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DIVISION OF RESEARCHNSF Participant Support Costs – Proposal Preparation and Award
Management
Fall 2008
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Agenda
• Background • Definitions
– Who qualifies as a participant?– What are participant support costs?
• Restrictions • Proposal preparation & budgeting • Account set-up• Account management• Monitoring
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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
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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)
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Participant Eligibility
• What did participants have to do to receive the payment?
• Documentation of attendees at conferences or workshops is needed.
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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.
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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.
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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).
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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).
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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.
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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.
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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.
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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)
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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.
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Participant Food & Beverage Charges
• Highly scrutinized by auditors and requires adequate documentation when appropriate.
• Generally unallowable when not on travel status.
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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.
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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.
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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.
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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
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DoR Contact Information
Greg SlackDirector of Research and Technology Transfer
[email protected] ext. 6475
Todd Travis Award Administrator (Pre-Award)[email protected] ext. 6475
Connie FergusonContract & Grant Administrator (Post-Award)
[email protected] ext. 6475
Kimberly KlattResearch Compliance Officer
[email protected] ext. 4441
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DoR Contact Information
Adele PuglieseSr. Dept. Secretary
(MAE, ECE, PPAS, IACUC)[email protected]
Billi Jo GoodfellowSr. Dept. Secretary
(CAMP, CBE, BIO, PSY, C&M)[email protected]
Norma WoodsAdministrative Secretary (CAMP, CBS, PT, CEE )[email protected]
Heather Kish Sr. Dept. Secretary
(CUSB, PHY, MCS, HSS, IRB) [email protected]
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Comptroller’s Office Contact Information
Jim FishComptroller
[email protected] ext. 6689
Donna MartellAssociate Comptroller
[email protected] ext. 7258
Sue ScottChief Accountant
[email protected] ext. 6407
Kelly RathbunResearch Accountant
[email protected] ext. 6462
Elizabeth CorbineAccounting Assistant (P-cards)
[email protected] ext. 3789
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Comptroller’s Office Contact Information
Roberta ChestnutAccounting Assistant (POs)
[email protected] ext. 3789
Betsy Niles Head Cashier (Aramark)
[email protected] ext. 6486
Sarah EllisAccounting Assistant (DOs/Travel)
[email protected] ext. 3789
Karen BarrettEndowment/Plant Accountant (Fabrication)
[email protected] ext. 7650
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QUESTIONS?