REG - 50.03.14 Participant Support

1. Purpose

The purpose of this regulation is to discuss participant support costs on (federal or non-federal agency) that are aimed at supporting outreach programs. Participant Support costs bring experts together to discuss research or education findings; or to expose other researchers or students to new research and education techniques.

2. Scope

This regulation applies to any grant awarded to the University that includes participant support.

3. Definition

3.1 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.

3.2. Modified Total Direct costs (MTDC) means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and subawards and subcontracts up to the first $25,000 of each subaward or subcontract (regardless of the period of performance of the subawards and subcontracts under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward and subcontract in excess of $25,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs, and with the approval of the cognizant agency for indirect costs.

3.2.1 Specifically, participant support costs may include costs of transportation or travel allowance, per diem, manuals and supplies (only those directly attributable to individual participants), tuition and stipends, publication and other related costs for participants or trainees.

4. Charging Participant Costs

4.1 Uniform Guidance regulations do not allow indirect costs to be charged on participant support costs.

4.2 Participant support costs are excluded from the calculation of Modified Total Direct Costs (MTDC) under the Uniform Guidance’s new definition, pursuant to Section 200.68 of MTDC. MTDC means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of subawards under the award). MTDC excludes equipment, tuition remission, scholarships and fellowships, and the portion of each subaward in excess of $25,000.

4.3. Participant support costs should not be confused with general travel costs which may be incurred by principal investigators and others as those costs relate to individual research and other projects.

5. New Fund Set-up

In order to have better financial reconciliation for each sponsored project that has participant costs, a new fund will be set up by the Office of Sponsored Research and Programs. This fund will only have the expenses allowable for participant support costs, but will be reported with the main/parent fund when reporting expenditures.

6. Special Considerations

6.1 Participant support costs should be considered as only those costs that can directly be attributable to an individual participant rather than costs that support all participants collectively.

6.2 Costs for project organizers (such as principal investigators, co-principal investigators, etc.), speakers, and program facilitators or coordinators, even where these individuals may also participate as a program participant, are not considered participant support costs.

6.4 See 2 CFR Part 200.75 – Participant Support Costs regulations for additional guidance on participant support costs.