval||Generally allowable with sponsor approval; incentives should be included in human subjects' protocol|
|Sponsor approval required to allocate funds||Sponsor approval may or may not be required to reallocate funds|
|Payments are taxable to the recipient||Payments may be taxable to recipient|
|Payments via student account or payment voucher (PV) via direct pay||Payments made in accordance with Declining Balance Bank Card|