• Participant support costs are allowable with prior approval from the federal awarding agency and are excluded from modified total direct costs.
• The transfer of funds budgeted for participant support costs to other budget categories requires approval from the federal awarding agency.
• Participant support costs are a restricted budget category frequently proposed on National Science Foundation (NSF) awards; however, participant support is provided by a number of other federal agencies and sponsors as well. Other sponsors may vary slightly in their definitions and restrictions for participant support costs.
• Participant support costs do not apply to National Institutes of Health (NIH) training grants.

Department/Managing Unit

Departments are responsible for developing proposals and managing awards in compliance with University guidance and the guidance provided by the sponsor regarding participant support costs. This includes coordination with the principal investigator (PI) and Sponsored Projects. Departments assume the primary responsibility for posting relevant  participant support costs and retaining related documentation in accordance with the terms of the award and Brown University policies. 

Principal Investigator (PI)

The PI is responsible for working with their managing department to communicate the needs of the project and budget, and is ultimately responsible for the charges on the federal award.

Sponsored Projects

The Sponsored Projects team is responsible for ensuring participant support costs are appropriately budgeted and, if awarded (via initial request or revision), setting up a separate account in the Workday system, which will be excluded from facilities and administrative costs (F&A). Sponsored Projects also services as a resource to the department and PI and submits prior approvals to the sponsor, if necessary.

A participant is defined as a nonemployee 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 are not required to provide any deliverable to the University, and they are not subject to human resources policies (e.g., they cannot be terminated for failure to perform).

Participants may be, but are not limited to, students, scholars, scientists from other institutions or teachers.  

A participant is not:

• an employee of the University;
• an intern who, while receiving training, is also providing a service;
• a student or project staff member receiving compensation;
• a research subject or participant in a clinical trial, receiving incentive payments; or
• anyone who has a deliverable or is primarily providing a service to the research outlined in the project’s scope of work.

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 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)

Agencies That Allow Participant Support

While the NSF has historically allowed participant support costs, the 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 the Environmental Protection Agency, National Aeronautics and Space Administration, U.S. Department of Agriculture, National Institute of Food and Agriculture, National Resources Conservation Service, National Oceanic and Atmospheric Administration and others. Nonfederal sponsors may allow participant support costs under some circumstances.

Review the funding solicitation for specific instructions and contact your Pre-Award contact in Sponsored Projects with any questions prior to proposal submission.

Participant support costs include expenditures for items such as the following.

Stipend

A stipend is a set amount of money to be paid directly to the participant in connection with a short-term training activity. Note that short-term means the appointment period approved by the sponsor. The payment may be one-time or recurring payments. Individuals receiving stipends under participant support costs must be paid as a stipendee and not an employee.

Travel

Travel includes the costs of transportation and associated costs and must follow sponsor guidelines (e.g., U.S. flag carrier, coach class, most direct route) as well as Brown University’s travel 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 necessary for the individual to participate in the conference or training activity are generally allowed, provided these expenses are reasonable and limited to the days of attendance. This includes registration fees. Although they may participate in meals and snacks provided at the meeting or conference, participants who live in the local area are not entitled to subsistence payments. 

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 and passport or visa fees for foreign participants.

Other Costs

Certain costs in support of the participant’s involvement may be allowable, including training materials, printing costs for presentation materials to be distributed at a conference, laboratory supplies and services that can be tied to specific participants. Check the funding announcement for additional guidance.

Examples of Participant Support Costs

Some examples of what might be considered participant support costs include the following:

The following costs cannot be included as participant support costs:

• Costs for a guest speaker or lecturer, such as honoraria or travel
• Costs for a consultant or trainer providing services to the sponsored project, such as fees or travel
• Costs for PI or project staff, such as salary, wages, fringe 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 (These types of costs should be on the primary project budget, not the participant support budget.)

Stipend payments to participants should be made according to the individual’s status as a Brown student or non-Brown student. The guidance below reflects typical payment protocol. Deviation from the following instructions may be necessary per the program solicitation or in extenuating circumstances. Please contact your Post-Award accountant in Sponsored Projects with questions.

