Participant support costs and human subject payments (research incentives) have very distinct definitions and different budget and processing considerations. Please see below for information on these two types of payments.

Participant Support Costs

As defined in 2 CFR 200.1, means 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. Amounts must be reasonable, based on type and duration of the activity, and outlined in the program solicitation.

Participants perform no work or services for the project or program other than for their own benefit. A participant is not involved in providing any deliverable to the University or a third party. Participants may include students, scholars, scientists from other institutions, individuals from the private sector, teachers, and state or local government personnel. UNT Employees are not eligible to receive participant support.

Allowable Expenses

Participant support costs may include the following expenses:

    • 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 food 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 participants are on travel status
    • Training materials

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 support funds must be returned to the sponsor.

Food and Meals for Participants (NSF)

NSF allows for a subsistence allowance or per diem to be paid to Participants to use for meals as Participant Support. If a meal is provided to a Participant at the conference or training, it can be provided as Participant Support as long as:

    • The per person cost of the meal is less than the Per Diem meal allocation for the meal and location; and
    • The Participant is not also receiving a Per Diem allowance OR the amount of the Per Diem allowance is reduced by the meal allocation.

Costs for meals for non-Participants and the portion of the actual meal cost that exceeds the per diem for the Participant(s) is not allowed as Participant Support on NSF Awards. Only the cost of meals for Participants up to the per diem amount are allowable as Participant Support. NSF Grant Proposal Guide

Budget Considerations

Most federal sponsors restrict rebudgeting of participant support costs.

    • The Uniform Guidance (2 CRF 200.407) requires prior approval of the Federal Agency in order to incur PSC under federally sponsored awards.
    • The PSC must be specifically allowed by the sponsoring agency.
    • F&A costs are not allowed on PSC expenditures and  are excluded from the MTDC base for F&A calculation.
    • Rebudgeting from the PSC category into other categories must have prior sponsor approval.
    • Any unexpended PSC are returned at award close-out - they cannot be used to offset overexpenditures in other categories.

NSF:

Participant Support funds are restricted and require approval of the cognizant NSF program officer to reallocate funds out of the Participant Support sub budget. Rebudgeting costs into Participant Support does not require NSF approval unless funds are moving into the “other” category of participant support.

PI Responsibility
The PI and his/her project staff should be familiar with the specific requirements set forth by the sponsor, and is expected to ensure compliance with those requirements. In addition to the financial restrictions noted above, the PI/department is also required to retain records detailing:
    • List of program participants and documentation of their participation in the program, such as sign-in sheets for attendance at workships
    • Documentation on supplies that are ordered or distributed to participants and how they support the participant in the project activity
    • Criteria by which participants in the program are selected
    • Copies of applications of selected participants, with documentation as to how they meet the selection criteria
Unallowable Costs
The following expenses, except when specifically allowed by the award, should not be processed as participant support costs:
    • Event support cost (i.e., facility rentals, media equipment rentals, food/refreshments)
    • 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 (see human subject payments below)
    • Expenses related to meetings of an administrative nature
    • Travel for project PI or staff
    • Travel for a consultant who is providing service to the university
    • Payments to a participant’s employer for reimburse for the costs related to sending the employee to the project event
Initiating Payments
Payment may include stipends, allowances, or reimbursement of expenses.Reach out to Rochelle Sykes prior to needing the funds disbursed to determine the best method of payment.

Human Subject Payments

Also known as Research Incentives. These payments include cash, checks, gift cards, gift giveaways, food, drawings, etc. given to participants in research that are consistent with the approved IRB protocol

These are incentive payments to encourage individuals to participate in research study and provide private data/information through intervention or interaction. This includes participation in surveys and interviews. These payments/incentives must be directly related to research activities and the budget justifications should include a correlation between the payment and the research activity.

Budget Considerations
  • Human Subject Payments shall be treated as Other Direct Costs in the budget
  • The full F&A rate is applicable.
Initiating Payment

Incentives for research participants may be in the form of checks, cash, gift cards, gift giveaways, food, drawings, etc. and paid on a grant or other local funds.

Please read the official IRB SOP for Compensation to Research Participants. Additional Information is available on the IRB website, and UNT Finance & Administration have a procedure for Purchase of Gift Cards that should be reviewed when compensating participants with Gift cards.

For gift cards, departments must process an ePro requisition to the vendor from whom the cards are to be purchased and assign a Custodian. The Custodian must be a full-time benefits eligible employee who will be designated as the responsible party for custody of the cash/cards at all times and are required to maintain a Research Participant Disbursement Log as the cash/cards are distributed. This is usually the PI or another senior personnel member working on the project. All employees involved in distribution of cards must complete cash handling training annually.

At all times the total value of the cash or gift cards being held and the value of the payments on the disbursement log must equal the amount of the Purchase Order.

The Principal Investigator must retain the confidential log at the department level per the record retention requirements of the grant or contract and must make it available for all approved audit purposes. For information about retention requirements for a specific project, please reach out to Rochelle Sykes.

Researchers are advised to work with the university grants office to help facilitate the best method for their award.

Information on gift card processing can be found in the UNT System Procurement Guide (p 66).

Non-University Employees

Per IRS guidelines, annual payments of $600 or more to non-employees require UNT System to issue a Form 1099 at the end of the calendar year. The Custodian must submit a log with the following information about the participants by sending an encrypted email to UNT System Tax at tax@untsystem.edu after each event or disbursement date to serve as supporting payment documentation.

    • List of participants including: 
      • Name 
      • SSN (if gift cards amount is $100 or more) 
      • Mailing Address 
      • Email or phone number 
    • Amount of gift card
    • Last 4 digits of gift card number 
    • Signature or initials of recipient acknowledging receipt
    • Disburser's name
    • Date card was disbursed 

The above requirements for Custodians to maintain and submit payment information also apply to the research participants payments administered through third party service providers. Custodians must submit the payment information as instructed above.

UNT Students

All non-work related payments to university students must be coordinated through Financial Aid (SFAS). An award authorization form must be sent to SFAS for them to capture the payment as an award rather than as payment through gift cards.

Please work with Rochelle Sykes to set up the award process.

UNT Faculty and Staff

Payment to university faculty and staff participating as research subjects represents taxable income to the recipient, regardless of the payment amount or method used and payments are taxable on employee paychecks and subject to taxes.

The Custodian must submit a research participant disbursement log containing the Employee ID, Employee Name, and amount paid to UNT System Tax by emailing at BSC-GA@Untsystem.edu after each event or disbursement date to serve as supporting payment documentation.

For more information, please contact rochelle.sykes@unt.edu.