DIVISION OF RESEARCH NSF Participant Support Costs – Proposal Preparation and Award Management

1. DIVISION OF RESEARCH NSF Participant Support Costs – Proposal Preparation and Award Management Fall 2008

2. Agenda • Background • Definitions • Who qualifies as a participant? • What are participant support costs? • Restrictions • Proposal preparation & budgeting • Account set-up • Account management • Monitoring

3. Background • Participant support is often provided when NSF funds a project or activity in connection with formal meetings, conferences, symposia, or training programs (i.e. REU, RET, K-12, LSAMP) • When Clarkson accepts an award we have agreed that NSF funds provided for participant costs will be separately accounted for, and expended for appropriate and intended purposes. • Participant support costs are being audited with increased scrutiny. • Institutions are required to maintain written policies and procedures

4. Who qualifies as a participant? • Participants are individuals who are recipients of or benefit from a service, training, or experience in connection with formal meetings, conferences, symposia, or training programs. • Participants are not required to deliver any deliverable or service to the University in return for participant support costs. Participants do not include Clarkson University employees (faculty and staff). • Participants may include students, national scholars and scientists, private sector representatives, agency personnel, teachers and others who attend and participate in a formal conference, workshop, or training activity. Project staff or general collaborators on a research project do not qualify as participants. Examples of projects or activities that include participants: Research Experience for Undergraduates (REU) Education Outreach (K-12) Louis Stokes Alliances for Minority Participation (LSAMP)

5. Participant Eligibility • What did participants have to do to receive the payment? • Documentation of attendees at conferences or workshops is needed.

6. What are participant support costs? • Participant support costs are cost paid to (or on behalf of) participants or trainees (but not employees) in connection with formal meetings, conferences, symposia, or training programs. • These costs include stipends or subsistence allowances, travel allowances, supplies, and registration fees paid to or on behalf of the participants or trainees.

7. What are participant support costs? • Participants may not be reimbursed for participant support allowances if they are receiving compensation from any other federal government source while participating in the project. • Local participants may participate in meals and snacks provided at the meeting or conference, however, are not entitled to subsistence payments.

8. What are participant support costs? Participant support costs do not include: • Payments made to research subjects as an incentive for recruitment and participation in a research project. • Honoraria paid to a guest speaker or lecturer. • Conference support costs such as facility rentals, media equipment rentals, or conference food. • Costs that cannot be specifically identified to a participant(s).

9. Proposal Preparation & Budgeting • Proposals that include participants may include participant support costs in the proposed budget, provided that the: • number of participants to be supported is included in the proposal budget • proposal includes justification for the costs • Note that some programs may have special requirements on how these costs are treated (i.e. REU, RET).

10. Restrictions Participant support costs are generally restricted by the following requirements: • Participant support costs cannot be re-budgeted into other categories without prior sponsor approval. • Indirect (F&A) is not allowed on participant support costs. • Typically, an administrative allowance of 25% is allowed, but only on stipend support (REU, RET). • Any unexpended participant support costs must be returned to the sponsor.

11. Identifying and Accounting for Participant Support Costs • When an award includes funding for participant supports costs, a primary fund for all awarded costs will be established, except for the participant support costs. • Participant support costs will be established in a separate sub-account, related to the primary account in order to keep participant support costs separate, restrict budget changes, and avoid charging indirect costs.

12. Identifying and Accounting for Participant Support Costs Participant support sub-accounts will differentiate the types of costs using the following object codes (account code):

13. Identifying and Accounting for Participant Support Costs • Principal Investigators must expend participant support funds as specified by using the appropriate sub-accounts and object codes. • Current NSF awards that were originally budgeted using the participant support object codes 2580 and 2581 will continue to do so until the end of the budgetary or project period. • When an award is accepted by the University that includes participant support costs, the Principal Investigator will be notified of any specific restrictions governing the expenditures of these funds. • Participant Support Costs require approval by the DoR (excludes p-card)

14. P-Card Reconciliations Involving NSF Participant Support Costs • “Expense Descriptions” should indicate the benefit to the project or scope of work (i.e. How did the purchase benefit the participant(s), What is the purpose of the item?). • Remember to proportionally charge expenses used for more than one project or educational activity. • Use the appropriate object code (account code) • Proper “Expense Descriptions” and object codes will minimize the need for Accounts Payable to request additional information (i.e. Direct Cost Justification Form) • This methodology also applies to purchase requisitions, disbursement orders, and travel expense accounts.

