Participant Support Costs

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Participant Support Costs Policy

Policy and Procedures for the use of Participant Support Costs in National Science Foundation Research Experience for Undergraduates Program Grants

Purpose:
This policy and procedure document sets forth the Colleges' guidelines and procedures for the use of participant support costs included in grant projects funded by the National Science Foundation Research Experiences for Undergraduates Program (NSF REU). This document is a necessary tool to ensure the Colleges' compliance with the rules and regulations specific to the inclusion of participant support costs in NSF REU grants. It includes eligibility and financial rules and documentation requirements unique to NSF REU grant projects which include participant support costs. The policy information included in this document is derived from the NSF Program Solicitation for NSF REU Sites and Supplements, currently identified as "NSF 13-542". This document will be updated periodically by the Business Office to align with the NSF Program Solicitation. However, this document does not supersede any other grant related policies of the Colleges or any National Science Foundation grant regulations, therefore the applicable federal regulations should be consulted before making a final determination on any policy decision.

Definition:
Participant support costs are direct costs for items such as stipends or subsistence allowances (not a salary or wage for work performed), housing, travel allowances, lab use fees, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with meetings, conferences, symposia or training projects.

Participant support payments are payments for which no services are rendered or required. If the intent is to engage students as technicians, then an NSF REU grant project is not the appropriate funding mechanism.

NSF REU has two mechanisms of support, REU Sites and REU Supplements. REU Sitesare based on independent proposals to initiate and conduct projects that engage a number of students in research. REU Supplementsmay be included as a component of proposals for new or renewal NSF grants or cooperative agreements or may be requested for ongoing NSF-funded research projects.

Participant support costs generally do not include:

  • Travel for Principal Investigator or other project staff
  • Consultant fees
  • Honoraria, stipends, or wages paid to speakers or presenters delivering the training
  • Room rental fees, supplies, etc. that can't be specifically identified to participants

Participant support costs are not to be confused with the costs related to participants in a survey or other study.

Policy:
Participant support costs under NSF REU projects are subject to several unique sponsor regulations. Including restrictions on participant eligibility, what fees can be charged to participants, and budget spending. Principal Investigators who receive awards under the NSF REU program are required to know and comply with these sponsor regulations and this policy and procedure document.

Specific regulations governing the NSF REU program are listed below. Note that this listing highlights most key compliance requirements for the NSF REU program but it is not all inclusive. The Principal Investigator applying for and/or receiving the award is responsible for compliance with all applicable NSF REU regulations.

NSF REU eligibility regulations explain that they:

  • Require participants to be accepted to or enrolled in an undergraduate program. Students who have received their bachelor's degrees and are no longer enrolled as undergraduates are generally not eligible to participate.
  • Require participants to be U.S. Citizens, U.S. Nationals or permanent residents of the United States.
  • Require that for NSF REU Site projects, a significant fraction of the student participants come from outside the Colleges.
  • Require that for NSF REU Site projects, at least half of the student participants be recruited from academic institutions where research opportunities in STEM are limited (including two-year colleges).
  • Require for NSF REU Site projects, the reporting of demographic data on REU student participants as a part of annual and final project reports.
  • Require that for NSF REU Site projects, the Principal Investigator must establish a website for the recruitment of students and dissemination of information about the REU site and maintain the website for the duration of the award.

NSF REU budget spending regulations explain that they:

  • Require that when participant support costs are not specifically awarded by the sponsor in the NSF REU Notice of Award, prior written approval from the sponsor must be received in order to include them.
  • Require that REU Site project costs be predominantly for student support, which usually includes such items as participant stipends, housing, meals, travel, and laboratory use fees. Costs in budget categories outside Participant Support must be modest and reasonable.
  • Require that no application fee be charged to participants.
  • Require that the Colleges not charge students tuition or include tuition in the proposal budget, as a requirement for participation (although it is permissible to offer students the option of earning academic credit for participation).
  • Require that the Colleges not charge participants for access to common campus facilities such as libraries or athletic facilities.
  • Require participant support costs to be accounted for separately.
  • Require that payment of stipends or subsistence allowances to participants be reasonable, and limited to the days of attendance at the conference or training event plus the actual travel time required to reach the conference or training activity location. So as not to create a financial hardship for students, REU Sites are encouraged to pay students their stipend and living expenses on a regular basis or at least on an incremental basis--not, for example, in a lump sum at the end of the project period.
  • Require that where meals or lodging are furnished without charge or at a nominal cost (e.g., as part of the registration fee), the per diem or subsistence allowance should be correspondingly reduced.
  • Do not allow spending on entertainment, amusement, diversion, social activities or any other kind of recreational activity for participants.
  • Do not allow re-budgeting from the participant support cost budget category into other categories without prior written approval from NSF. However, they do allow re-budgeting into the participant support cost budget category without prior written approval unless the principal investigator plans to move funds into the "Other" subcategory of participant support costs.
  • Do not allow spending on additional categories of participant support costs, such as incentives, gifts, souvenirs, t-shirts and/or memorabilia, without prior written approval from NSF.
  • Do not allow spending on per diem or similar expenses for local participants in the conference or training program.
  • Allow spending on non-alcoholic beverages during conference or meeting breaks, but not food.
  • Allow spending on "working meals" at seminars and other events at which student participation is required and for which there is a documented formal agenda.
  • Allow, in training activities that involve field trips, costs of transportation of participants to be charged as participant support costs.
  • Do not allow indirect costs (facilities and administrative costs (F&A) on participant support costs.