For Activity Pay payments through UFunds, please contact Financial Operations within the Office of Financial Strategy and Planning for assistance in setting up the appropriate UFunds application for the department.

For a direct cost to be charged to a sponsored award, the cost must comply with terms and conditions of the award, federal regulations and Brown University policy. For participant support costs to be allowable, the costs must be programmatically justified and explicitly included in the budget, and the budget approved or prior written approval received from the federal awarding agency. The expense may not include indirect costs.

For costs to be classified as participant support costs, they must support the participant’s engagement in the activity. The project may incur costs that are allowable on the award but do not qualify as participant support costs; these costs should be budgeted and expensed on accounts bearing full overhead.

The “other” category under participant support costs must be specific and justified to be allowable. For the NSF, costs included under this subcategory may be related to community building activities, lab supplies and services. 

Participant vs. Employee

It is not appropriate for a person to be a participant on the project and perform work on the same project at the same time. Participants do not perform work or services. An individual cannot be classified as a participant and an employee in the same budget period.

If the project spans years, it is possible that the participant’s role may evolve as the scope of work shifts in the later years of the project. If this happens, the change must be documented and justified. For example: An undergraduate from another university participates in a summer REU program at Brown on an NSF award. The following year they are accepted to Brown’s graduate program and begin work on the same project.

Budgeting for Participants vs. Employees

Rebudgeting may be allowed, but in most cases requires prior approval from the sponsor.  Rebudgeting requests should be processed during the life of the award.

Rebudgeting to a Nonparticipant Support Costs Account

It is not allowable to move funds from a participant support costs grant account to a nonparticipant support costs account unless prior approval has been obtained in advance from the sponsor. If approval is obtained and funds are moved into a nonparticipant support costs account, F&A will be applied to the rebudgeted funds, as appropriate.

Rebudgeting to a Participant Support Costs Account

If a participant support project was approved as part of the original award, funds can be rebudgeted from the nonparticipant support costs account 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 needs the sponsor’s prior approval.

Adding a Participant Support Component to a Project

Adding a participant support component to a project requires prior approval from the sponsor. With the sponsor’s approval, it may be possible to fund the new component by rebudgeting unused funds from the current project into participant support costs. 

Another option is to request a supplement for participant support costs. A supplemental proposal needs to be submitted, but first discussed with the program officer. If an approval for participant support costs is obtained, Sponsored Projects will set up a new participant support costs child account under the award to separately account for these costs and apply a 0% F&A rate, as required by Uniform Guidance.

Rebudgeting Funds within Different Categories

Rebudgeting within different participant support cost categories is allowable. There is an exception for NSF awards. If the intent is to rebudget funds into the Other category, that action may need NSF prior approval. Given that the NSF closely scrutinizes costs in the Other category, please contact your Pre-Award and Post-Award contacts in Sponsored Projects with questions.  

Requesting Prior Approval

Work with your Pre-Award and Post-Award contacts in Sponsored Projects to determine sponsor requirements for submitting a prior approval request. Note that NSF prior approval requests must be initiated by the PI on Research.gov.

Documentation must be retained when managing participant support costs and may vary based on scope of work or revisions to the award (prior approval or rebudget requests). Programmatic documentation should include the following and be attached to the PCard expense or Workday transaction:

• Sign-in sheets for participant attendance at workshops
• Documentation on supplies that are ordered or distributed to participants and how they support the participant in the project activity
• List of participants the materials are for 
• Support for allocating costs as “other” or “fees”

Importance of Documentation

Please note that some sponsors, such as the NSF, will explicitly list participant support costs in the notice of award budget. Other sponsors may not be as explicit. Therefore, it is crucial to maintain all communication and other documentation that would support the inclusion of participant support costs on the award. 

Procuring these documents and providing context in cases of audit or review is largely the responsibility of the department. Maintaining such documentation at the department level is important to compensate for portfolio changes and employee turnover.