Overview
Participant Support costs are direct costs for stipends, subsistence allowances, travel allowances, or registration fees paid to or on behalf of a “Participant” in connection with sponsor-funded conferences or training projects. A Participant is someone whose function is to learn something. According to 2 CFR 200.75 Participant support costs, Participants cannot be employees.
Per 2 CFR 200.456 Participant support costs, Participant Support costs are only allowed on an award when Participant Support is defined by the sponsor in the Request for Proposal/Funding Announcement, or specifically identified in the award document. Per 2 CFR 200.68 Modified Total Direct Cost (MTDC), F&A is not allowed on Participant Support costs.
The intent is to use Participant Support for the cost of Participants in conferences or training projects. Read your Award and your sponsor's terms and conditions to know whether costs associated with hosting the conference or training project should be budgeted and charged to the parent budget or the Participant Support sub budget.
Please see the GCA web page for information on setting up and managing a Participant Support sub budget.
Unallowable Costs
Examples of costs that are typically unallowable as Participant Support are:
- Speaker fees
- Trainer or facilitator fees
- Meal costs for non-Participants
- Human subject payments
- Indirect costs
Food and Meals for Participants (NSF)
NSF allows for a subsistence allowance or per diem to be paid to Participants to use for meals as Participant Support.
Thus, if a meal is provided to a Participant at the conference or training, it can be provided as Participant Support as long as:
- The per person cost of the meal is less than the Per Diem meal allocation for the meal and location; and
- The Participant is not also receiving a Per Diem allowance OR the amount of the Per Diem allowance is reduced by the meal allocation.
Costs for meals for non-Participants and the portion of the actual meal cost that exceeds the per diem for the Participant(s) is not allowed as Participant Support on NSF Awards. Only the cost of meals for Participants up to the per diem amount are allowable as Participant Support.
For example, the per diem allocation for lunch is $18. There are 10 Participants and two UW staff attending a conference. The actual cost for lunch is $20 per person, so the total lunch cost is 12 people x $20 = $240. Of the total cost, only $180 (10 Participants x $18) can be charged to Participant Support.
Rebudgeting
Most federal sponsors restrict rebudgeting of participant support costs. For this reason, Participant Support is set up as a sub budget under the Parent Award.
NSF
NSF, through implementation of the Research Terms & Conditions, specifies prior approval requirements for rebudgeting participant support funds. The UW-edited version of the Prior Approval Matrix has more details:
Participant Support funds are restricted and require approval of the cognizant NSF program officer to reallocate funds out of the Participant Support sub budget.
Rebudgeting costs into Participant Support does not require NSF approval unless funds are moving into the “other” category of participant support.
Non-NSF Sponsors
Generally, recipients may not rebudget funds from Participant Support to other categories without prior written approval of the sponsor. However, this is not the case for all sponsors. As always, read your award document, along with any applicable terms and conditions or agency specific regulations, for guidance on rebudgeting Participant Support funds. A Table of Select Federal Agency Regulations may be found on the PAFC website.
Several sponsors have implemented the Research Terms & Conditions, which includes guidance as to whether or not prior approval is required to rebudget Participant Support funds. Please see the UW-edited Prior Approval Matrix for additional information.