Participant support costs

Participant support costs are payments to individuals for training through a workshop, conference, seminar or other short term instructional or information sharing activity funded by a sponsored award.

Purpose

• Distinguish participant support costs from honoraria, human subjects payments and fellowships support
• Provide guidance on the use of participant support costs
• Describe the responsibilities

When may participant support costs be appropriate?

Participant support

• Attendee at a workshop, conference or symposia funded by a sponsored project
• Short-term educational project/training activity including programs such as, but not limited to:
  • NSF Research Experiences for Undergraduates
  • NSF Research Experiences for Teachers
  • NSF Research Traineeship
  • NIH National Center for Rehabilitative Auditory Research Summer Research Training Program

What costs do NOT qualify as participant support costs?

Honoraria

• Payment to a guest (non-ASU) subject matter expert for speaking at a conference, symposium or workshop
• Payment for participation on an advisory board related to a sponsored project

Human subjects

• Incentive payment to encourage individuals to participate in a research study and provide private data/information through intervention or interaction. This includes participation in surveys and interviews.

Additional resource: ORIA website, Human Subjects, Special Considerations>Research Subject Compensation

Fellowships

• Support for individual with strong ties to ASU working toward their degree and who may or may not be providing services to ASU, the sponsor or other third party.
• Examples of fellowships include:
  • SFAz Bisgrove Scholar Program
  • NIH Ruth L. Kirschstein National Research Service Award

Additional resource: Fellowships

CAUTION: The terms “participant” and “participant support costs” are sometimes used interchangeably when referring to trainees, human subjects, or human subject incentive payments. Financial transactions involving stipends or incentives in research administration context are not interchangeable.

What is the difference between a stipend and an incentive?

Stipend:  payment to an individual who is attending a conference/workshop/or other short term educational training activity. It may also be applicable to those on a training grant or fellows with no service obligations 

Incentive: cash or cash equivalent payments (such as gift cards or course credit) for participation in a research study

Who may receive participant support from a sponsored project granted to ASU?

Non-ASU students meeting criteria specified for the training activity. Non-ASU faculty or staff meeting specified criteria may qualify for sponsored training or information sharing activities.

Are there any circumstances where ASU faculty/staff/students can receive participant support costs on an award to ASU?

Rarely. In general, university staff cannot be a participant. Students and faculty cannot receive both participant support payments AND salary, directly or indirectly, from the same sponsored project award. Payments for student participants must be coded as Student Support.

Postdoctoral associates/assistants may not receive stipend payments. All payments for postdocs are processed through the payroll system.

Example: A student who is being paid as an employee on the sponsored project may not also be a participant on that same sponsored project.

Can individuals from other entities receive participant support costs?

Assuming they meet the sponsored project criteria for participants, the following groups may receive participant support:

• Students, Scholars and Scientists from other institutions
• Representatives of private sector companies
• Teachers
• State or local government agency personnel

Can individuals receiving participant support costs provide a service to ASU, the sponsor or other third party?

No. If the individual will provide services or produce deliverables, the individual must be paid as an employee.

Can individuals receive both a stipend for the training received and a salary for training they provide to others on the same project?

They may not. If any portion of an individual’s activity is classified as salary, then all payment to that individual is salary. Example: The individual will participate in the training but will then train others as part of a sponsored project. Though the individual is first trained, the training of others is a service and therefore the entire expense is a personnel expense, not a participant support cost.

If participant support is for training activities or “traineeships,” does that mean internship costs are also participant support?

Participant support opportunities may be considered “traineeships” but not all traineeships are related to participant support. Interns are trainees who receive information to advance their knowledge, skills, and experience; however, interns also provide services to ASU, the grant sponsor/program, or a third party. Service providers, such as interns, are not participants.

What costs are generally included in the participant support costs category?

Sponsors generally stipulate allowable costs for the participant support category which normally includes:

• Event registration or tuition fees
• Travel (airfare, mileage, lodging, per diem)
• Training materials
• Participant supplies*
• Stipend

Participant support costs may also include, only if permitted by sponsor’s guidelines:

• Health Insurance allowance
• Subsistence: meals and catered food*

Read the sponsor’s general guidelines, the specific FOA, and ASU’s description of Expenditure Codes 7400 (Non-ASU) and 7700 (ASU).

*The National Science Foundation’s (NSF) Policy office has stated that room rental fees, catering, and supplies should not be budgeted in participant costs in NSF proposals. If essential for project completion, include request in Other Direct Costs category.

What costs may not be budgeted as participant costs?

• Payments to guest speakers, trainers and/or individuals providing peer review or evaluation services
• Expenses for the PI or other project team members to attend the workshop, conference, or symposia supported by an ASU sponsored award. These must be budgeted in the “travel” category
• Food expenses for the PI or other project team members. These must be budgeted in Other Direct Costs

Are facilities and administrative costs charged on participant support costs?

