Trish,

Jean addressed this yesterday on the webinar. You would need to carefully
justify anything in the "other" category of participant support.

I would suggest that you email your specific question to xxxxxx@nsf.gov.
Jean encouraged us to send questions there. You can use your answer as
justification for your PI. :-)

Carolyn

-----Original Message-----
From: Research Administration List
[mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Trish Brock
Sent: Wednesday, January 28, 2015 10:56 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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 via our web site at http://www.healthresearch.org (click on the
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