GUIDELINES FOR PROCESSING AND RECORDING PARTICIPANT SUPPORT COSTS
Some contract and grant sponsors include a budget category called ‘participant support costs,’ which are defined as 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 meetings, conferences, symposia, or training projects. These costs are allowable with the prior approval of the awarding agency.
Participant support is allowed by a number of contracts and grants awarded by the U.S. Department of Education, the National Institutes of Health, the Office of Naval Research, and the National Science Foundation (NSF), including the NSF Research Experience for Undergraduates (REU) program. While participant support expenses are handled as direct costs under extramurally supported contracts and grants, agencies vary as to whether some or all of these cost items are included in the direct cost base upon which F&A costs are calculated.
Since guidelines vary from sponsor to sponsor and from program to program, it is important to refer to agency and program-specific guidelines.
Who is a Participant?
A participant is an individual who is receiving a service or training opportunity from a workshop, conference, seminar, symposium or other short-term instructional or information sharing activity funded by a sponsored award. A participant may be a UC Berkeley student/scholar, a student/scholar from another institution, a private sector company representative, a K-12 teacher, or a state or local government agency personnel. A participant may not be a UC Berkeley employee. Employees from other UC campuses are eligible if they do not have a role in organizing the event or forwarding the project’s aims.
A participant may be a U.S. citizen, permanent resident, or foreign national. The participant must have a Social Security Number or an Individual Taxpayer Identification Number (ITIN).
A participant is not:
- An employee of UC Berkeley
- A student or project staff member receiving compensation directly or indirectly from the grant
- A research subject receiving incentive payments
- A recipient of any compensation from any other federal government source while participating in the project (applies only to federal grants)
A participant does not perform work or services for the project or program other than for their own benefit. The participant is not required to deliver anything or provide any service to the university in return for these support costs.
What are Participant Support Costs?
Participant support costs are direct costs for items such as participant allowance, supplies, per diem, travel expenses, and/or registration fees paid to or on behalf of a participant in connection with a meeting, workshop, conference, symposium or training project conducted under the award. Amounts must be reasonable, based on type and duration of the activity, and outlined in the program solicitation.
Participant support costs may include the following expenses:
- UC Berkeley tuition and registration fees if required to participate in the project
- Event registration fees
- Stipend (predetermined amount regardless of actual costs) for housing and subsistence allowance
- Travel costs when the sole purpose of the trip is to participate in the project activity
- Event support costs for lodging and meal expenses paid directly to the event facility, only if the payment is made on behalf of, or reimbursed directly to, the participant
- Meals and incidentals when on travel status
- Training materials
- Lab supplies
All costs that are reimbursed or paid on behalf of the participant must be incurred within the project period and be specifically allowed by the sponsoring agency. Participant support costs are budgeted in a separate line and must be accounted for separately. Funds provided for participant support costs that are not spent cannot be rebudgeted for use in other categories except with the prior written approval of the sponsor. In most cases, unspent participant costs must be returned to the sponsor.
The following expenses, except when specifically allowed by the award, should not be processed as participant support costs:
- Travel for project PI or staff
- Multi-purpose travel (i.e., to perform research in addition to attending a project related meeting)
- Travel for a consultant who is providing service to the university
- Event support cost (e.g, facility rentals, media equipment rentals, food/refreshments) not made on behalf of or paid to participants
- Entertainment/food for non-participants
- Honoraria paid to a guest speaker or lecturer
- Incentive payment to encourage an individual to participate as a research subject
- Subaward to a provider for multiple training events (i.e., an ongoing contract with specific terms and conditions)
- Payments to a participant’s employer for reimburse for the costs related to sending the employee to the project event
- Expenses related to meetings of an administrative nature
How to Process Payments for Participant Support Costs
I. The participant must be established as a vendor in BFS in order for payments to be processed.
Vendor Record in BFS for Non-Students
To establish a vendor record (for non-students), a Social Security Number or Individual Taxpayer Identification Number is required. Instructions for requesting a vendor record are available at http://supplychain.berkeley.edu/programs/vendoring-process.
Student Record in CARS and in BFS
Profiles for students are created in the Registration/Student Information System through the admission process. Summer Sessions coordinates with the Registrar’s Office to create records for students admitted as summer-only visiting students; these records are also recorded in the Registration/Student Information System. The Reg/SIS system interfaces student profiles to CARS to create a billing account and to BFS to create a vendor record.
II. The system and process for the payment depends on the purpose:
|Payment Type||System/Process||Expense GL Account|
Travel & Entertainment
Participant support should rarely be used for reimbursement of non-travel related purchases. However, if such a situation occurs, the reimbursement request should be submitted via a Bear Buy Payment Request Form.
The participant may obtain a Direct Bill ID for participant related airfare to be booked via Connexxus. However, due to programming logic, the general ledger account associated with the airfare expense will not be recorded in the participant support GL account range. Until the DBID system can be reprogrammed, project administrators will need to execute a financial journal to reclass the airfare expense to the appropriate account.
Stipend - One-Time and/or Recurring/Multiple Payments - Student and Non-Student Participants
A stipend is a pre-determined amount paid to the participant to help offset housing and/or subsistence expenses. You must submit a BearBuy Payment Request Form to request all stipend payments.
Note: Stipend payments to non-resident aliens are subject to withholding unless the individual is eligible to claim a tax treaty exemption.
Note: If the funding of the contract/grant is from a foreign source, recipients are not subject to withholding. Administrators of foreign sourced awards should communicate with the Accounts Payable Office prior to submitting payment transactions for special instructions.
If it is required for the participant to be a registered student in order to participate in the project, the terms of the grant may allow for payment of UC Berkeley tuition/registration fees. Because these payments are not for financial aid, they are not processed using the DSAS system. Instead, project administrators should submit a CARS: Participant Support Fee Payment Form (Excel) to Accounts Receivable. A financial journal will be processed to charge the expense to the project funds; a ‘check/cash’ payment will be made to the student’s CARS account. Special administrative concerns apply to this process:
- If the student’s registration fees are prorated or canceled, the funds will be used to pay other charges on the account or refunded to the student. Project administrators are responsible for monitoring the student’s continued eligibility for fee payment and for notifying Accounts Receivable of any adjustments in the payment amount.
National Science Foundation
UCB Research Advocate
IRS Topic 421 – Scholarship and Fellowship Grants
Bear Buy Payment Request Form