Title

Participant Support Costs for Federally Funded Projects Policy

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Steward

Steward:

Vice President of Finance and Facilities

Category:

Finance

Effective date:

February 10, 2026

Last content update:

February 10, 2026

Purpose

To set guidelines for including participant support costs for federally funded projects (e.g. external grant or contract funded projects). This includes costs for participant involvement, incentives and grant or contracted activities.

Definitions

Direct Costs

Expenses that can be directly and specifically traced to a particular project. Examples of direct costs are the purchase of equipment for a lab, supplies for classroom instruction, or a contract with a vendor for technical services.

Indirect Costs

Also known as facilities and administration costs are overhead expenses that make it difficult to trace to a single cost object, such as rent, utilities and supervisor salaries. Indirect Costs are calculated based on Modified Direct Cost total.

Modified Direct Costs

Direct Costs excluding certain items, such as those classified as equipment, capital expenditures and participant support costs.

Participant Support Costs

Defined by the federal Uniform Guidance Code as "direct costs that support participants and their involvement in a federal award, such as stipends, subsistence allowances, travel allowances, registration fees, temporary dependent care, and per diem paid directly to or on behalf of participants." (2 CFR 200.1)

Participant

Defined by the federal Uniform Guidance Code as “an individual participating in or attending program activities under a federal award, such as trainings or conferences, but who is not responsible for implementation of the federal award. Individuals committing effort to the development or delivery of program activities under a federal award (such as consultants, project personnel or staff members of a recipient or subrecipient) are not participants. Examples of participants may include 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.” (2 CFR 200.1)

Participant Incentives

Payments (cash or cash equivalents) for the purpose of motivating participation in research, such as offering gift cards in return for participating in a survey. Incentives are not the same as participant costs, should be budgeted as a direct cost under “Other,” and are subject to indirect (facilities and administration) costs.

Principal Investigator/Project Director

The individual responsible for the conduct and oversight of a sponsored project. This role includes the administrative direction of the project, fiscal accountability and ensuring adherence to all institutional, sponsor and regulatory policies. The Principal Investigator/Project Director is ultimately accountable but may delegate day-to-day tasks to other team members.

Sponsored Project

An activity, such as research, instruction or training, that is funded by an external organization or sponsor (federal, state, local or private agency) through a formal agreement, such as a grant or contract. These projects have a defined scope of work to meet specific goals and fulfill reporting requirements set by the sponsor.

Policy

Federal grant applicants and awardees must obtain prior approval from the grant sponsor to include participant support costs in a sponsored project budget. Funds designated for participant support must be used exclusively for that purpose. If funds need to be transferred out of this category to another budget area, sponsor approval is required.

Re-budgeting funds from other direct cost categories into participant support costs may or may not require prior approval from the sponsor, depending on the terms of the award.

Unexpended participant support costs are returned to the sponsor at award close-out.

Allowable participant costs:

Training materials and supplies.
Event registration and tuition fees.
Travel (airfare, mileage, allowance for lodging, meals, incidental expenses) when the sole purpose of the trip is to participate in the project activity.
Participant costs listed as allowable by the funding agency within the Request for Proposals (RFP) document.

The following items are considered unallowable uses for federal dollars earmarked for participant costs:

Honoraria for guest speakers.
Expenses for the Principal Investigator, Project Director, project staff or collaborators to attend project meetings, conferences or seminars.
Conference support costs, such as facility rentals or media equipment rentals.
Payments to individuals as an incentive for recruitment or participation in a sponsored project.

Responsibility

Principal Investigator/Project Director

Be familiar with the specific requirements set forth by the sponsor and ensure compliance with those requirements.
Be knowledgeable of the approved project proposal and scope, including budget, narrative, budget narrative, work plan, logic model, measurable goals and outcomes.
Be knowledgeable of the criteria by which participants in the program are selected.
Provide evidence of participant activity in the form of daily logs or similar documentation that must be maintained within the project’s records.
Make certain that reports are submitted ahead of deadlines and comply with guidelines set by the sponsor.
Delegate day-to-day tasks among project team members.
Review and sign invoices from subrecipients. If a subaward is issued where participant support has been budgeted, the Principal Investigator/Project Director must monitor subrecipient invoices to ensure the participant support costs are being accounted for and are allowable and allocable.

Grants Office Personnel

Be familiar with the specific requirements set forth by the sponsor and ensure compliance with those requirements.
Provide technical assistance to the Principal Investigator/Project Director and business services personnel to comply with the federal Uniform Guidance Code and sponsor requirements.
Provide technical assistance regarding proposal development during the pre-award phase.
Provide technical assistance to the Principal Investigator/Project Director and business services personnel regarding budget revisions and reporting during the post-award phase.
Provide technical assistance to the Principal Investigator/Project Director and business services personnel six months prior to end of the grant as part of preparation for the close-out process.

Business Services Personnel

Set up accounts within the College’s financial accounting system so participant support costs are recorded as a category separate from other award accounts.
Provide monthly financial reporting to Principal Investigator/Project Director and grants office personnel for review and compliance monitoring.
Develop procedures for implementing the distribution of participant support costs in accordance with federal, state, system and institutional policies.
Create purchase orders and pay invoices.
Ensure indirect costs are correctly allocated and calculated based on Modified Direct Costs. Participant support costs must be excluded when calculating the Modified Total Direct Cost (MTDC) of a federal sponsored project. Note: Participant incentives are not the same as participant support costs and therefore are subject to indirect costs.