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I. Purpose of Policy

This policy defines participant support costs for the purposes of budgeting and direct charging of expenses paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects.

II. Scope of Policy

This policy applies to all federally-funded sponsored projects. It must be understood by Principal Investigators, Department and Grant Administrators, Office of Research Administration (ORA) and Sponsored Programs Accounting (SPA).

III. Key Definitions

Participant Support Costs: 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.

IV. Statement of Policy

It is the Policy of Brandeis University to comply with the federal requirements in the OMB Uniform Guidance Part 200-Uniform administrative requirements, cost principles, and audit requirements for federal awards. Participant support costs are allowable only with the prior approval of the Federal awarding agency (usually when the costs are included in the budget that is approved by the awarding agency). Prior approval of the Federal awarding agency is also required to transfer funds budgeted for participant support costs to other categories of expense. All participant support costs are excluded from Brandeis’s Modified Total Direct Cost (MTDC) base for the purpose of indirect cost calculation.

V. Procedures

Participant support costs are allowed if all of the following criteria are met:

  • The costs are programmatically justified.
  • The costs are included in the budget and the budget is approved by the Federal agency.
  • The expense does not recover indirect costs.

Note: NIH will only allow Participant Support Costs to be charged if they were approved in the original Funding Opportunity Announcement.

A participant is defined as a non-employee who is the recipient, not the provider, of a service or training associated with a workshop, conference, seminar, symposium, or other short-term instructional or information sharing activity. Participants may include students, scholars, and scientists from other institutions, Brandeis students, representatives of private sector companies, teachers, and state or local government agency personnel, but may not include Brandeis employees (faculty, staff, or students engaged in an employment relationship).

Expenses included in participant support costs

  • Stipend. A stipend is a set amount of money to be paid directly to the participant in connection with a short-term (e.g., appointment period approved by the sponsor) training activity.
  • Travel. Travel includes the costs of transportation and associated costs and must follow sponsor guidelines. The sole purpose of the trip must be to participate in the project activity. If a training activity involves field trips, the cost of transportation for participants may be allowable.
  • Subsistence allowance. The cost of a participant’s housing and per diem expenses necessary for the individual to participate in the project are generally allowed, provided these expenses are reasonable and limited to the days of attendance. Although they may participate in meals and snacks provided at the meeting or conference, participants who live in the local area are not entitled to subsistence payments.
  • Fees. The fees paid by a participant in connection with meetings, conferences, symposia, or training projects are generally allowable costs. These fees may include laboratory fees, passport or visa fees for foreign participants, and registration fees.
  • Other. Certain other costs paid on behalf of or to the participant as required for their involvement may be allowable, including training materials, laboratory supplies, and insurance.

Expenses not included in participant support costs

Participant support costs do not include the following types of payments:

  • Honoraria paid to a guest speaker or lecturer.
  • Conference support costs such as facility rentals, media equipment rentals, or conference food.
  • An incentive payment to encourage an individual to participate as a human subject in a research study.
  • Expenses for collaborators to meet at destination/ location and discuss a research project’s progress and direction.

Stipends or Subsistence Allowances

  • To help defray the costs of personal maintenance while participating in a conference or training activity, participants may be paid a stipend, per diem or subsistence allowance, based on the type and duration of the activity, as outlined in the pertinent program solicitation and in the grant.
  • Such allowances must be reasonable and limited to the days of attendance at the conference plus the actual travel time required to reach the conference location by the most direct route available. Where meals or lodgings are furnished without charge or at a nominal cost (e.g., as part of the registration fee), the per diem or subsistence allowance will be correspondingly reduced.
  • Although local participants may participate in conference meals and coffee breaks, which are included in the registration fee, grant funds may not be used to pay per diem or similar expenses for local participants in the conference.
  • Participant support allowances may not be paid to trainees who are receiving compensation, either directly or indirectly, from other Federal government sources while participating in the project.
  • Participant costs cannot be used to pay or reimburse employees.
  • Because the participant support cost budget category is restricted and may not be re-allocated to other budget categories, any unexpended balance left in a participant support award at the end of the project period will become a de-obligated balance and cannot be used to offset other expenses on the award.
  • Documentation is required to support payment to participants (e.g., attendance at workshop, conference, symposia).

Listed below are the spend categories used at Brandeis to track Participant stipends and related expenses:

  • Participant Support Stipend
  • Participant Support Costs Meals
  • Participant Support Costs Travel
  • Participant Support Costs Housing
VI. Regulatory Sources