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Policy Contact: Grants and Contracts Administration

1. Purpose

   The purpose of this policy is to ensure compliance with sponsor regulations and to ensure that funds provided for participant support costs (“PSC”) are accounted for according to the sponsor’s terms and conditions and expended for the appropriate and intended objectives.

2. Definitions
    
   1. Participant: In the context of a Sponsored Project, a participant is an individual who is receiving a service or training opportunity from a meeting, conference, workshop, seminar, symposium, information sharing activity or short‐term instructional activity that is funded with federal or other funding. A participant may not be a University employee. PSC are allowable with prior approval of the federal awarding agency (2 CFR 200.456).
       
   2. Non-Participant: A non-participant includes the following:
      1. An employee of the University;
      2. A student or project staff member receiving compensation directly or indirectly from the Sponsored Project;
      3. A research subject receiving incentive payments;
      4. A guest speaker or lecturer receiving an honorarium;
      5. A collaborator on a Sponsored Project; or
      6. A recipient of any compensation from any other federal government source while participating in the project.
          
   3. Participant Support Costs (“PSC”): 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 (2 CFR 200.75).
       
   4. Sponsored Project: an activity funded by a non-University entity requiring the University, by written agreement, to conduct certain work under a set plan, a set schedule, and a set budget, typically for the purpose of supporting research, instruction or public service through tangible or intangible deliverables that are the ultimate result of the Project.
       
3. Policy
    
   1. In general, participants may be students, national scholars and scientists, private sector representatives, agency personnel, teachers, and others who attend and participate in the conference, workshop, or training activity supported by a particular sponsored award. Participants perform no work or services for the project other than for their own benefit. A participant is not involved in providing any deliverable to the University or a third party.
       
   2. The Principal Investigator (“PI”) or Project Director (“PD”) must be familiar with the specific requirements set forth by the sponsor’s terms and conditions, and in working with departmental support staff, is responsible for ensuring that PSC are spent in accordance with federal regulations, the terms and conditions of the sponsor’s agreement, and applicable SDBOR and University policies.
       
   3. Conditions Associated with Participant Support Costs
      1. Funds awarded for PSC must be in direct support of participants and must meet the allowable, allocable, and reasonability of cost requirements outlined in OMB Circular A-21, pt. C. All costs that are reimbursed to or paid on behalf of participants must be incurred within the project period of performance and specifically allowed by the federal awarding agency. These costs must also be limited to the days of the service or training opportunity plus the actual travel time required to reach the opportunity’s location.
      2. PSC will be excluded from the Facilities and Administrative (“F&A”) rate calculation when the Modified Total Direct Cost Base (“MTDC”) is used (2 CFR 200.68).
      3. Funds received for PSC must be budgeted and accounted for separately. Therefore, a separate fund may need to be created for this special category of cost as there are no specific account codes for budgeting PSC. Funds budgeted for PSC cannot be transferred for use in other direct cost categories without the written prior approval from the federal awarding agency (2 CFR §200.308).
      4. Evidence of attendance of participants must be maintained.
      5. Where meals or lodging are included in the cost of the registration fee, any per diem or subsistence allowance should be reduced accordingly.
      6. Departments will pay participant support stipends through Accounts Payable on Account Code 766060 (Grants to Individuals/Stipends), and not through payroll (Salary/Benefits).
      7. At the end of the project, in most cases, unspent PSC must be returned to the awarding agency.
          
4. Procedures
    
   1. Budgeting for Participant Support Costs at the Pre-Award Stage
      1. When PSC can be included in a proposal budget, the PI/PD will list all costs for stipends, subsistence allowances, travel allowances and registration fees paid to or on behalf of participants or trainees as a separate category on the budget. A detailed budget justification that describes the purpose for the costs and the way in which they will directly benefit the proposed project’s scope of work (“specified, itemized and justified” costs) will need to be provided. This includes specifying the number of participants to be supported.
          
   2. Identifying and Accounting for Participant Support Costs
      1. When an award is received by the Office of Grants and Contract Administration (“GCA”) for project/fund set up, GCA typically will create a separate fund in the Financial Information System for tracking PSC expenses.
      2. Departments will pay participant support stipends through Accounts Payable on Account Code 766060.
          
   3. Re-budgeting of Participant Support Costs at Post-Award Stage
      1. If a PI/PD determines that a re-budget out of PSC to other direct cost budget categories is necessary, written approval from the federal awarding agency must be obtained before a re-budget can occur. The PI/PD will submit a request for a re-budget through GCA fund monitor.
      2. For PSC involving non-federal sponsors, the PI will need to consult the award-specific guidelines before requesting approval for re-budgeting.
          
   4. Monitoring the Project for Participant Support Costs
      1. GCA will provide monthly financial reports to PIs/PDs and departmental support staff for their review. PIs will need to ensure that PSC are being spent in accordance with pertinent regulations and the sponsor’s terms and conditions.
      2. GCA will conduct an after-the fact review of expenditures that have posted and will notify the PI/PD and department support staff if questions or concerns arise on the treatment of PSC for further evaluation and/or corrective action.
      3. For subawards issued with PSC, PIs/PDs will monitor subrecipient invoices to ensure that these costs are being accounted for separately, that the costs are allowable and allocable, and that no F&A has been charged, if applicable.
          
   5. When the project is complete or all funds have been expended, GCA will proceed to close the project/fund.

5. Responsible Administrator

   The Director of Grants and Contracts Administration, successor, or designee is responsible for annual and ad hoc review of this policy and its procedures. The University President is responsible for approval of this policy.

Approved by President on 11/06/2018. Revised 08/05/2024 (clerical).

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