Participant Support Costs

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.[1]

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.

Management of Participant Support Costs

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 Participant Support 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.

[1]This does not include NIH Kirschstein-NRSA programs.

Participant Support Cost FAQs

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.

1. What is a participant?
Last Updated September 15, 2020

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.

2. What types of sponsored projects may include participant support costs?
Last Updated September 15, 2020

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:

  • Research Experiences for Undergraduates (REU)
  • Research Experiences for Teachers (RET)
  • National Research Traineeship (NRT)
  • Research Training Groups (RTG) in Mathematical Sciences
  • Integrative Graduate Education and Research Traineeship Program (IGERT)

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.

3. Should participant support costs be identified in the budget/budget justification?
Last Updated September 15, 2020

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.

4. What costs may be included as participant support costs?
Last Updated September 15, 2020

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.

  • Stipend: A stipend is a set amount of money to be paid by UW-Madison directly to the participant. For more information regarding stipends, please see FAQ #11.
  • Travel: Travel includes the costs of transportation and associated travel-related expenses and must follow sponsor guidelines as well as UW-Madison policies and guidelines. The sole purpose of the trip must be to participate in the project activity.
  • Subsistence Allowance: The cost of a participant’s housing and per diem expenses (reduced accordingly if meals are provided at the meeting/conference) necessary for the individual to participate in the project are generally allowed, provided these costs are reasonable and limited to the days of attendance. Participants who live in the local area are not entitled to subsistence payments, although they may participate in meals and breaks provided at the meeting or conference. Subsistence allowances can be either a lump sum direct payment to the participant or reimbursement of actual expenses through e-Reimbursement, based on UW-Madison policies and guidelines.
    • Provided business meals (excluding catering): The meals paid on behalf of a participant in connection with meetings, conferences, symposia, or training projects are generally allowable costs. Please see FAQ #6 for more information.
  • Other: Certain other costs in support of the participant’s involvement may be allowable, including training materials or laboratory supplies that can be tied to specific participants. (This differs from conference supplies, which should be charged to the non-PSC project.) See Fees example below. Check the funding solicitation for guidance and contact RSP with questions.
    • Fees: The fees paid by or on behalf of a participant in connection with meetings, conferences, symposia, or training projects are generally allowable costs. Additionally, these fees may include laboratory fees, passport or visa fees for foreign participants, and registration fees.
5. What costs cannot be included as participant support costs?
Last Updated September 15, 2020

Participant support costs do NOT include the following types of expenses:

  • Costs for PI or project staff*, such as salary and wages, fringe, or travel
  • Costs for a consultant or trainer providing services to the University project or program, such as fees or travel
  • Costs for a guest speaker or lecturer, such as honoraria or travel
  • Conference/workshop support costs such as facility rental, catering, supplies, or media equipment rental
  • Costs for collaborators, such as travel
  • Human subject payments for participating in a research project

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.

6. How are catering and business meals defined and are they allowable on PSC?
Last Updated September 15, 2020

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.

7. What are some examples of what might or might not be considered participant support costs?
Last Updated September 15, 2020

Some examples that would be considered participant support costs:

  • An NSF project has been awarded an REU supplement. The REU supplement will enable 5 undergraduate students from around the country to participate in a summer research project with a UW-Madison PI. The students will be paid a stipend and provided room and board over an 8-week period. The stipends and room/board would be considered participant support costs.
  • The UW-Madison is awarded a grant from a Federal agency to host an educational workshop in Washington, DC. Individuals (the audience is primarily postdoctoral fellows from around the country) will apply for financial support to attend the conference. The financial support will cover the costs to travel to and attend the workshop. Travel reimbursement costs, lodging/per diem during the event, and registration fees would be considered participant support costs. However, costs of hosting the event, such as room rental, AV equipment rental, or catering, would not be allowable as participant support costs and would need to be charged to the non-PSC project.
  • The UW-Madison receives an award from the NSF that includes an REU component. The REU component allows the PI’s lab to support UW-Madison undergraduate students during the academic year over the course of the three-year grant. The students will be mentored and will assist with various research projects, e.g., media preparation, plant tissue culture, cloning, and mutant analysis. The student stipends would be considered participant support costs. Undergraduate student stipend payments require special treatment and should not be paid as student hourly wages. Consult your divisional office for guidance.
  • NSF provides an award to UW-Madison that includes a RET activity. The PI will host a teacher over the course of the summer who will gain research experience, and then use that knowledge to develop educational materials and activities. The teacher will pilot the activities with students and present the materials at regional conferences with fellow teachers. The teacher’s summer stipend, supplies for the activities, and travel to regional conferences would be considered participant support costs.
  • A Federal agency provides an award to UW-Madison to train teams of classroom educators and community members from around the state. The teams of educators and community members will then engage local youth in community-based science and service-learning projects. The workshops to train classroom educators and community members take place over the summer. The costs associated with the workshops that enable the individuals to attend, including stipends, transportation, and lodging, are participant support costs.

