Research Administration Guidelines
RAG22 Guidelines for Participant Support Costs
Policy Steward:Vice President for Research, and Corporate Controller>
- Who Is A Participant?
- Who Is Not A Participant?
- Who May Be A Participant?
- Participant Support Costs
- Further Information
- Cross References
This guideline provides additional guidance regarding participant support costs per Policy RA22.
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 Penn State 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 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 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.
Penn State faculty or staff members cannot be participants.
Professional or keynote presenters whose only role in attending is as a presenter.
NOTE: Individuals attending a conference who may also present a session on their research findings as a secondary role could still be considered participants if appropriately documented.
Research subjects receiving incentive payments to participate in studies are not participants for the purposes of this policy.
Post-doctorates and graduate assistants serve in a dual role at the University. These individuals are eligible to be participants unless they have a role in organizing the event or forwarding the project’s aims and are receiving compensation directly or indirectly from the grant.
Student wage employees, including graduate assistants receiving bridge funding over the summer through wage or Fixed-Term 2 appointments, are participants only if they are strictly attending the workshop for training purposes.
The determination of participant status relates to their primary role – student or employee/graduate assistant. For a project where post-doctorates or graduate assistants or wage payroll students of the University are helping to manage the logistical/administrative details of a sponsored conference or training project, such work would be considered part of their appointment duties and therefore their time and/or travel expenses should be paid for by another appropriate funding source. They should not receive participant support funds on top of that. Conversely, if a post-doctorate, graduate assistant or student wage employee is attending a conference specifically for the purpose of receiving training, those costs generally may be included as 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:
- Penn State 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
Generally, travel costs are reimbursed to participants through ERS. Travel allowances may be permitted (a set amount for each participant regardless of actual costs incurred by the participant), but must be proposed in the award – both narrative and budget – to assure approval by the sponsoring agency. If a department will be incurring substantial administrative costs due to the cost of processing ERS travel reimbursements for participants, administrative time may be permitted as a direct cost on the non-participant portion of the award.
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 in a separate account. 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
- Multipurpose 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 nonparticipants
- 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 to reimburse the costs related to sending the employee to the project event
- Expenses related to meetings of an administrative nature
For questions, additional detail, or to request changes to this policy, please contact the Office of the Senior Vice President for Research or the Office of the Corporate Controller.
RA22 - Participant Support Costs
September 18, 2019 - Changed Vice President for Research to Senior Vice President for Research
- March 10, 2017 - New guideline, created to provide additional guidance regarding participant support costs discussed in Policy RA22.
Date Approved:March 9, 2017>
Date Published:March 10, 2017>