Any project related travel reimbursement must comply with sponsor regulations and the Colleges' travel guidelines at Travel Expense Reimbursement Guidelines. Note that travel costs must be substantiated with original receipts even if the travel allowance amount is well below the total costs incurred for the trip.

Procedures:
To evidence compliance with the policy described above, the following procedures must be followed:

  • Before the project begins, the participant must sign and return to the PI, a project acceptance letter that at a minimum, includes the following:
  • A description of the support payment terms;
  • An explanation that support payments will be reported on an IRS Form 1099 and that it is the participant's responsibility to determine the taxability of the payments;
  • An early termination clause explaining the impact on the support payments;
  • A listing of the programmatic requirements the participant must meet to receive support payments; and
  • An explanation of any housing or other items provided to the participant by the Colleges.
  • Along with the project acceptance letter, the participant must also submit a completed and signed IRS Form W-9. This document is the participant's certification that they are a U.S. Citizen, U.S. National or permanent resident of the United States.
  • Before beginning the project, each participant institution must submit an official transcript to the Principal Investigator. The PI must verify that the participant is accepted to or enrolled in an undergraduate program. The PI must maintain the official transcript in their grant file. When the verification is complete the PI must notify the grants manager in the Business Office in writing that the enrollment status of all participants has been verified.
  • In order to make support stipend/subsistence allowance payments to participants, at the beginning of the project, the Principal Investigator will be required to submit a Request for Payment/Reimbursement form to the Business Office which explains the schedule of payments to be made to the participant. The form must be accompanied by a copy of the participant agreement and an IRS Form W-9 signed by the participant. It is the Principal Investigator's responsibility to notify the Business Office immediately if the participant withdraws from the project. At the time of the withdrawal, the Grants Manager in consultation with the Principal Investigator, will review the stipend payments made and/or remaining and determine if the participant is owed a prorated amount of the remaining stipend amount or if the participant needs to return any amount to the Colleges.
  • The PI is responsible for documenting participant attendance at structured events such as meetings, workshops, symposia, etc. where project costs are incurred. The attendance records will at a minimum include the date of the event, the name of all attendees, and the purpose of the event. Each participant should sign or initial next to his or her name, or the PI could place a check mark next to the participant's name. These attendance records will be kept with the PI's grant records as backup for charges related to the event.
  • If a meal is served/taken at any of these events, a copy of the working meeting meal agenda must be sent with the expense reimbursement request or invoice.
  • Participant support costs must be accounted for separately. Below are the account numbers that must be used to record participant support costs:
    • 54401 - PSC ' Subsistence/Stipend
    • 54402 - PSC ' Domestic Travel
    • 54403 - PSC ' Foreign Travel
    • 54404 - PSC ' Summer Housing
    • 54405 - PSC ' Meeting Meals
    • 54406 - PSC ' Supplies
    • 54407 - PSC ' Print Services Charges
    • 54408 - PSC ' Domestic - Conference Registration Fees
    • 54409 - PSC ' Foreign ' Conference Registration Fees
    • 54410 - PSC ' Vehicle Rental
  • To facilitate accounting for participant support costs separately, when applicable, the PI is responsible for documenting a reasonable methodology for calculating participant support costs versus non-participant support costs. This documentation must be submitted to the Business Office along with the expense reimbursement request or invoice. Allocating the cost of a working meeting meal between participant and non-participant using the headcount for each would be considered a reasonable methodology. Note that when a rental vehicle is needed to transport participants the cost of the vehicle can be charged in total to participant support costs.
  • At the completion of the project the PI must prepare and sign a certificate of completion or other document evidencing each participant's completion of the project. A copy of the document must be maintained by the PI in their grant records.