Sponsored Research

Research CCHIP #012

CLARIFICATION OR CHANGE IN PROCEDURE (CCHIP)

Accounting for Participant Costs on Sponsored Projects

OVERVIEW

This CCHIP establishes the guidelines for Accounting for Participant Costs on Sponsored Projects to comply with sponsoring agency regulations. This will ensure that funds provided for participant costs are separately accounted and appropriately expended for within the intended objectives.

Participants or trainees (not employees) receive a service or training provided at a workshop, conference, seminar, symposium, or other short-term instructional or information sharing activity. Participants may include students, national scholars and scientists, private sector representatives, agency personnel, teachers, and others who attend and participate in the conference, workshop or training activity.

DEFINITIONS

Adequate Subsistence – Means safe, clean lodging with a meals allowance.

Administration – General administration & general expenses, departmental administration, sponsored projects administration, student administration and services, and all other types of expenditures not listed specifically in one of the subcategories of facilities.

F&A Costs – Facilities & Administrative costs means costs that are incurred for common or joint objectives that cannot be identified readily and specifically with a particular sponsored project, instructional activity, or any other institutional activity. F&A costs are synonymous with indirect costs.

Facilities – Depreciation and use allowances, interest on debt associated with certain buildings, equipment and capital improvements, operation and maintenance expenses, and library expenses.

Participant Cost – 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.

Stipend (or subsistence allowance) - A periodic fixed or regular payment allowance granted to trainees to help defray the costs of personal maintenance while participating in a conference or training activity.

Sponsoring Agency – The agency that provides an award directly to the recipient.

Sponsored Project – Any grant, contract, or other agreement between the University of South Florida and a sponsoring agency.

Travel Allowance – Defined as adequate subsistence to cover authorized travel expenses of participants.

CLARIFICATION OR CHANGE

Funds provided for participant support may not be used by USF for any other purpose without specific prior written approval from the sponsoring agency. USF will separate the budget for participant support costs from other funds awarded by the sponsoring agency in a subproject (ending with the 2 digits 44).

Participant support allowances may not be paid to trainees who are receiving compensation, either directly or indirectly, from other Federal government sources while participating in the sponsored project.

The recovery of F&A cost on participant costs for sponsored projects varies by sponsor and program. During the award proposal stage Sponsored Research Pre Award will verify whether the recovery of F&A cost (and the rate) on participant costs is allowable (NOTE: Participant Costs are not automatically exempt from F&A). If a program contains special instructions for the treatment of participant support, the directives can be found in the terms and conditions of the award guidance. 

PROCEDURES

Principal Investigator

  • Identify participant costs during the proposal stage. Complete required participant information in grant proposal.
  • Develop budget for participant costs using representative budget categories (i.e. travel, tuition, etc.).
  • Request prior written approval from the sponsoring agency thru Sponsored Research Pre Award if rebudgeting if required.
  • Ensure that participant costs are charged to the participant subproject (last 2 digits ending in 44).
  • Implement a monitoring plan for participants such as a sign-in sheet or attendance record that conforms to HIPAA Health Information Privacy Standards.
  • Coordinate with Sponsored Research Post Award to report actual participant costs to sponsors.

Department Administrator 

  • Assist PI in developing the budget for participant costs.
  • Request a subproject to account for participant costs from Sponsored Research (last 2 digits ending in 44).
  • Assist PI in developing & implementing a monitoring plan for participants such as a sign-in sheet or attendance record that conforms to HIPAA Health Information Privacy Standards.
  • Record participant costs during the conduct of the project to representative budget categories.
  • Confirm that participant support allowances are not paid to trainees who are receiving compensation from other Federal government sources while participating in the sponsored project.
  • Monitor expenditures for appropriateness of participant classification.

Sponsored Research Pre Award

  • Review proposal for participant costs to ensure that funds are separately accounted for.
  • Verify whether the recovery of F&A cost (and the rate) on participant costs is allowable.
  • Authorize the setup of participant cost subprojects (last 2 digits ending in 44).
  • Forward subproject setup to Sponsored Research Post Award.
  • Contact sponsor to request prior written approval from the sponsor if rebudgeting if required.
  • Advise PI and department administrators on the proper accounting of participant costs.

Sponsored Research Post Award

  • Complete subproject account setup for participant costs (ending with 2 digits 44).
  • Release the project budget for participant support costs.
  • Verify that participant costs are recorded correctly, including any applicable F&A.
  • Report participant costs accurately to sponsoring agency on financial reports.
  • Advise PI and department administrators on the proper accounting of participant costs.
CONTACT

Please address your comments or questions regarding this CCHIP to Sponsored Research Compliance.

AGENCY GUIDELINES

OMB Circular A-21 (Federal awards issued prior to 12.26.14)
Uniform Guidance (2 CFR §200) (Federal awards issued on or after 12.26.14)
HIPAA Health Information Privacy Standards
NIH Grants Policy Statement
HHS Grants Policy Statement
NSF Grants Policy Guide

EFFECTIVE DATE

This CCHIP is effective as of the date of revision and rescinds all previous versions pertaining to the Accounting for Participant Costs on Sponsored Projects.

ISSUED: February 29, 2008
LAST REVISION: August 16, 2018