Federally funded projects with full F&A

Generally, F&A is not assessed on participant support costs expensed on federal projects, unless otherwise stipulated by the sponsor’s guidelines and/or FOA.

Non-federal awards with an MTDC F&A rate base

 F&A on participant support costs is not normally charged to nonfederal sponsors employing a Modified Total Direct Costs base.

Sponsored limited F&A rate

F&A on participant support expenses is charged to prime sponsors and nonfederal sponsors (e.g., non-profit, for profit, industry, foreign entities) that stipulate a limited F&A rate based on Total Direct Costs or Total Costs.

Charitable grants received by ASUF and administered by ASU

No. Below are some general guidelines but to make a definitive determination, the sponsor’s guidelines and the FOA must be carefully read.

Federal sponsors – in general

May be allowed if releant to program and not precluded by FOA.

Federal programs – FOA specific

Allowable if relevant to the program and if permitted by FOA.

Non-federal public and for profits

Not typically allowed unless sponsor’s program is intended to support students

Foreign sponsors

Not typically familiar with the concept but may be allowed for specific situations.

Is sponsor approval required to budget participant support costs?

Yes. They must be permitted by the sponsor’s FOA or general guidelines and approved by the sponsor prior to expenditure. There may be exceptions to this when the funds are unrestricted or the award is fixed price, two situations where sponsor prior approval is typically not required for budget changes.

What considerations are there when meals/catered food are included in the budget?

Any food or catering associated with the subsistence of participants must be explicitly identified within the project budget justification during the project approval process, with the following considerations:

1. Food costs are typically scrutinized closely and may be prohibited by certain sponsors or funding opportunities. See Other Direct Costs > Food
2. Projected costs for food expenses must be identified within the budget justification for each year/phase of the project period.
3. Meals/catered food provided during training events must be budgeted in accord with sponsor policies. If allowable, the meals/catered food is budged as Participant Support – Subsistence for the participants.
4. Food for investigators and supporting staff essential to the event may not be paid from the Participant Support – Subsistence category.  If food costs are not budgeted and/or subsequently approved for this purpose in the Other Direct Costs – Food category, the expense must be paid for from a non-sponsored source.
5. To substantiate the quantity of group meals and/or catered meals, a sign-in sheet for event participant attendees must be utilized. 
6. PIs/supporting staff should avoid paying for food from their own money with the intent of receiving reimbursement and should instead utilize department “P-Cards”, when possible.
7. Reimbursements should not be made through the payroll system but rather through the proper category within participant support costs.

If participant support budget is underspent, can the balance be used in other categories to complete the project?

Rarely are participant support costs allowed to be rebudgeted and then only with prior sponsor approval. Rebudgets of participant costs into F&A cost bearing categories will impact the amount of F and A that must be budgeted.

PI/Unit responsibilities

• The PI and RA/unit should be familiar with the specific requirements set forth by the sponsor and also comply with ASU requirements:
  • Confirm that sponsor’s guidelines and/or FOA allow for participant support costs to be budgeted.
  • Determine whether the proposed costs are participant support costs, human subject incentives, or fellowship and budget accordingly
  • Review internal requirements related to ASU Participant Expenses Policy 7400.
  • Budget costs in accord with ASU standard cost practices such as approved per diem rates, competitive airfare, etc.
  • Include a proposal budget justification which fully explains all the individual costs (e.g. stipend, travel, supplies, meals and catered food, etc.) and the number of anticipated participants.
  • Ensure participant support costs are approved by the sponsor prior to expenditure
  • Ensure participant support costs are allowable, allocable, and reasonable
    
    • ASU PI must monitor subaward invoices which include participant costs to ensure they are being accounted for separately and that they are allowable and allocable
  • Determine what, if any, sponsor restrictions exist for example:
    • Does the sponsor require prior approval to rebudget the funds to another direct cost category?
    • Does the sponsor require that unspent participant support costs to be returned to them?
  • Take note that
    • Participant support costs will be placed in a separate account to allow for compliance
    • participant support cost balances may not be used to offset project overruns
• Identify and Recruit Participants
• Prepare Participant Certification Form
• Disburse payments to participants/monitor expenses
• The PI/unit should also retain records detailing:
  • Criteria by which participants in the program were selected
  • Copies of applications of selected participants, with documentation as to how they met the selection criteria
  • List of program participants and documentation of their participation in the program (signed check-in lists; email acceptance from participants; etc.)

Where should questions be directed?

For questions about budgeting participant costs, contact the PNT GCO assigned to the proposal. For questions about using the funds once the project is awarded, contact the assigned AMT GCO.

For questions about entering participant support costs in an ERA budget, or other ERA questions, contact [email protected].