15. Participant Food & Beverage Charges • Highly scrutinized by auditors and requires adequate documentation when appropriate. • Generally unallowable when not on travel status.

16. Participant Food & Beverage Charges Allowable Charges • Food and beverages may be allowable if allthe following tests are satisfied: • Food and beverages are not considered entertainment. • Food and beverages are incidental to the activity. • Activity is integral to the goals of the award (should be part of the original proposal). • Costs of the food and beverages are considered reasonable.

17. Participant Food & Beverage Charges Allowable Charges must be justified with documentation (p-card expense descriptions, email, etc…): • Explain how the activity is significant and integral to the goals of the project? • Provide any available supporting documentation such as, an activity invitation or announcement that describes the activity purpose, agenda, attendee roster, or reference that it is explicitly in the proposal.

18. Participant Food & Beverage Charges • If allowable, charges for Clarkson employees must be allocated outside of participant support costs (2543 Food Service Other) • If using Aramark, notify Betsy Niles in Accounts Payable ahead of time by email to avoid receiving a Direct Cost Justification Form.

19. Monitoring Periodically, the Comptroller’s Office will query all NSF awards that have participant support account codes budgeted, review the following below, and notify the PI if the account warrants review and/or re-budget: • Budget will be compared to the actual transactions • Rate of transactions • Transactions posted During close-out the Comptroller’s Office and DoR will: • Reconcile the budget to actual transactions • Verify that the prior sponsor approval from NSF was documented, if re-budgeting occurred • Ensure that indirect costs were not assessed on the participant support costs • Return unspent funds to NSF, if needed

20. DoR Contact Information Greg Slack Director of Research and Technology Transfer gslack@clarkson.edu ext. 6475 Todd Travis Award Administrator (Pre-Award) ttravis@clarkson.edu ext. 6475 Connie Ferguson Contract & Grant Administrator (Post-Award) cferguson@clarkson.edu ext. 6475 Kimberly KlattResearch Compliance Officer kklatt@clarkson.edu ext. 4441

21. DoR Contact Information Adele Pugliese Sr. Dept. Secretary (MAE, ECE, PPAS, IACUC) apugliese@clarkson.edu Billi Jo GoodfellowSr. Dept. Secretary (CAMP, CBE, BIO, PSY, C&M)bgoodfellow@clarkson.edu Norma WoodsAdministrative Secretary (CAMP, CBS, PT, CEE )nwoods@clarkson.edu Heather Kish Sr. Dept. Secretary (CUSB, PHY, MCS, HSS, IRB) hkish@clarkson.edu

22. Comptroller’s Office Contact Information Jim Fish Comptrollerfishj@clarkson.edu ext. 6689 Donna Martell Associate Comptrollerdmartell@clarkson.edu ext. 7258 Sue Scott Chief Accountant scotts@clarkson.edu ext. 6407 Kelly Rathbun Research Accountant krathbun@clarkson.edu ext. 6462 Elizabeth Corbine Accounting Assistant (P-cards) ecorbine@clarkson.edu ext. 3789

23. Comptroller’s Office Contact Information Roberta Chestnut Accounting Assistant (POs) rchestnu@clarkson.edu ext. 3789 Betsy Niles Head Cashier (Aramark) nilesbm@clarkson.edu ext. 6486 Sarah Ellis Accounting Assistant (DOs/Travel) sellis@clarkson.edu ext. 3789 Karen Barrett Endowment/Plant Accountant (Fabrication) kbarrett@clarkson.edu ext. 7650

24. QUESTIONS?