This page will help you assess your participant support cost practices. It is intended for organizations that are submitting a proposal to the U.S. National Science Foundation or have received an NSF award.
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What are participant support costs?
As defined in 2 CFR 200.1 "Definitions", participant support costs are "direct costs that support participants and their involvement in a Federal award, such as stipends, subsistence allowances, travel allowances, registration fees, temporary dependent care, and per diem paid directly to or on behalf of participants." In summary:
- A participant is an individual whose primary purpose of attending an event is learning or receiving training and who receives a stipend, per diem or subsistence allowance rather than a salary and fringe benefits.
- Participant support costs are direct costs for items such as stipends or subsistence allowances, travel allowances and registration fees paid to or on behalf of participants or trainees in connection with meetings, conferences, symposia or training projects.
General requirements for participant support costs
Organizations receiving awards from NSF must:
- Have a management-approved participant support policy that states compliant requirements and has been distributed to staff for official use.
- Segregate participant support costs in their accounting system by using separate accounts, sub-accounts, sub-tasks, subledgers, etc.
- Track and document participant attendance at meetings, conferences and other events.
- Exclude participant support costs from the allocation base of the project's indirect cost calculations unless this is explicitly provided for in your organization's Negotiated Indirect Cost Rate Agreement (NICRA) or NSF-issued award agreement.
- Ensure that funds budgeted for participant support have not been reallocated to other budget categories without prior written approval from the cognizant program officer for the NSF award.
NSF requirements
Proposals:
Awards:
When you receive an award notice from NSF, it will specifically identify certain conditions that are applicable to, and become part of, your award.
Applicable federal regulations
Checklist for assessing your organization's policies
Creating a policy to help personnel understand the federal and organizational requirements is the first step to ensuring compliance. Please ensure your policy:
- Provides the definition of participant and eligible participant support costs.
- Communicates that participant support costs are to be segregated in the accounting system and provides details on organizational specific codes/procedures to be used (e.g., separate accounts, sub-accounts, sub-tasks or sub-ledgers).
- Requires prior written approval from NSF to re-budget funds out of the participant support budget category or to move costs within the participant support budget that affect the participant support "other" line.
- States that participant support costs are to be excluded from indirect cost recovery calculations unless specifically allowed in your NICRA or your NSF-issued award agreement.
- Outlines requirements for supporting documentation to demonstrate that participant support costs charged are allocable, allowable and reasonable.
Providing clear guidance on what constitutes a participant and what are allowable participant support costs can help avoid common errors, such as direct charging salaries and fringe benefits for employees who are not considered participants.
Employee participation in these events should not be included in the participant support line but should instead be charged to other budget categories.
Your policy should provide guidance on which accounting codes (e.g., object/account codes that are clearly defined as only applicable to participant support) must be used to record participant support costs.
Tracking participant support costs in segregated accounts helps ensure that amounts budgeted for participant support costs are on track for spending and used for participant costs in line with scope or objective of the award. This practice can also ensure that participant support costs are excluded from indirect cost rate calculations and allow your organization to determine whether a request to NSF (or other sponsor) for rebudgeting participant support or a change in scope may be necessary.
NSF recommends that organizations' policies and procedures require compliance with documentation requirements set forth in 2 CFR 200.302(b)(3), which states that organizations must maintain "records that sufficiently identify the amount, source, and expenditure of Federal funds for Federal awards. These records must contain information necessary to identify Federal awards, authorizations, financial obligations, unobligated balances, as well as assets, expenditures, income, and interest. All records must be supported by source documentation."
Typically, this documentation might include the following:
- Evidence of eligibility to participate in the event (e.g., proof of U.S. citizenship or enrollment in a STEM-related accredited degree program).
- Information on attendance at the event, such as participant sign-in sheets.
- Detailed receipts or expense reports clearly marked with the event and NSF award.
Lack of adequate supporting documentation is one of the most common causes of questioned or disallowed participant support costs. NSF recommends awards be reviewed periodically to ensure that these requirements are met.
NSF strongly recommends that you implement and document this as part of your policy. Participant support costs can be tricky; the rules surrounding them can be easily misunderstood and they often receive additional scrutiny by auditors and reviewers.
Obtaining prior approval for costs that are not part of the 2 CFR 200.1 definition for participant support type costs (e.g., T-shirts, tote bags, field trips, awards/gifts, incentives, etc.) and explicitly approved in the grant award or amendment helps ensure your organization, NSF and future auditors or reviewers share a common understanding and that those costs are reasonable, allowable and allocable.
Frequently asked questions
Answers to common questions regarding participant support costs are listed here. NSF recommends you review existing policies and procedures carefully to avoid audit findings and disallowed costs.
Always ensure you obtain written approval from NSF (documented in Research.gov) before rebudgeting participant support costs for any costs that fall outside of the 2 CFR 200.1 definition. Otherwise, this would be a violation of the award terms and conditions and costs could be disallowed.
Participant support costs must be excluded from the allocation base for indirect cost recovery charges to NSF awards. The only exception to this policy is if your organization's current, federally approved indirect cost rate agreement or the NSF award notification allows for the allocation of indirect costs to participant support costs.
Participant support costs may not be used for costs related to employees of the grant they are working on, except for educational projects conducted at local school districts where the participants being trained are employees (e.g., teachers) of the organization. In such exceptional cases, costs must be classified as participant support if payment is made through a stipend or training allowance method. The school district must have an accounting mechanism in place (i.e., sub-account code) that can differentiate between regular salary and grant stipend payments.
If employees have been incorrectly budgeted under participant support, NSF recommends that the charges be removed or a request to the NSF program officer to reallocate the funds out of participant support into the correct budget category be submitted immediately. This request should be made through Research.gov.
These items are typically unallowable. However, when necessary to accomplish program objectives, and if reasonable in amount, these costs may be allowable if properly described and justified in the proposed budget description. Acceptable incentives may include certificates, plaques, ribbons or inexpensive instruction-related material such as pens, pencils and other materials and supplies that are nominal in cost. See PAPPG Chapter II.D.2.f(v) for more information.
If these costs are not included in your original award budget, but later determined to be necessary for the success of the project after an award has been issued, you must follow the guidance in PAPPG Chapter X.A.3 and request prior written approval from NSF.
Speakers and trainers at conferences are not typically participants and should instead be budgeted under the "G.6, Other direct costs" section of your budget. However, if the primary purpose of a speaker's attendance at the conference is learning and receiving training as a participant, then their costs may be included under participant support. See PAPPG Chapter II.D.2.f(v) for more information.
It depends. Students working in jobs unrelated to and uncompensated by the NSF award (such as the bookstore or school cafeteria) may participate in workshops, conferences or other training events as part of their educational experience and be charged as participant support costs.
Incentive payments to research subjects should be budgeted and accounted for under the "G.6, Other direct costs" section of your budget, not as participant support costs.
It depends. If a meal is brought in for the group from a local restaurant while in a conference, workshop or working meeting, a list of participants along with the supporting documentation of the meal provided with associated costs should be provided. In this case, employees must be segregated from participants and only participants can be charged to the participant support budget line. Employees on travel must be charged under employee travel and their per diem reimbursement for that meal reduced accordingly. Employees from the local area must provide for their own meal costs.
If the meal costs are secured through a service agreement or contract (such as part of a hotel package), the costs should be budgeted under the "G.6, Other direct costs" section of your budget to ensure the proper allocation of indirect costs.
