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Participant Support Costs Guidance

Definition

Participant support costs (as defined in 2 CFR 200.75 of the Uniform Guidance) 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.

Prior Approval

The Uniform Guidance (2 CFR 200.456) requires prior approval by the Federal Sponsor 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 Federal Sponsor.

Allowable and Unallowable Participant Support Costs

Participant support costs relate to the recipients of the training provided, not the providers of the training, and the participants cannot be employees of Dartmouth College. It is acceptable for both providers and employees of the College to participate in an event, but care should be taken to allocate costs between 'participants' and those that do not qualify as 'participants'. Lists of attendees and their role at the training event should be included in expense documentation to support the allocation of costs. All costs should be reasonable, in conformance with Dartmouth College policies, and limited to the days of attendance at the conference or training event, plus the actual travel time required to reach the location.

Common types of Participant Support Costs:

    • Payments to defer the cost of attending the conference.
    • Subsistence allowances for housing and meals necessary for the individual to participate. Actual expenses or per diems for the term of the project may be reimbursed following Dartmouth College Business Expense Reimbursement policy.
    • Travel allowances to be reimbursed for actual travel expenses applying the Dartmouth College Business Expense Reimbursement policy.
    • Other costs paid on behalf of the participant such as fees and tuition. Any expenses such as incentives, gifts, souvenirs, t-shirts and memorabilia would need to be well justified in the proposal.

Expenses not considered Participant Support Costs:

    • Honoraria paid to speakers or presenters.
    • An incentive payment to encourage an individual to participate as a human subject in a research study is not a participant support cost and should be budgeted as an 'other direct costs' as 'Subject Payments.'
    • Conference venue expenses such as room rentals, video services, and supplies.
    • Conference meals and catering.
    • Expenses of an employee of Dartmouth College.
    • Per diem or subsistence payments to local participants.

Budget

Participant support costs are most commonly included in NSF proposals and awards. NIH only allows participant support costs when identified in specific Funding Opportunity Announcements. They may be a significant part of a training or conference grant, or a smaller component of a research grant. Regardless of the scope of the training component, care should be taken to budget correctly during the proposal process, identifying those costs that qualify as participant support costs and those that are appropriately categorized elsewhere in the budget.

F&A

Facilities and Administration Costs (F&A) are not allowable on participant support costs, and therefore should be accounted for separately in the financial system. When the PTA account is being set up, the awarded participant support cost budget should have either a unique task number or project number.

Subaward

If a subaward is issued where participant support has been budgeted, the PI/department must monitor subawardee invoices to ensure that the participant support costs are being accounted for separately, and that these costs are allowable.

Rebudgeting

Rebudgeting out of the participant support cost category requires prior approval by the Federal Sponsor. For non-Federal Sponsors, award specific guidelines should be reviewed before rebudgeting participant support costs.

Resources

Uniform Guidance

NSF Proposal and Award Policies and Procedures Guide

NSF publication 'Participant Support Costs Explained'

Dartmouth College Business Expense Policy