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Participant Support Costs

Participant Support Costs (PSC) as defined by 2 CFR §200.1, 200.456, are 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 (note that participant support costs do not apply to NIH training grants).

Participant Support Costs are a restricted budget category frequently proposed on National Science Foundation (NSF) awards. Other sponsors may vary slightly in their definitions and restrictions for participant support costs. Participant support costs defined under this guidance should not be confused with costs associated with participants in a clinical trial or research project, such as incentive or human subject payments. Similarly, this guidance does not apply to participants in courses or conferences that are expected to produce a deliverable or provide a benefit to the research outlined in the project scope of work.

Applicability

This guidance applies to federal funding and individuals who are in the role of receiving instruction or training from a federal award.

Defining & Charging Participant Support Costs

A participant is an individual participating in or attending program activities under a federal award, such as trainings or a conference, seminar, symposium, or other short-term instructional or information sharing activity under a federal award, but who is not responsible for implementation of the Federal award.

Individuals committing effort to the development or delivery of program activities under the Federal award (such as consultants, project personnel, or staff members of a recipient) are not participants.

The classification of items as participant support costs must be documented and treated consistently across all federal awards. Participant support costs include expenditures for items such as the following:

  • Stipend (622005): A stipend is a set amount of money to be paid directly to the participant in connection with a short-term training activity. Note that short-term means the appointment period approved by the sponsor. Individuals receiving stipends under participant support costs must be paid as a stipendee and not an employee.
  • Travel (622015): Travel includes the costs of transportation and associated costs and must follow sponsor guidelines (e.g., US flag carrier, coach class, most direct route) as well as UND’s Travel Policy and guidelines. The sole purpose of the trip must be to participate in the conference or training activity. If a training activity involves field trips, the cost of transportation for participants may be allowable.
  • Subsistence Allowance (622010): The cost of a participant’s housing and per diem expenses necessary for the individual to participate in the conference or training activity are generally allowed, provided these expenses are reasonable and limited to the days of attendance. This includes registration fees. Catering is not a permissible expense.
  • Other (622020): Certain costs in support of the participant’s involvement may be allowable, including training materials, printing costs for presentation materials to be distributed at a conference, laboratory supplies and services that can be tied to specific participants. General conference supplies must be charged to the non-PSC account. Check the funding announcement for guidance.

  • Incentives/prizes, memorabilia, or gifts, unless the cost is specific to the project, sufficiently justified at the proposal stage, and approved by the sponsor. For questions on the approved budget, please reach out to your pre-award administrator.
  • An incentive payment to encourage an individual to participate as a human subject in a research study is not a participant support cost and should be budgeted as an “other direct cost” bearing full overhead.
  • Honoraria or fees paid to a guest speaker or lecturer
  • Conference/workshop support costs such as facility rental, building services, video recording, audio transcription, program printing, catering, supplies, or media equipment rental.
  • Subaward to a provider for multiple training events (i.e., an ongoing contract with specific terms and conditions).
  • Agreements with employers (e.g., public school system) to reimburse the employer for the costs related to sending its employee to a conference or workshop. It is recommended that the PI inform participants prior to the initiation of the project about any costs associated with their participation in the project that are not covered.
  • Expenses for collaborators to meet at a single destination and discuss a research project’s progress and direction. Such expenses should be budgeted under travel or other expenses as allowed by the sponsor.
  • Costs for collaborators to attend project meetings, conferences, or seminars.

The intent of participant support is solely to provide financial assistance for participants to attend conferences and training. For a direct cost to be charged to a sponsored award, the cost must comply with the terms and conditions of the award, federal regulations, and UND policy.

For costs to be classified as participant support costs, they must support the participant’s engagement in the activity. The project may incur costs that are allowable on the award, but do not qualify as participant support costs; these costs should be budgeted and expensed on accounts bearing full overhead.

