Lacey,

I do believe that NSF allows for participants to be paid as an hourly wage or via a stipend.  Regardless of how the participants receive their funding, I think the critical concern is that F&A may not be charged for either category.  Many universities' financial systems are not set up to exclude participant hourly wages from F&A, However, others may have an established expense code for participant hourly wages, which does exclude F&A.

You may wish to utilize this information in the decision as to how your institution chooses to provide the participants with these funds.

Bobbie Ursin
________________________________________
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> on behalf of Megan Roth <xxxxxx@ACU.EDU>
Sent: Friday, June 5, 2020 8:11:03 AM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] Participant Support Costs via payroll systems

Because we can’t issue a w-2 and 1099 to the same person, students who have other campus employment receive their training stipends through payroll. However, we DO have a separate accounting code that is used for the stipend payments so those can be tracked separately.

On Fri, Jun 5, 2020 at 8:42 AM Rhea,Lacey N <xxxxxx@ufl.edu<mailto:xxxxxx@ufl.edu>> wrote:
Hello all –

I have always lived by the simple understanding that participants can’t be employees.  With that in mind, the attached REU FOA has a statement that I’d like to discuss (see page 6):

The REU experience is a research training experience paid via a stipend, not employment (work) paid with a salary or wage. In this
case, the student's training consists of closely mentored independent research. For administrative convenience, organizations may
choose to issue payments to REU students using their normal payroll system. The funds received by students may be taxable income
under the Internal Revenue Code of 1986 and may also be subject to state or local taxes. Please consult the Internal Revenue Service
(IRS) for additional information. Students might find the IRS's "Tax Information for Education" website to be particularly helpful.

I take this to mean that an institution may elect to process PSC payments via their payroll system as a delivery mechanism.  However, I would expect that there be some thought put into how this is managed, and that the PSC should be distinguishable from a non-participant employment relationship (by a specific job code for instance).  I do not think this means that the institution can hire participants as, for instance, an hourly student assistant entering nominal hours to reach a certain dollar amount.

In my research of how other institutions handle PSC, I came across two which seem to have very clear policy:

-          Berkeley (https://controller.berkeley.edu/financial-operations/accounts-payable/guidelines-processing-and-recording-participant-support-costs)

-          University of Utah (https://fbs.admin.utah.edu/compliance-oversight-and-reporting/pscg/)

Is there anyone from these institutions who would be willing to discuss?  Does anyone else have thoughts on this?  Or clear policies/procedures they can share?

Thank you.
_______________________________________________________________________________­­­____________
Lacey Rhea |Research Administration Manager|CLAS Department of Physics|University of Florida|2001 Museum Rd<https://www.google.com/maps/search/2001+Museum+Rd?entry=gmail&source=g>,
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