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Type: University Policy
Division: Research, Sponsored Research, and Grants
Classification: ACADEMIC & STUDENT AFFAIRS

Contact Phone Number: 503-838-8361
Contact Email Address: sponsoredprojects@wou.edu

TITLE
Participant Support Costs in Sponsored Projects
POLICY NUMBER
ASA-03-016
RESPONSIBLE OFFICER UNIVERSITY CONTACT
Provost & VP for Academic Affairs Sponsored Projects Office
SUMMARY

This policy establishes Western Oregon University's standards for participant support costs allowed for sponsored projects.

APPLICABLE TO
This policy applies to anyone receiving participant support on a sponsored project
DEFINITIONS

Participant:

Individuals who are eligible to receive participant support costs under the Unform Guidance. TO the extent consistent with current and subsequent law, the university further interprets “participant” to mean an individual who is not a Western Oregon University employee, contractor, or intern who is the recipient, not the provider, of training associated with a workshop, conference, seminar, symposium, or other short-term instructional or information-sharing activity. Participants may include, but are not limited to, students scholars, and scientists from other institutions, representatives of private sector companies, teachers, and federal, state, or local government agency personnel. Participants do not include any individuals who are required to provide any products, services, or other deliverables to the university.

Participant Support Costs:

Those costs defined as “participant support costs” pursuant to 2 CFR § 200.1 or any applicable successor statute or regulation as 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.

Sponsored Project:

A program or activity that is funded or sponsored by an external organization. External organizations may include, but are not limited to, federal, state, and local agencies as well as foundations or other private organizations.

Uniform Guidance:

The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards promulgated as 2 CFR Part 200 or, to the extent applicable, any successor statute or regulation.

AUTHORITY
FULL STATEMENT OF AUTHORITY

This policy establishes the requirements for eligibility to provide and receive participant support in sponsored projects conducted by Western Oregon University. The policy promotes uniformity in sponsored projects by establishing consistent standards for permissible participant support in sponsored projects.
 
The university is allowed to use sponsored project funds to pay for participant support costs in connection with the sponsored project if all of the following criteria are met:

  • The costs are necessary and reasonable for the performance of the sponsored project;
  • The costs are explicitly included in the approved project budget or prior written approval is received from the sponsor (i.e., if applicable, the awarding agency); and
  • The expense does not constitute an indirect cost.

Participant support costs include expenditures for items such as the following:



  • Stipend: A stipend is a set amount of money to be paid directly to the participant in connection with their short-term participation in a sponsored project. Note that the sponsor determines or approve the length of time that qualifies for a stipend for short-term participation.
  • Travel: Travel includes the costs of transportation and associated costs and must follow sponsor guidelines as well as University travel policies and guidelines. Travel costs can only be paid as participant support costs for trips or portions of a trip that are primarily related to participation in the sponsored project activity. If a training activity involves field trips, the cost of transportation for participants may be allowable.

  • Subsistence allowance:  The cost of a participant’s housing and per diem expenses necessary for the individual to participate in the project are generally allowed, provided these expenses are reasonable and limited to the days of attendance. Although they may participate in meals and snacks provided at the meeting or conference, participants who live in the local area are not entitled to subsistence payments.
  • Fees: The fees incurred by a participant in connection with meetings, conferences, symposia, or training projects are generally allowable costs. These fees may include laboratory fees, passport or visa fees for foreign participants, and registration fees.

  • Other: Certain other costs paid on behalf of or to the participant as required for their involvement may be allowable, including training materials, laboratory supplies, and insurance.

 
Participant support costs do not include the following types of payments:

  • Honoraria paid to guest speakers or lecturers
  • Conference support costs such as facility rentals, media equipment rentals, or conference food
  • Subaward to a provider for multiple training events (i.e., an ongoing contract with specific terms and conditions)
  • Agreements with employers (e.g., public school system) to reimburse the employer for the costs related to sending its employee to a conference or workshop. It is recommended that the Principle Investigator inform participants prior to the initiation of the project about any costs associated with their participation in the project that are not covered.
  • Expenses for collaborators to meet at a single destination and discuss a research project’s progress and direction. Such expenses should be budgeted under travel or other expenses as allowed by the sponsor.
  • An incentive payment to encourage an individual to participate as a human subject in a research study is not a participant support cost and should be budgeted as an “other direct cost” bearing full overhead.

This policy does not prohibit the university from paying for costs that do not qualify as participant support costs to the extent those expenditures are authorized under other university policies and procedures and applicable law for other purposes and/or paid from other funds.

Prior approval from the sponsor is required to transfer funds budgeted for participant support costs to the direct fund to be utilized under other categories of expenses. Participant support costs will be segregated in the accounting system by setting up a separate fund from all other direct costs.

REFERENCED OR RELATED POLICIES
RELEVANT DOCUMENTS AND LINKS
Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 CFR 200.68, 200.75, 200.308, 200.407, 200. 456; NSF PAPPG II.C2.g(v)
HISTORY
APPROVAL DATE: 02/06/2024
EFFECTIVE DATE: 02/06/2024
LAST UPDATED: 01/09/2024

HISTORICAL DETAIL NOTES:


SOURCE:    NSF Proposal & Award Policies & Procedures GUide (PAPPG) - https://www.nsf.gov/publications/pub_summ.jsp?ods_key=papp
FOR POLICY WEBSITE INPUT (public audience keyword search)
Participant Support, Sponored Projects

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