Participant Support Costs - Policy & Procedure

1. Background Information

Participant support costs (PSC) are defined by the Uniform Guidance in §200.75:

Participant support costs means 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.

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 do not perform work or services for the project or program unless it is for their own benefit. Participants are not required to provide any deliverable to the University or third party, nor would they be disciplined or terminated for their failure to perform. 

Participants are not paid salaries or wages to provide any deliverable, other than meeting the program requirements (e.g. attendance, testing, etc.).

Participants may be, but are not limited to, students, scholars, scientists from other institutions, or teachers. Participant support is funding provided to help defray the costs to participants or trainees (but not employees) of participating in a conference or training activity.

See the solicitation and/or award document for award specific PSC requirements.

2. Purpose

The purpose of this policy is to comply with sponsor regulations and to ensure that funds provided for participant support costs are accounted for according to sponsor’s requirements and expended for appropriate and intended objectives.

3. Procedures 

3.1. Budgeting for Participant Support Costs

Participant support costs are listed as a separate category within the proposal budget. Participant support costs that are proposed in a budget require detailed justification that describes the purpose for the costs and the way in which they directly benefit the proposed project’s scope of work. Re-budgeting unspent participant support funds into other categories requires prior written approval from the cognizant Program Officer. This should be done as soon as possible during the life of the Award. Any unspent funds are returned at Award Closeout and cannot be used to offset overages in other categories. You may, however, re-budget funds into this category without prior sponsor approval.

3.2. Identifying & Accounting for Participant Costs 

When an award provides funding for participant support, the Office of Contracts and Grants (OCG) and Research Financial Services (RFS) may establish a separately budgeted project number and SpeedType in the University’s PeopleSoft Finance System, based on the sponsors’ terms and conditions. The project Description attribute is entered as “Participant Costs for [insert project number]” to easily identify and isolate these projects. All awards must follow this process.

3.3. Facilities & Administration (F&A)

Participant support costs are exempt from F&A in federally sponsored projects as stated by the Uniform Guidance (§200.68). For Non-Federal awards, specific guidelines within each award should be utilized to determine if F&A is allowable on the Participant support costs. 

3.4. Subaward

If a subaward is issued where participant support has been budgeted, the PI/department must monitor sub awardee invoices to ensure that the participant support costs are being accounted for separately, and that these costs are allowable. Before a subaward is initiated prior approval is required if it was not included in the original proposal budget.

3.5. Monitoring the Project

The Principal Investigator and their respective department are responsible for appropriate spending and monitoring of the Project throughout the award lifecycle. At time of closeout, the Grant Accountant will review all expenditures, transactions, and source documents if necessary, to ensure the University is in compliance with federal regulations and the terms of the agreement. If questions or concerns arise, the Grant Accountant notifies the key contact of the Principal Investigator’s department for further evaluation and/or corrective action. When the project is complete or all funds have been expended, the Grant Accountant proceeds to close the project.

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