Policy Number: IV-3
Last Reviewed: June 10, 2025
Responsible Dept.: Grants Development & Special Projects
A signed copy of this policy is available in the President’s Office.
Purpose
Some federal agencies and other sponsors include a budget category called participant support costs. Specifically, the National Science Foundation (NSF) has the most restrictive policies governing the budgeting expending and reporting of these funds; this policy is based on NSF requirements. Virginia Western will account for participant support costs separately.
Participant support costs provided by sponsors other than NSF will follow the same requirements as specified in this policy unless an award specifies otherwise. Funds provided for participant support may not be used by grantees for other categories of expense without the specific prior written approval of a cognizant NSF Program Officer.
Definitions
Participant
Participant (as defined by 2 CFR 200.1) generally means 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. (April 2025)
Participant Support
Participant support costs (as defined by 2 CFR 200.1 and NSF General Grant Conditions GC-1 – 10/1/24) means 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. (April 2025)
Types of Participant Support Costs
- Stipends, per diem, or subsistence allowance paid by the conference or training organizer to defray the personal costs of participants while participating in a conference or training activity.
- Travel allowances (if allowable for an award agreement) that cover travel costs of participants, including transportation activities for training activities that involve field trips, and must follow sponsor guidelines as well as the Commonwealth of Virginia policies (e.g. U.S. flag air carrier, coach class, most direct route).
Policy
The National Science Foundation (NSF) participant support cost budget category is to be used for 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 meetings, conferences, symposia, or training projects.
To help defray the costs of participating in a conference or training activity, funds may be proposed for payment of stipends, per diem, or subsistence allowances, based on the type and duration of the activity. Such allowances must be reasonable, in conformance with the policy of the proposing organization and limited to the days of attendance at the conference plus the actual travel time required to reach the conference location. Where meals or lodgings are furnished without charge or at a nominal cost (e.g., as part of the registration fee), the per diem or subsistence allowance should be correspondingly reduced. Although local participants may participate in conference meals and coffee breaks, funds may not be proposed to pay per diem or similar expenses for local participants in the conference.
Participant support allowances may not be paid to individuals receiving compensation from other federal sources while participating in the NSF project. The participant support cost budget category is also excluded from the indirect cost calculation.
Procedure
If participant support costs are proposed in the budget, a detailed justification must describe the purpose for the costs and the way in which the costs will directly benefit the proposed project’s scope of work. If the award includes participant support costs, the Principle Investigator will be notified of the specific restrictions governing the expenditure of these funds.
To track and manage participant support activity, a separate account number, which is not coded to incur indirect cost, is established by the Financial and Administrative Services office for any awards containing a participant support cost budget allocation.
The Principle Investigator is responsible for reviewing project budget reports, transactions, and source documents to ensure that the participant support funds are being expended according to federal regulations and the terms of the agreement.
Participants are not required to deliver any deliverable or service to Virginia Western in return for participant support costs. Participants are not college employees. Participants may include students, private sector representatives, agency personnel, teachers and others who attend and participate in a formal meeting, conference, or training project. Costs that cannot be specifically identified to a participant are not allowed as a participant support cost.
Participant support costs are restricted and cannot be re-budgeted into other categories without prior approval from the funding agency. Any unexpended participant support costs must be returned to the funding agency.
Regulatory Authority
This policy implements the National Science Foundation’s Participant Support requirements. (NSF Proposal Award Policies and Procedures Guide Effective May 20, 2024, and NSF General Grant Conditions GC-1, October 1, 2024).
The Uniform Guidance (2 CRF 200) requires prior approval of the Federal Agency in order to incur Participant Support Costs under federally sponsored awards. The Participant Support Costs must be incurred within the period of performance of the project and be specifically allowed by the sponsoring agency. Applicable federal regulations include:
- eCFR :: 2 CFR 200.1 — Definitions.
- eCFR :: 2 CFR 200.308 — Revision of budget and program plans.
- eCFR :: 2 CFR 200.456 — Participant support costs.