Some examples that would not be considered participant support costs:

  • The UW-Madison is part of a scientific collaboration involving PIs from five different institutions. The UW-Madison PI hosts a meeting with her Co-PIs and other scientists to discuss project progress. Collaborators must travel to Madison to attend the meeting. The costs for this meeting of scientific collaborators to discuss the project would not be considered participant support costs.
  • As part of a conference grant, a UW-Madison PI invites an expert in the field to talk about recent discoveries that were featured in a prominent scientific journal. In order to support the expert’s attendance, the grant provides an honorarium of $2,000. The honorarium for the speaker would not be considered a participant support cost.

8. Is rebudgeting of participant support costs allowed during the life of the award? How would I go about rebudgeting?
Last Updated September 15, 2020

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.

  1. Can I rebudget funds from a PSC project to a non-PSC project within the award after an award has been received?
    Maybe. Generally, it is not allowable to rebudget from the participant support costs category into other budget categories unless prior written approval has been obtained from the sponsor. If approval is obtained from the sponsor and funds are moved from participant support costs into other budget categories, F&A costs will be applied to the rebudgeted funds as appropriate.
  2. Can I rebudget funds from the non-PSC project into a PSC project?
    If a participant support project were approved as part of the original award, then funds could be rebudgeted from the non-PSC project in accordance with the terms and conditions of the award. If the award did not already include a participant support project, then adding a participant support component to the award would need the sponsor’s prior approval. See part c. for more detail.
  3. If participant support costs were not included in the original award, can I add a participant support component to my project?
    Maybe. Adding a participant support component to the project will need prior approval from the sponsor. With the sponsor’s approval, one option to fund this new component would be to rebudget unused funds into participant support costs. RSP can assist with submitting a prior approval request to rebudget funds for this purpose. The other option would be for the PI to request a supplement for participant support costs. A supplemental proposal would need to be submitted, but discuss with your program officer first. If approval were obtained for participant support costs, RSP would set up a new project under the award in order to separately account for these costs and apply a 0% F&A rate as required by the Uniform Guidance.
  4. Can I rebudget funds within the different participant support cost categories?
    Generally speaking, rebudgeting within different participant support cost categories is allowable. An exception would be for NSF awards. If the intent were to rebudget funds into the “Other” category, that action may need agency prior approval. Given that NSF closely scrutinizes costs in the “Other” category, please contact your RSP accountant with questions.
  5. How would I make a prior approval request?
    Please work with your RSP accountant to submit a prior approval request to the sponsor. A WISPER record is not required, but you may need to submit a rebudgeting request according to sponsor requirements. Note that NSF prior approval requests must be initiated by the PI in Research.gov. See the instructions for how to process an NSF PSC reallocation request here: https://rsp.wisc.edu/policies/nsf-psc-reallocation.cfm
9. What kind of documentation should a department keep on file for participant support costs?
Last Updated February 17, 2017

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.

10. Are participant support costs treated differently in the Uniform Guidance than they were in OMB Circular A-21?
Last Updated February 17, 2017

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.

11. How should stipends be paid to participants?
Last Updated February 17, 2017

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.

Pariticpant Support Costs Flow Chart
12. Are payments to research subjects/participants considered participant support costs?

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/

13. Are costs to support pre- or post-doc trainees in a training grant considered to be participant support costs?
Last Updated February 17, 2017

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.

14. What if a sponsoring agency representative requests that I move student hourly employee costs to the participant support costs budget section?
Last Updated February 17, 2017

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.