OMB Uniform Guidance A-81 Part 200.75 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.

• The cost is excluded from the Modified Total Direct Cost (MTDC) base
• The cost is only allowed on federal awards when budgeted and approved at the proposal stage and with prior approval from the Agency.
  • The addition of participant cost/program where not previously awarded is considered a change in the scope requiring prior agency approval
• Funds budgeted for participant cost cannot be re-budgeted into other budget categories except with the prior written approval of the sponsor. However, if participant cost is approved and awarded on a grant, funds can be re-budgeted from other budget categories into Participant Support cost without the prior written approval of the sponsor.
  • As a member of the Federal Demonstration Partnership (FDP), the university has expanded authority to re-budget in this manner without prior approval.
    • Note: Re-budgeting funds in or out of a budget category by more than 25 percent of the total costs of the award is a signal that there may be a change in the Scope of Work. Let your Research Administrator and Program Officer know when that is the case.

Definition of a Participant

A participant is a non-employee who is the recipient, not the provider, 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 benefit.

Participants may include the following:

• University of Houston students not employed and paid via payroll at the time of participation
• Students and researchers from other Universities and research institutions
• Representatives from the private sector, teachers, and state or local government agency personnel.

Participants may not include the following:

• An employee of the university including students on payroll
• Advisory board members
• Interns who have paid appointment
• Anyone who has a deliverable or is primarily providing a service to the project

Budgeting for Participant Cost

Before spending, it is recommended that the Principal Investigator (P.I.) maintain a website or printed brochure describing the training program activity and schedules, and maintain a log of participant attendance. Budget account B5079 will be used to budget and account for participant cost seperatly. It should NOT be added to federal sponsored project cost centers where the sponsor has not previously approved the cost. Participant support costs categories under this budget account are the following:

• Stipend
• Travel
• Subsistence
• Fees
• Other

Stipend: A set amount of money to be paid directly to the participant. Stipend rates must be consistently applied across the program and pro-rated where appropriate. Written agreements about the stipend and the amount should be signed by the project P.I. The Participant Cost for Sponsored Projects Payment Form should be used for this purpose and uploaded as backup documentation on the payment voucher

• Use account code 54825 for the voucher payment. Payments to U.H. 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. Refer to the "Voucher Workflow Matrix for Scholarships and Tax Related Payments" for additional voucher routing instructions. 

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 university travel policy. The sole purpose of the trip must be to participate in the project activity. If a training activity involves additional field trips, the costs of transportation of participants may be allowable. Field trips for recreational purposes are not permitted.

• Use account code 54817 - Non-Taxable Travel Reimbursements to participants in research studies. Taxable to Foreign Nationals. Contact the Tax Department for tax withholding rates
• Use account code 54824 - When paying a third-party vendor for travel expenses such as hotel and room accommodation under a separate contract.  Detail receipts must be maintained, including copies of individual room occupancy receipts for each participant.

Subsistence: The cost of housing and meal expenses necessary for the individual to participate in the project are generally allowed, provided these costs are reasonable and limited to the days of attendance. Although participants who live in the local area are not entitled to subsistence payments or per diem, they may participate in meals and refreshments provided at the meeting or conference. While employees are not considered participants, they may receive conference meals under this provision.

• Use account code 54818 - Non-Taxable Expense Reimbursements, other than travel, to participants in research studies- to reimburse the participant directly based on actual expenses
• Use account code 54824 - Participant Expense to a Third Party - Payment to a third party for costs on behalf of a participant in a training program- to pay a vendor directly for expenses related to the meeting or conference.

Fees: Costs directly associated with attending conferences, symposia, or training projects. Such costs include registration, conference, and related fees.

• Use account code 54817 when the cost is associated with travel.
• Use account 54824 - Payment to a third party for expenses on behalf of a participant in a training program.

Other: Certain other costs may also be allowable if specified in the proposal and approved by sponsor upon review and if consistent with university policy and practice. Example: training materials or laboratory supplies where approved up-front by the sponsor.

• Use account code 54818 - to reimburse the participant directly based on actual expenses
• Use account 54824 - Payment to a third party for expenses on behalf of a participant in a training program.

Participant Cost does not include:

• Guest speaker or lecturer fees.
• Conference support costs, such as facility and audio/visual equipment rental.
• Independent contractor agreements.
• Incentives (prizes), memorabilia, or gifts.
• Employee compensation and expenses (Except for meals provided to all attendees of a sponsored conference)

Participant Support Cost and NSF Awards

NSF, unlike most other agencies, views the training of participants as a significant component of their mission. They require the tracking of both participant budget and costs; as such, the use and monitoring of the budgets and account codes on NSF project cost centers are necessary. In addition to the requirements above some specific requirement are the following:

• Funds budgeted for participant cost cannot be moved from that budget category into another budget category AND vice versa without prior approval.
  
  
• Within the participant cost budget, re-budgeting to a cost not defined in 2 CFR 200.75 is not allowed though re-budget between specified costs such as stipends or subsistence allowances, travel allowances, and registration fees, are allowed.   
  
  
• Each meal associated with a conference award must be listed explicitly in the proposal, and only beverages (i.e., not food) for session breaks are allowed.
  
  
• Conference with an "All-inclusive" accommodation cost that includes lodging and meals for a fixed cost should have prior approval or the cost per participant broken down the vendor/provider agreement.
  
  
• NSF Research Traineeship Program, Integrative Graduate Education and Research Traineeship (IGERT)
  • International students may participate in all IGERT activities, but they may not receive NSF IGERT funding.
• Research Experience for Undergraduates (REU) Site awards
  • Participants in training programs must be U.S. citizens or permanent residents.
  • Students in this program are trainees and should not be considered or appointed as student employees and paid via payroll
• Supplemental funding on an existing award classified as Participant Support cost should follow the guidelines above as well:
  • Research Experience for Undergraduates (REU)
  • Research Experience for Teacher (RET)
  • Lab Experience for Faculty (LEF)