Grant Management & Financial Oversight
Unraveling Participant Support
Participant support is an exciting budget category because it is exempt from Modified Total Direct Costs (MTDC), which means grantees get a bigger bang for their buck. Let’s take a closer look at what is appropriate and allowable in this budget category. To do that, we need to determine who qualifies as a participant, and what is allowable under the support. First, participants are individuals participating in or attending program activities such as trainings or conferences, but who are not responsible for implementation of the award. This includes community members participating in a community outreach program, members of the public whose perspectives or input are sought as part of a program, students, or conference attendees. This excludes anyone committing effort to the development or delivery of program activities, so consultants, project personnel, or staff members of a recipient or subrecipient are not participants. Human participants (aka human subjects in research) are also NOT participants under this definition.
Next, we need to identify what costs are considered participant support costs. These are direct costs that support participants such as stipends, subsistence, travel allowances, registration fees, temporary dependent care, and per diem. The use of the term stipend is important because that indicates the dollars are not wages – training participants who receive stipends only have the obligations required by the respective program – they are not employees. This may mean that your institution pays the stipends by a means other than its normal payroll system, possibly by disbursement voucher. This has a ripple effect for trainees who are not enrolled students at your institution. If they aren’t enrolled and aren’t being entered as a new employee, you’ll need to take steps to get them entered into “the system” at your institution so they have appropriate electronic access to the resources they may need as part of the program.
Now that we know how to define participants, and what is allowable as participant support costs, we have reached the paperwork stage. All direct costs on a grant need substantiation and this includes participant support costs. This is likely documented as the costs are incurred – your backup documents need to include the benefit and necessity of the expense to the participant and program. This may also include tracking participation at workshops or other events or even trainee completion of the program. For those without detailed institutional policies – document everything! It just seems to make life easier, and you’ll have data to compare participation in future years.
It is possible that the PI may decide the amount of participant support in the proposal was overestimated – or perhaps an-in person event shifted to virtual, reducing the costs. The PI then sees “extra” money in the grant and wants to know what it can be spent on. The answer is simple – only on other allowable participant support expenses. If the PI wants to shift budget out of participant support, this is likely going to require sponsor approval, and you’ll need detailed information from the PI that addresses the implications for this proposed change in scope.
As the research administrator, with careful monitoring that the expenses charged to participant support are reasonable, allowable, and allocable, you can help the PI stay in compliance with the myriad of federal and institutional policies and get the most bang for their buck with that budget category.
(https://www.ecfr.gov/current/title-2/part-200/section-200.1 2 CFR 200.1)