Hi Rebecca,

We would not consider a direct transfer of PSCs allowable, if I understand the scenario given (paying educators / trainers to provide instruction). The registration fees would have to be collected (as program income, if your institution is the provider) and then the instructors paid out of that. The PAPPG discusses program income here: https://www.nsf.gov/pubs/policydocs/pappg18_1/pappg_8.jsp#VIIID (there are additional reporting requirements).

PSCs in our interpretation from the guidance we've received can't be used to support speakers / trainers at workshops. They can only be used to directly support the participants themselves (lodging, registration fees if applicable, travel, stipends in certain cases). Whether the speakers / training providers are also university employees or not doesn't yet enter in -- although, of course, employees also cannot be supported with PSCs. The idea is that the participants who are supported aren't providing any goods or services in return for the educational experience -- they are being supported for learning alone (to show up and be sustained for the duration of the experience). That said, REU students are a special case in that they can be supported by a stipend while learning (this does not make them an employee, per NSF's 2017 Newsletter -- see below).

NSF writes of PSCs in the current PAPPG: "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." One way to think of why PSCs are restricted in this way: The F&A waiver on any cost item is a burden on participating institutions (they aren't recovering costs otherwise permitted on a federal grant), so NSF is restricting how much the program cuts into that support (at the same time it is ensuring that the core purpose of the program gets the most bang for the federal buck). Paying educator / trainers out of PSCs would increase the burden, so that's not allowed. Per our SPA office, educational materials and supplies for participants are also not covered under PSCs.

All the best,
Kelly

NSF Newsletter, Vol. 1 (2017)

Q: We are preparing a
Research
Experiences for Undergraduate
Research
 (REU) proposal. Is it
acceptable to categorize students
as both employees and participants
if we have made the appropriate
determination?
A: No, the REU program is different
in that the goal of the program is
to provide a practical educational
experience for undergraduate
students, rather than simply a job.
The role of an REU student differs
from the role of a student employee
because the REU program is aimed
at developing the students’ research
skills and providing a high-quality
mentoring experience. Based on this
role, an REU student is considered
a participant in a training activity
and funds for their support should
be included as a stipend in the
participant support cost section of
the budget.

https://www.nsf.gov/bfa/dias/policy/newsletter/may_2017.pdf

-----Original Message-----
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Rebecca Larrow
Sent: Thursday, July 12, 2018 11:46 AM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] Allowability on Participant Support - NSF

Good Afternoon All,

I am looking for any and all input as we are working on best practices in our office and would love to know how you would handle this situation.

On an NSF REU award - specifically the participant support portion - would you consider it allowable to pay registration fees for a workshop for GRE prep training for participants directly to faculty members by way of disbursements charged against the participant support portion of the award?

On one hand, I look at it as similar to paying for the participant to go to a conference, but on the other hand there are strict guidelines about employees of the grantee institution not being paid from the participant support portion of the award. Would it be allowable if the workshop was hosted by someone who was not employed by the university? Would you encourage the PI to charge to the main account versus the participant account?

I *think* I know what I would do in this situation but would love to have opinions/ideas and other perspectives on whether you would or would not allow it.

I look forward to hearing your responses! Thank you in advance.

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