UMB Policy on Participant Support Costs
3702 (E) | Financial Affairs | Approved August 9, 2024
Responsible VP/AVP: Dawn M. Rhodes, DBA, MBA
Applies to: Faculty, Staff, Students
Purpose
The purpose of this policy is to ensure that funding for Participant Support Costs (PSC) is accounted for properly in UMB’s financial system and expended for the intended objectives in compliance with sponsor requirements.
Policy Statement
Some extramural sponsors of research projects include a category in their budget forms called participant support costs, which encompass costs for participants or trainees (but not employees) in connection with relevant conferences, meetings, symposia, training activities, and workshops. Costs associated with an individual’s participation in these activities may be allowable under the sponsoring agency’s program guidelines as participant support costs.
Participant support is provided by a number of federal agencies and other sponsors; however, the National Science Foundation has the most restrictive policies governing the budgeting, expending, and reporting of these funds. The departments must review guidelines carefully to determine whether participant support costs can be included in the project budget as direct costs and whether F&A costs can be recovered. Whenever participant support costs are proposed in a budget, a detailed justification will be required that describes the purpose for the costs and the way in which they will directly benefit the proposed project’s scope of work.
Participants may include students, visiting scholars, scientists, or workshop attendees. UMB employees should not be paid as participants.
Typical Participant Support Costs may include:
• Registration fees
• Manuals and Supplies
• Per Diem
• Stipends
• Tuition
• Travel allowances/meals
Participant Support Costs are not:
• Honoraria for Guest Speakers
• Expenses for the project staff to travel to a conference
• Expenses for the Principal Investigator to attend a seminar
• Payments made to research subjects as an incentive for recruitment or participation in a
research project
Expenses that are reimbursed to or paid on behalf of participants must be specifically allowed by the sponsor and must be incurred within the project period. Participant support costs are listed as a separate category on the project budget.
2 CFR Part 200 {Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards} (“Uniform Guidance”) provides that participant support costs are allowable with prior approval from the Federal awarding agency. It also explicitly excludes participant support costs from the Modified Total Direct Costs (MTDC) base, and details rebudgeting requirements.
Prior Approval
Grant recipients must request prior approval to:
- Incur PSC if not already budgeted in the approved award.
- Transfer participant support budget to other categories of non-participant support expense.
- Any other situation specified by the sponsor.
In most cases, unspent participant support costs must be returned to the sponsor. Individual agencies may have more restrictive policies related to Participant Support costs. Therefore, all staff administering sponsored awards with participant support costs should be cognizant of the sponsor’s guidelines and award terms for specific requirements.
Exclusion from the MTDC base
Federal agencies do not allow participant support costs to be included as direct costs for the calculation of F&A cost recovery for a sponsored program. Therefore, a separate child account must be set up to track the participant support costs with a “0%” F&A rate.
Rebudgeting Requirements
2 CFR §200.308(c)(5) states prior approval is required to transfer funds budgeted for participant support costs to another expense category. If rebudgeting of PSC is needed, prior approval is required depending on the action that needs to be taken.
Definitions
Participant Support Costs: 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 awards.
Child Account:
UMB uses child projects to allocate funding across multiple projects. The reasons for child accounts include but are not limited to project department or PI different than award attributes, tasks that need to be tracked separately for internal or external needs, or different rates of F&A on different funding within an award.
Scope and Exceptions
Participant support costs are typically incurred for projects that include an education or outreach component. Participant support costs are allowable with prior sponsor approval, per the Uniform Guidance.
For costs to be classified as participant support costs, they must support the participant’s engagement in the activity. The project may incur costs that are allowable on the award, but do not qualify as participant support costs; these costs should be budgeted and expensed on accounts bearing full F&A.
Roles and Responsibilities
Schools/Departments Administration:
- Request a child account for participant support costs.
- Ensure allowable participant support costs are correctly coded to the appropriate award and
project ID. - Follow proper channels to request approval for any rebudgeting of participant support costs.
SPAC Team:
- Establish an award in the financial system to capture costs when a federal award is received
with a budget category of participant supports costs. - Establish the child account requested by the department for participant support costs.