The kind of costs you describe are not participant support costs: they're payments to human subjects and, as such, they go under Other Direct Costs (and are subject to IDC recovery), per the GPG, Section II.C.2.g.vi (http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/gpg_2.jsp#IIC2gvi):

"Examples include aircraft rental, space rental at research establishments away from the grantee organization, minor building alterations, payments to human subjects, and service charges."

Michael Spires, M.A., M.S.
Senior Proposal Analyst
Office of Contracts and Grants
Woodbury 401, 572 UCB
University of Colorado Boulder
Boulder, Colorado 80309-0572
O (303) 492-6646
F (303) 492-6421

NEW Uniform Guidance (2 CFR 200) is effective December 26, 2014!
Questions? Contact your Proposal Analyst or Grant Officer or visit our website.
-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Trish Brock
Sent: Wednesday, January 28, 2015 8:56 AM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] Participant Support vs Incentives: NSF

Good morning,

The new GPG specifically identifies that any incentives included as participant support costs will be carefully scrutinized.  I have the regulations, but I also have a faculty member who believes my office is fabricating the regulations and is insistent that we get confirmation of our stance that an incentive of $50 for participation in a focus group may not be participant support (unless the focus group is a training exercise).

Has anyone reached out to Jean Feldman on this topic or has anyone seen a FAQ that addresses the practicalities of the language change in the GPG?

“(v) Participant Support (Line F on the Proposal Budget) This budget category refers to 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.

The number of participants to be supported must be entered in the parentheses on the proposal budget. These costs also must be 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.

Funds provided for participant support may not be used for other categories of expense without specific prior NSF written approval. Such requests must be submitted electronically via use of NSF’s electronic systems.”

Note that the language regarding CFR 200.75 is new, and not in last year's GPG.

“(v) Participant Support (Line F on the Proposal Budget) This budget category refers to costs of transportation, per diem, stipends and other related costs for participants or trainees (but not employees) in connection with NSF-sponsored conferences, meetings, symposia, training activities and workshops.26 (SeeGPG Chapter II.D.8) 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.
The number of participants to be supported must be entered in the parentheses on the proposal budget. These costs also must be justified in the budget justification section of the proposal. Some program solicitations may have special instructions for treatment of participant support.
Indirect costs (F&A) are not allowed on participant support costs. Additional information on the charging of participant support costs to an NSF award is available in AAG Chapter V.B.8.”

The specific definition of participant support costs for ALL federal assistance (grant) programs, as of December 2014 is:

"direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on the behalf of participants or trainees (but not employees) in connection with conferences, or training projects."

Thanks!
Trish Brock
***************************
Grants Analyst, CPRA
Grants Development Office
Cal Poly, Bldg 38, Room 152
805-756-1450
***************************

Upcoming out of office days:
Thursday, February 5th, 2015

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 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.healthresearch.org (click on the
 "LISTSERV" link in the upper right corner)

 A link directly to helpful tips:  http://tinyurl.com/resadm-l-help
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