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Participant Support

OMB Uniform Guidance A-81 Part 200.75, previously in A-21, defines participant support costs as 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.

 When participant support costs are budgeted and awarded by a sponsor:

  • Funds cannot be re-budgeted into other categories except with the prior written approval of the sponsor. 

When participant support cost is not budgeted and awarded by a sponsor:

  • Prior approval of the Agency is needed in order to incur Participant Support Costs under federally sponsored awards.  

The Participant Support Costs must be incurred within the period of performance of the project and be specifically allowed by the sponsoring agency

Definition of a Participant

A participant is a non-UH employee who is the recipient of a service or training associated with a sponsored project workshop, conference, seminar, symposium or other short-term instructional or information sharing activity. Participants do not perform work or services for the project or program unless it is for their own benefit. Participants may include students, researchers from other institutions, and representatives from the private sector, teachers, and state or local goverment agency personnel. 

Budgeting for Participant Cost

Participant support costs is normally exempt from indirect cost. However, when the entire award or most of the award funds are budgeted and geared towards trianing, a de-minimus IDC rate may be provided for in the sponsor's program announcement for the entire award including participant support cost.

Expending for Participant Cost

Direct stipend payments (account codes 54823 and 54825) to UH students must be routed through Student Financial Services. Administrators should advise students to discuss these potential payments with their financial aid advisor, before issuing stipend payments as they may affect the student’s financial aid.

The PIs and the Department Business Administrators are responsible for providing evidence of attendance of participants in the form of a daily log or similar documentation that must be maintained within the project's records. It is recommended that a participant brochure outlining the training program be provided to each participant and a signup sheet be used.

The Participant Cost for Sponsored Projects Payment Form should be used as backup documentation.

Account Codes for Participant Cost

Separate Expenditure Account Codes that roll up Budget Account Code B5079 are used to budget and account for this cost separately. This budget account will not be added to sponsored project cost centers where the sponsor has not previously approved participant support costs.

  • Account code 54817 - Non-Taxable Travel Reimbursements to participants in research studies. Taxable to Foreign Nationals. Contact the Tax Department for tax withholding rates. 
  • Account code 54818 - Non-Taxable Expense Reimbursements, other than travel, to participants in research studies.
  • Account code 54823 - UH Employee Participant Stipend - Stipend payment to a UH System employee (including a UH System student who is also an employee) who is a participant in a training program. It is not considered a payment for services. Taxable to Foreign Nationals. Contact the Tax Department for tax withholding rates. 
  • Account code 54824 - Participant Expense to a Third Party - Payment to a third party for expenses on behalf of a participant in a training program. The procedure is used when paying a vendor directly on behalf of the participant. This payment must be tied to the participant for audit/tracking purposes.
  • Account code 54825 - Non-UH Employee Participant Stipends - Stipend payment to a non-employee of UH System (including a non-employee student) who is a participant in a training program. This is not considered a payment for services. Taxable to Foreign Nationals. Contact the Tax Department for tax withholding rates. 

The Participant Cost for Sponsored Projects Payment Form must be uploaded as backup documentation on the regular voucher. Refer to the "Voucher Workflow Matrix for Scholarships and Tax Related Payments" for additional voucher routing instructions. 

Additional Guidance

Budget account B5079 will not be added to sponsored project cost centers where the sponsor has not previously approved participant support costs.

The transfer of funds budgeted for participant support costs to other categories of expense requires prior approval from the sponsor.

Participant support costs is normally exempt from indirect cost. However, when the entire award is budgeted and geared towards training, a de-minimus IDC rate is provided for in the sponsor's program announcement.

Direct stipend payments (account codes 54823 and 54825) to UH students must be routed through Student Financial Services. Administrators should advise students to discuss these potential payments with their financial aid advisor, before issuing stipend payments as they may affect the student’s financial aid.

The PIs and the Department Business Administrators are responsible for providing evidence of attendance of participants in the form of a daily log or similar documentation that must be maintained within the project's records. It is recommended that a participant brochure outlining the training program be provided to each participant and a signup sheet be used.

How will the department know a sponsored project has participant cost?

  1. The amount will be included in the proposal budget at the time of submission and when awarded.
  2. The amount will be budged in the PeopleSoft project cost center under the Budget Account code B5079.
  3. The amount may be budgeted in a separate cost center if one of the two conditions exists:
    1. IDC charged to participant costs is a rate different from IDC charged to the rest of the budget expenditures.
    2. Participant costs will be used to pay student support via payroll.