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Policy 3.6.5.2
Policy and Procedures Manual
Classification Number: 3.6.5.2
Inception: March 9, 51³Ô¹ÏÍøÊÓƵ
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SUBJECT: PARTICIPANT SUPPORT FOR FEDERAL GRANTS
Policy Statement
51³Ô¹ÏÍøÊÓƵ Baptist University (WBU) will follow all federal regulations with regard to the use and distribution of participant support costs. Specific guidelines and limitations are described below, but in all cases federal regulations supersede any local guidelines.
Principal Investigators (PI) and other senior personnel are responsible for ensuring that research plans involving human subjects are reviewed by the WBU Institutional Review Board (IRB) before beginning any research or incurring any costs.
Overview
Participant Support costs are direct costs for stipends, subsistence allowances, travel allowances, or registration fees paid to or on behalf of a “Participant” in connection with sponsor-funded conferences or training projects. A Participant is someone whose function is to learn something. According to , Participants cannot be employees.
Participant Support costs are only allowed on an award when Participant Support is defined by the sponsor in the Request for Proposal/Funding Announcement, or specifically identified in the award document. Per 2 CFR 200.68 Modified Total Direct Cost (MTDC), Finance and Administrative overhead is not allowed on Participant Support costs.
Participant Support is intended to cover the cost of education and training activities for those the project is intended to serve, or whose input is important to meet the proposed objectives.
Unallowable Costs
Examples of costs that are typically unallowable as Participant Support are:
- Speaker fees
- Trainer or facilitator fees
- Meal costs for non-Participants
- Indirect costs
Food and Meals for Participants
WBU allows for a subsistence allowance for Participants to cover the cost of meals as Participant Support.
Participants who are traveling may submit for meal reimbursement up to the amount of the budgeted meal allowance as approved in the grant budget.
If meals are provided to Participants who is not traveling in conjunction with a scheduled activity under the grant, it can be provided as Participant Support as long as the per person cost of the meal is less than the Federal Per Diem meal allocation for the meal and location.
Costs for meals for non-Participants and the portion of the actual meal cost that exceeds the per diem for the Participant(s) is not allowed as Participant Support. Only the cost of meals for Participants up to the per diem amount are allowable as Participant Support. For example, if the federal per diem allocation for lunch is $18. There are 10 Participants and two WBU staff attending a workshop. The actual cost for lunch is $20 per person, so the total lunch cost is 12 people x $20 = $240. Of the total cost, only $180 (10 Participants x $18) can be charged to Participant Support.
Re-budgeting
Most federal agencies restrict re-budgeting of participant support costs. PIs who wish to reallocate participant support costs should contact their program office to obtain approval.
National Science Foundation (NSF) Specific Requirements
- NSF, through implementation of the , specifies prior approval requirements for re-budgeting participant support funds.
- Participant Support funds are restricted and require approval of the cognizant NSF program officer to reallocate funds out of the Participant Support sub budget.
- Re-budgeting costs into Participant Support does not require NSF approval unless funds are moving into the “other” category of participant support.
Non-NSF Agencies
Generally, recipients may not re-budget funds from Participant Support to other categories without prior written approval of the agency. However, this is not the case for all agencies. As always, read your award document, along with any applicable terms and conditions or agency specific regulations, for guidance on re-budgeting Participant Support funds.
Contact for Interpretation: Chief Financial Officer
This policy statement supersedes all previous policy statements on this subject.
Revisions:
03/09/51³Ô¹ÏÍøÊÓƵ – Inception
Printable Policy 3.6.5.2 Participant Support for Federal Grants.pdf
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