It is not appropriate for a person to be a participant on the project and perform work on the same project at the same time. Participants do not perform work or services. An individual cannot be classified as a participant and an employee in the same budget period. If the project spans years, it is possible that the participant’s role may evolve as the scope of work shifts in the later years of the project. If this happens, the change must be documented and justified.

Participant support funding is typically restricted for purpose and exempt from F&A, requiring separate accountability from the rest of the award. If participant support is approved by the sponsor and indicated in the award documents, a budget line for 622 (Participant Support) will be added in PeopleSoft (PS). A sub-project exclusively for participant support costs may be created upon request or at GCA’s discretion. Expenditures may be incurred in any of the allowable account codes in the series. 

Do not assume that an unexpended balance on the participant support sub-budget may be used to offset a deficit on the parent or other non-participant support sub-budgets. If the award agreement restricted the funds for a purpose, they may not be used to offset a deficit on the parent budget without written approval from the sponsor. If you are uncertain, please contact your Grants Officer for help.

PSCs are:

  • Identified specifically on National Science Foundation (NSF) awards.
  • Awarded by other sponsors (but not necessarily referred to as "participant support costs") and tend to be by program
  • Accounted for in separate sub budgets.
  • Budgeted for the full amount under account code series [622] (Participant Support), whereas the actual participant support cost expenditures may post to account codes Participant Support Stipends (622005), Subsistence (622010), Travel (622015) or Other (622020), as appropriate.
  • Often subject to special sponsor regulations:
    • Do not allow rebudgeting from the participant support cost category into other categories without prior sponsor approval.
    • May be exempt from facilities and administrative (F&A) costs.
    • Require the university to return any unexpended participant support costs to the sponsor.
    • Associated with special programs that provide research experience for participants, such as Research Experience for Undergraduates (REU) and Research Experiences for Teachers (RET) on National Science Foundation grants. Additional sponsor regulations:
      • Do not allow participant support costs to be budgeted on REU and RET sub-budgets to be spent on non-participant activities.
      • Budget allocations cannot offset a deficit in the parent account.

Documentation

Documentation must be retained when managing participant support costs and may vary based on scope of work or revisions to the award (e.g., prior approval or rebudget requests). Programmatic documentation should include:

  • Sign-in sheets for participant attendance at workshops.
  • Documentation on supplies that are ordered or distributed to participants and how they support the participant in the project activity.
  • List of participants the materials are for.
  • Support for allocating costs as “other” or “fees”.

Programmatic documentation should be retained in the department.

Importance of Documentation

Please note that some sponsors, such as NSF, will explicitly list PSC in the notice of award budget. Other sponsors may not be as explicit. Therefore, it is crucial to maintain all communication and other documentation that would support the inclusion of PSC on the award. Procuring these documents and providing context in cases of audit or review is largely the responsibility of the department/local-level managing unit. Maintaining such documentation at the department level is important to compensate for portfolio changes and employee turnover.

Responsibilities

  1. Review award documents at set up, looking for wording similar to “participant support” or “participant costs awarded” to determine if this issue is applicable to your grant.
  2. Check the sponsor’s regulations to see if any rules prohibit the university from applying F&A costs to these charges.
  3. If a separate sub project has not been set up and the sponsor does not allow the university to apply F&A costs to these charges or requires separate accountability for these costs, an Award Budget Setup form must be sent to GCA so that a separate sub project can be established.
  4. Monitor expenditures for appropriateness throughout the life of the grant.
  5. Obtain written sponsor approval for any rebudgeting into or out of the participant support cost sub project categories.
  6. Work with GCA at closeout.

The submitting offices are responsible for ensuring participant support costs are appropriately budgeted and if awarded (via initial request or revision), proper setup in the PS financial system in PSC account codes. RSPD and GCA should serve as a resource to the PIs and departments and submit prior approvals to the sponsor if necessary.

Grants & Contracts Accounting
Twamley Hall 100
264 Centennial Dr Stop 7306
P 701.777.4151
UND.grantcontracts@UND.edu

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