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.
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
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.
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
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
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.
Human Subject Payments shall be treated as Other Direct Costs in the budget
The full F&A rate is applicable.
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.
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).
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.
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.
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.