Page Updated: Wednesday, January 27, 2021 11:06:58 AM CST
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 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 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.
Participant support costs are budgeted in a separate category in the application budget and must be accounted for separately. Participant support costs are excluded from the MTDC base when calculating F&A costs.
Once awarded, RSP sets up a separate project under the award to isolate participant support costs and to ensure that F&A is not applied against these costs. These can be identified in WISER by UW Project Type GM_04 Participant Support. All expenses must be consistent with University policies for payments, travel, fees, and other costs.
Rebudgeting funds from the non-participant project into the participant support project may or may not require sponsor approval, depending on the applicable award terms. However, funds provided for participant support costs cannot be rebudgeted for use in non-participant projects and some participant categories unless prior written approval has been obtained from the sponsor. If a project has unexpended participant support funds that the PI/department would like to repurpose, the PI/department should work with their RSP accountant to process a prior approval request with the sponsor. Such rebudgeting should be done as soon as possible during the life of the award. See FAQ #8 for additional guidance.
This does not include NIH Kirschstein-NRSA programs.
The FAQs listed below are based on common scenarios, though they may not be all inclusive. Please contact RSP with questions about participant support costs. Contact the Proposal team with proposal questions and the Award Setup team with award setup questions, see the Staff Directory. Questions pertaining to existing awards should go to the RSP Accountant, see Account Search.
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 may be, but are not limited to, students, scholars, scientists from other institutions, or teachers.
Participants are not paid salaries or wages to provide any deliverable, other than meeting the program requirements (e.g. attendance, testing, etc.).
See FAQ #5 for further information regarding who and what type of costs do not qualify as PSC.
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. These types of costs are most commonly included in National Science Foundation (NSF) grants, such as the following programs:
While NSF has historically allowed participant support costs, NIH only allows participant support costs if they are explicitly identified in the Funding Opportunity Announcement. Other Federal sponsors that may allow participant support include EPA, USDA NIFA or NRCS, NOAA, and others. Non-Federal sponsors may allow participant support costs under some circumstances. Review the funding solicitation for specific instructions and contact RSP with any questions prior to proposal submission.
Yes, participant support costs must be explicitly identified in the budget and budget justification. The NSF budget form has a section on line F specifically for participant support costs, and they are identified in the categories listed in FAQ #4 below. If the budget form you are using does not have such a section, but you plan to include participant support costs, please explicitly identify any participant support costs in the budget and budget justification. Participant support costs are excluded from the MTDC base when calculating F&A costs. Identifying participant support costs will help ensure prior sponsor approval is requested and, if awarded, that RSP sets up a separate project with appropriate F&A.
Participant support costs for a project may include registration fees for the event, transportation to/from and lodging during the event, as well as a per diem allowance to cover meals and incidental expenses.
Participant support costs do NOT include the following types of expenses:
In general, costs listed above may be allowable on the non-PSC project, not the participant support project. If your area of concern is not addressed in this FAQ, please reach out to your RSP 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.
It depends. Catering is not a permissible PSC expense. Business Meals, however, if expenses are for participants, in place of a meal per diem, are eligible to be considered PSC. It must be a budgeted cost or we must have received prior sponsor approval. We are required to follow institutional definitions provided by Business Services, to determine what category of expense the food/meals provided fit(s) into. The payment mechanism, such as a Purchasing Card, Corporate Card, Personal Card, or the use of a Purchase Order, does not determine PSC allowability. See the PSC Food Chart for additional visual guidance.
Per Business Services, a Business Meal is a breakfast, lunch or dinner attended by multiple people which has a UW business purpose. Business Meals do not have a fixed timeline or agenda and may be attended by employees and non-employees. To be considered allowable on PSC, only the participant’s portion of the meal is allowable within the UW’s per person event meal limits. This can be prorated if necessary, between the non-PSC project to include employees working on the grant in attendance, and the PSC project for only the participants in attendance. Itemized, paid receipts are required for all business meals.
Examples of business meals could include purchased food, such as pre-packaged box lunches, sandwiches, cheese trays, pizza, cookies, fruit, etc., purchased from a licensed restaurant and/or catering operation and served by University staff on University property. Prepared food may be delivered by the vendor or picked up at the vendor’s site by University staff. An example is a PI buying lunch to be delivered from a local restaurant for a group of NSF REU students so that, over lunch, they can discuss the projects to which the students have been assigned. Business meals provided by the University that are directly charged to a PSC project are in lieu of the participant receiving a per diem reimbursement or stipend. The per diem or subsistence allowance, if any, is to be correspondingly reduced.
Per Business Services, catering occurs when a vendor provides food service for University sponsored programs on property owned or leased by the University, is both licensed and insured, and prepares, transports, set outs and/or serves the food. Catering is not an allowable expense on PSC funds.
Examples of catering may include a conference the University is hosting at Union South, where the vendor prepares, sets out, and serves the food. As noted above, catering is not an allowable expense on PSC funds.
Some examples that would be considered participant support costs:
Some examples that would not be considered participant support costs:
Rebudgeting may be allowed, but in almost all cases requires prior approval from the sponsor. See the Research Terms and Conditions Prior Approval Matrix. Rebudgeting requests should be processed during the life of the award. More information is available below.
Similar to 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.
Yes. Previously, in A-21, the definition of MTDC did not address participant support costs. In the Uniform Guidance, the definition of Modified Total Direct Costs addresses participant support costs. This means, for awards from any agency that are made under the Uniform Guidance, participant support costs (similar to equipment) should be excluded from the base used to calculate F&A costs.
Stipend payments to participants should be made on a Payment to Individual Report (PIR). The account code used will be either 5709 or 5710, depending on whether or not the individual is a non-student or student and, if a student, whether or not s/he is attending a UW System institution. See diagram below. Consult with your divisional office, as well.
No. A payment to an individual who agrees to participate as a human subject in a research project is not a participant support cost and should be budgeted as Other Direct Costs in the project proposal. Information on payments to research subjects/participants is available at this site: https://businessservices.wisc.edu/documents/103-payments-to-research-participants/
The answer depends on the sponsor. Generally, costs for training grant programs are not considered participant support costs. Training grant programs are not typically short-term experiences and are not consistent with the types of experiences considered to be participant support activities. Trainees are also actively engaged in the scope of work, where participants do not perform work or service for the project or program.
It depends. If UW-Madison has determined that student hourly employee is the appropriate role, then a compelling justification should be sent to the sponsoring agency representative about why that determination was made. Guidance from the National Science Foundation is that the institution determines whether a student hourly employee or participant is appropriate for the project.
However, for the NSF REU program, any student involved would be considered a participant. The NSF REU program is intended to provide a practical educational experience for undergraduate students, to develop their research skills while being mentored. Given the goals of the NSF REU program, it is not possible to have both student hourly employees and participants – all students on an NSF REU project should be considered participants.