DIVISION OF RESEARCHNSF Participant Support Costs – Proposal Preparation and Award

Management

Fall 2008

Agenda

• Background • Definitions

– Who qualifies as a participant?– What are participant support costs?

• Restrictions • Proposal preparation & budgeting • Account set-up• Account management• Monitoring

Background

• Participant support is often provided when NSF funds a project or activity in connection with formal meetings, conferences, symposia, or training programs (i.e. REU, RET, K-12, LSAMP)

• When Clarkson accepts an award we have agreed that NSF funds provided for participant costs will be separately accounted for, and expended for appropriate and intended purposes.

• Participant support costs are being audited with increased scrutiny.

• Institutions are required to maintain written policies and procedures

Who qualifies as a participant?

• Participants are individuals who are recipients of or benefit from a service, training, or experience in connection with formal meetings, conferences, symposia, or training programs.

• Participants are not required to deliver any deliverable or service to the University in return for participant support costs. Participants do not include Clarkson University employees (faculty and staff).

• Participants may include students, national scholars and scientists, private sector representatives, agency personnel, teachers and others who attend and participate in a formal conference, workshop, or training activity. Project staff or general collaborators on a research project do not qualify as participants.

Examples of projects or activities that include participants:Research Experience for Undergraduates (REU)Education Outreach (K-12)Louis Stokes Alliances for Minority Participation (LSAMP)

Participant Eligibility

• What did participants have to do to receive the payment?

• Documentation of attendees at conferences or workshops is needed.

What are participant support costs?

• Participant support costs are cost paid to (or on behalf of) participants or trainees (but not employees) in connection with formal meetings, conferences, symposia, or training programs.

• These costs include stipends or subsistence allowances, travel allowances, supplies, and registration fees paid to or on behalf of the participants or trainees.

What are participant support costs?

• Participants may not be reimbursed for participant support allowances if they are receiving compensation from any other federal government source while participating in the project.

• Local participants may participate in meals and snacks provided at the meeting or conference, however, are not entitled to subsistence payments.

What are participant support costs?

Participant support costs do not include:

• Payments made to research subjects as an incentive for recruitment and participation in a research project.

• Honoraria paid to a guest speaker or lecturer.• Conference support costs such as facility

rentals, media equipment rentals, or conference food.

• Costs that cannot be specifically identified to a participant(s).

Proposal Preparation & Budgeting

• Proposals that include participants may include participant support costs in the proposed budget, provided that the:– number of participants to be supported is

included in the proposal budget– proposal includes justification for the costs

• Note that some programs may have special requirements on how these costs are treated (i.e. REU, RET).

Restrictions

Participant support costs are generally restricted by the

following requirements:

• Participant support costs cannot be re-budgeted into other categories without prior sponsor approval.

• Indirect (F&A) is not allowed on participant support costs.

• Typically, an administrative allowance of 25% is allowed, but only on stipend support (REU, RET).

• Any unexpended participant support costs must be returned to the sponsor.

Identifying and Accounting for Participant Support Costs

• When an award includes funding for participant supports costs, a primary fund for all awarded costs will be established, except for the participant support costs.

• Participant support costs will be established in a separate sub-account, related to the primary account in order to keep participant support costs separate, restrict budget changes, and avoid charging indirect costs.

Identifying and Accounting for Participant Support CostsParticipant support sub-accounts will differentiate the types of costs using the following object codes

(account code):Object Code

Descriptions Definition

2126 Stipend – SummerA stipend is a set amount of money to be paid directly to an individual classified as a participant.

2175 Stipend – Academic Stipend

2143 Stipend - Temp.(Non-Clarkson)

2670 Participant Support – Travel

Travel expenses are costs (such as transportation, meals, lodging) incurred while under a travel authorization for individuals classified as a participant. (Examples would be travel to and from Clarkson and/or associated field trip expenses for REU students.)

2671 Participant Support – Supplies Supplies are expenses incurred for individuals classified as a participant, such materials kits, demonstration supplies, or research materials.

2672Participant Support – Subsistence

Subsistence is an allowance granted for the reasonable cost of temporary housing, meals and living expenses to an individual classified as a participant.

2673 Participant Support – Misc. Other associated costs pertaining to individuals classified as a participant, such as registration fees or insurance.

Identifying and Accounting for Participant Support Costs

• Principal Investigators must expend participant support funds as specified by using the appropriate sub-accounts and object codes.

