Participant Support
OMB Uniform Guidance A-81 Part 200.75 defines participant support costs 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 UMES employees) in connection with meetings, conferences, symposia or training projects.
Participant support is distinguished from student support in that stipends for student support are for the objective of obtaining a degree, whereas participants are usually not students and, if they are, the non-compensatory stipend (for which no services are required) is not to support their degree-seeking enrollment.
The University of Maryland Eastern Shore (UMES) has the following guidelines for the use of participant support costs:
Definition of a Participant
A participant is defined as 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 may include students, scholars, and scientists from other institutions, individuals from the private sector, teachers and state or local government personnel. Employees of the University of Maryland Eastern Shore are not eligible to receive participant support. A person classified as an intern would be paid as an employee and not as a program participant, because the intern, while receiving certain training, also is providing services to UMES, the grant sponsor, or a third party.
F&A on 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 reviewed at the time of proposal to determine if F&A is allowable.
Allowable 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 grant sponsored conferences or training projects, is allowable. Any additional categories of participant support costs other than those described in 2 CFR 200.75 (such as incentives, gifts, souvenirs, t-shirts and memorabilia), must be justified in the budget justification, and such costs will be closely scrutinized by the Office of Research during pre-proposal review.
Subsistence Allowance
Stipends, per diem, and/or subsistence allowances represent a predetermined amount to be used to help offset housing or subsistence expenses during the period of the training, in accordance with the specified grant budget. The cost of a participant’s housing and per diem expenses must be necessary and reasonable for the individual to participate in the training, and limited to the days of attendance at the conference plus the actual travel time required to reach the conference location. Where meals or lodgings are furnished without charge or at a nominal cost (e.g., as part of the registration fee), the per diem or subsistence allowance should be correspondingly reduced. It should be noted that participants who live in the area local to the training are not entitled to subsistence payments. They can however, participate in meals and snacks that are provided at the meetings, workshops, and/or conferences.
Travel Allowance
Funds may be requested for the travel costs of participants. If so, the restrictions regarding class of accommodations and use of US-Flag air carriers are applicable. In training activities that involve field trips, costs of transportation of participants are allowable. Participant support costs must be specified, itemized and justified in the budget justification section of the proposal.
Unallowable Costs
The intent of participant support is solely to provide financial assistance for participants to attend conferences and training. Unallowable costs include honoraria for guest speakers, expenses for the PI, project staff or collaborators to attend, and payments made to research subjects as an
incentive for recruitment or participation in a research project. Costs for hosting the conference or training should be budgeted and charged to the parent budget.
Participant support allowances may not be paid to trainees who are receiving compensation, either directly or indirectly, from other Federal government sources while participating in the project. A Federal employee may receive participant support allowances from grant funds provided there is no duplication of funding of items and provided no single item of participant cost is divided between two different agencies.
Field trips for recreational purposes ae not permitted. If a PI is not sure what constitutes recreation activities as opposed to training related activities, consult with the cognizant Program Officer during proposal preparation and/or obtain written permission for the activity.
Participant Support Procedures
Before spending, it is recommended that the UMES Principal Investigator (PI) maintain a website or printed brochure describing the training program activity and schedules, and maintain a log of participant attendance. The PI will keep a record of attendees as well as documentation to justify the activity and expense. Documentation is required indicating successful program completion. Classes or workshops require records indicating program attendance such as sign-in sheets or record of ID being swiped.
Participant support may not be re-budgeted by grantees for other categories of expense without the specific prior written approval of the cognizant Program Officer.
UMES will account for participant support costs separately. An account number will be created to account for the participant support costs. Participant support costs categories under this budget account are the following:
- Stipend
- Travel
- Subsistence
- Fees
- Other
Participant Support Cost and NSF Awards
NSF requires the tracking of both participant budget and costs; as such, the use and monitoring of the budgets and account codes on NSF project cost centers are necessary. In addition to the requirements above some specific requirement are the following:
- Funds budgeted for participant cost cannot be moved from that budget category into another budget category AND vice versa without prior approval
- Within the participant cost budget, re-budgeting to a cost not defined in 2 CFR 200.75 is not allowed though re-budget between specified costs such as stipends or subsistence allowances, travel allowances, and registration fees, are allowed.
- Each meal associated with a conference award must be listed explicitly in the proposal, and only beverages (i.e., not food) for session breaks are allowed.
- Conference with an “All-inclusive” accommodation cost that includes lodging and meals for a fixed cost should have prior approval or the cost per participant broken down the vendor/provider agreement.
- Research Experience for Undergraduates (REU) Site awards
- Participants in training programs must be U.S. citizens or permanent residents.
- Students in this program are trainees and should not be considered or appointed as student employees and paid via payroll
For more detailed descriptions of NSF polices, consult the following webpage:
