Good afternoon to the group. One of our PIs received an email yesterday from an NSF PO with the following request (the highlight is mine):

 

D.   A revised budget and budget justification, reflecting undergraduate student participation (including any travel costs) under the participant support section (F) of the budget. If university policy does not allow this revision, please include a letter from the appropriate individual in your grants office to indicate this.

We have always considered undergraduates working on research grants (a common feature of a RUI) to be research assistants and not trainees. This is what the PAPPG says:

 

  (v) Participant Support (Line F on the Proposal Budget)

This budget category refers to 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 NSF-sponsored conferences or training projects. Any additional categories of participant support costs other than those described in 2 CFR § 200.75 (such as incentives, gifts, souvenirs, t-shirts and memorabilia), must be justified in the budget justification, and such costs will be closely scrutinized by NSF. (See GPG Chapter II.D.9). For some educational projects conducted at local school districts, however, the participants being trained are employees. In such cases, the costs must be classified as participant support if payment is made through a stipend or training allowance method. The school district must have an accounting mechanism in place (i.e., sub-account code) to differentiate between regular salary and stipend payments.

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.

Funds may be requested for the travel costs of participants. If so, the restrictions regarding class of accommodations and use of US-Flag air carriers are applicable.²¹ In training activities that involve field trips, costs of transportation of participants are allowable. The number of participants to be supported must be entered in the parentheses on the proposal budget. Participant support costs must be specified, itemized and justified in the budget justification section of the proposal. Indirect costs (F&A) are not allowed on participant support costs. Participant support costs must be accounted for separately should an award be made.

 

This is not a training project.

 

Just wondering if anyone else had received anything similar.

 

Carolyn

Carolyn Elliott-Farino

Executive Director, Office of Research

Kennesaw State University

xxxxxx@kennesaw.edu; 470-578-6381

 

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