• Current NSF awards that were originally budgeted using the participant support object codes 2580 and 2581 will continue to do so until the end of the budgetary or project period.

• When an award is accepted by the University that includes participant support costs, the Principal Investigator will be notified of any specific restrictions governing the expenditures of these funds.

• Participant Support Costs require approval by the DoR (excludes p-card)

P-Card Reconciliations Involving NSF Participant Support Costs

• “Expense Descriptions” should indicate the benefit to the project or scope of work (i.e. How did the purchase benefit the participant(s), What is the purpose of the item?).

• Remember to proportionally charge expenses used for more than one project or educational activity.

• Use the appropriate object code (account code)

• Proper “Expense Descriptions” and object codes will minimize the need for Accounts Payable to request additional information (i.e. Direct Cost Justification Form)

• This methodology also applies to purchase requisitions, disbursement orders, and travel expense accounts.

Participant Food & Beverage Charges

• Highly scrutinized by auditors and requires adequate documentation when appropriate.

• Generally unallowable when not on travel status.

Participant Food & Beverage Charges

Allowable Charges

• Food and beverages may be allowable if all the following tests are satisfied:

– Food and beverages are not considered entertainment.

– Food and beverages are incidental to the activity.

– Activity is integral to the goals of the award (should be part of the original proposal).

– Costs of the food and beverages are considered reasonable.

Participant Food & Beverage Charges

Allowable Charges must be justified with documentation (p-card expense descriptions,

email, etc…):

• Explain how the activity is significant and integral to the goals of the project?

• Provide any available supporting documentation such as, an activity invitation or announcement that describes the activity purpose, agenda, attendee roster, or reference that it is explicitly in the proposal.

Participant Food & Beverage Charges

• If allowable, charges for Clarkson employees must be allocated outside of participant support costs (2543 Food Service Other)

• If using Aramark, notify Betsy Niles in Accounts Payable ahead of time by email to avoid receiving a Direct Cost Justification Form.

MonitoringPeriodically, the Comptroller’s Office will query all NSF awards thathave participant support account codes budgeted, review the

following below, and notify the PI if the account warrants review and/or re-

budget: • Budget will be compared to the actual transactions • Rate of transactions• Transactions posted

During close-out the Comptroller’s Office and DoR will:

• Reconcile the budget to actual transactions• Verify that the prior sponsor approval from NSF was

documented, if re-budgeting occurred• Ensure that indirect costs were not assessed on the participant

support costs• Return unspent funds to NSF, if needed

DoR Contact Information

Greg SlackDirector of Research and Technology Transfer

gslack@clarkson.edu ext. 6475

Todd Travis Award Administrator (Pre-Award)ttravis@clarkson.edu ext. 6475

Connie FergusonContract & Grant Administrator (Post-Award)

cferguson@clarkson.edu ext. 6475

Kimberly KlattResearch Compliance Officer

kklatt@clarkson.edu ext. 4441

DoR Contact Information

Adele PuglieseSr. Dept. Secretary

(MAE, ECE, PPAS, IACUC)apugliese@clarkson.edu

Billi Jo GoodfellowSr. Dept. Secretary

(CAMP, CBE, BIO, PSY, C&M)bgoodfellow@clarkson.edu

Norma WoodsAdministrative Secretary (CAMP, CBS, PT, CEE )nwoods@clarkson.edu

Heather Kish Sr. Dept. Secretary

(CUSB, PHY, MCS, HSS, IRB) hkish@clarkson.edu

Comptroller’s Office Contact Information

Jim FishComptroller

fishj@clarkson.edu ext. 6689

Donna MartellAssociate Comptroller

dmartell@clarkson.edu ext. 7258

Sue ScottChief Accountant

scotts@clarkson.edu ext. 6407

Kelly RathbunResearch Accountant

krathbun@clarkson.edu ext. 6462

Elizabeth CorbineAccounting Assistant (P-cards)

ecorbine@clarkson.edu ext. 3789

Comptroller’s Office Contact Information

Roberta ChestnutAccounting Assistant (POs)

rchestnu@clarkson.edu ext. 3789

Betsy Niles Head Cashier (Aramark)

nilesbm@clarkson.edu ext. 6486

Sarah EllisAccounting Assistant (DOs/Travel)

sellis@clarkson.edu ext. 3789

Karen BarrettEndowment/Plant Accountant (Fabrication)

kbarrett@clarkson.edu ext. 7650

QUESTIONS?