travel costs uniform guidance

Colorado State University

Vice president for research, office of sponsored programs, frequently asked questions about uniform guidance: general and allowability.

• January 28, 2020

A recent webinar on Uniform Guidance yielded a slew of questions. A number of those questions have been grouped into major topics of concern and addressed below. Due to the sheer number of questions asked, this first blog will address general questions and allowability. Next week’s blog will address effort reporting, F&A, participant support costs, purchasing, and subawards.

Where is the best digital version of the Uniform Guidance (UG) available?

The version found on govinfo can download as a PDF or in XML. It can also be accessed from Grants.gov which takes you to the version in the e-CFR (electronic Code of Federal Regulations). For the most up-to-date, go to the Federal Register (downloadable as a pdf).

What are the parts of UG most commonly referred to/used to in daily research administration?

The answer to this question may depend on where you sit in the lifecycle of an award (pre- or post-award) and if you are in a central unit or department. For Tricia as a trainer, I often refer to Subpart A (definitions), Subpart D (post-award requirements) and Subpart E (cost principles).

What’s the difference between uniform guidance and NIH grant policy?

Uniform Guidance is guidance to the Federal awarding agencies on administrative requirements, cost principles, and audit requirements for Federal awards. Once the Federal agencies codify these guiding principles they become agency regulations. Therefore, the NIH grant policy document is NIH’s codification of Uniform Guidance and should be followed for NIH awards.

The Department of Education regulations used to be EDGAR (Education Department General Administrative Regulations). Was EDGAR replaced by Uniform Guidance?

EDGAR (Education Department General Administrative Regulations) was amended after the Uniform Guidance was published and the U.S. Department of Education now points to Uniform Guidance for much of its guidance, though parts of EDGAR are still applicable.

Is it possible to discuss briefly Appendix IX that applies to Hospitals? Why is the difference between academic institutions?

Personnel appointments in hospitals are different than in academic settings and many of the “other hospital activities” are not allowable costs under Uniform Guidance. Additionally, there are patient care costs that you may not see at an Institution of Higher Education that is addressed in Appendix IX and credits (insurance, etc.) that must be taken into consideration in a hospital setting. Finally, the “A” portion of F&A (Facilities & Administrative) costs is not capped for hospitals like it is for institutions.

The order of Precedence that I’ve seen is the following. Is this correct?

• Applicable Laws
• Code of Federal regulations
• Standard Terms and Conditions
• Award Specific Terms and Conditions
• Other documents and Attachments

Law always trumps all else. If you cannot by law engage in an activity (such as hemp research), then it doesn’t matter what award terms or Uniform Guidance say. Typically, the most restrictive law wins, though there are exceptions. Research using alcohol is an exception. While Uniform Guidance says that alcohol is typically an unallowable charge (meaning you cannot reimburse meals that include alcoholic beverages), you may be able to purchase alcohol for a research study.

How often is the Uniform Guidance updated?  Where do we find updates?

Uniform guidance is reviewed every 5 years after the initial December 26, 2013 date (2 CFR 200.109). Updates are published in the Federal Register. Always consult the on-line version for the most up-to-date information. For the most up-to-date, go to the Federal Register (downloadable as a pdf).

As a manager, what are some ways that I can increase exposure to/increase the use of Uniform Guidance for my staff? What would be best practices for ‘getting to know’ the Uniform Guidance?

You can start by sharing the free webinar and these frequently asked questions with your staff. You can also create a Uniform Guidance scavenger hunt for your staff. Also, cite any references to Uniform Guidance in communications and training as applicable.

How do the FAR and Uniform Guidance overlap?

The Federal Acquisition Regulation (FAR) establishes rules and requirements that Federal agencies must follow when procuring goods and services. The Uniform Guidance (UG) establishes requirements that must be followed by grantees when procuring goods and services needed to carry out a Federal award.

What’s new for Uniform Guidance in 2020? Could you include changes over the years?

The newest changes are in Procurement and Audit Requirements. For the most up-to-date, go to the Federal Register (downloadable as a pdf).

ALLOWABILITY

Is an Airbnb allowable on federal awards?

Allowability of an Airbnb for travel supported with federal funds is not addressed. Uniform Guidance instructs that housing/travel costs are allowable as direct costs if reasonable and necessary and approved in advance by the Federal awarding agency. See more under 2 CFR 200.474 (Travel costs). As always, follow the travel rules of the agency/program and of your institution.

Is space rental for institutional space allowable?  All departments on campus charge for space not used for instruction.

Yes, space rental for institutional space is generally allowable. Double-check sponsor/program guidelines as some may consider rent or space unallowable. Also, ensure that space is not part of the indirect cost base if charging as a direct cost.

Is alcohol allowed if the sponsor says okay to it?

Yes, alcohol used in research is generally an allowable charge as long as there are no state or local laws that state otherwise.

What does Uniform Guidance say about managing unallowable purchases, especially when there is no place to put the charges?

This is something each institution must have a way of handling and is not specifically addressed in the Uniform Guidance other than to say that costs determined as unallowable may not be charged to a Federal award, and if they are, must be reimbursed. Also, institutions are directed to have a way to segregate and account for unallowable costs. For best practices, consider asking this question on RESADM-L ( https://www.healthresearch.org/office-sponsored-programs/research-administration-listserv/ ).

Please talk about the Fly America Act as it pertains to flights to/from Canada.

Fly America Act is not specifically addressed in the Uniform Guidance. However, the Fly America Act requires the use of a U.S. air carrier service for all air travel and cargo transportation funded by the U.S. government. Use a U.S. air carrier for flights to/from Canada. Find more guidance here- https://www.gsa.gov/policy-regulations/policy/travel-management-policy/fly-america-act

What does Uniform Guidance say about cost-sharing?

Federal awarding agencies are instructed to include cost-share requirements in their funding opportunities. Expenses that are cost-shared must be verifiable and allowable under the award terms and conditions. Uniform guidance states that voluntary-committed cost-sharing is not expected and cannot be used as a factor during the merit review process. See 2 CFR 200.306 for more on cost-sharing.

How does your organization deal with supplemental compensation?

Uniform guidance instructs us to follow institutional policies for supplemental compensation and instructs us to establish a consistent written definition of work covered under our definition of Institutional Base Salary (IBS). Our institutions discourage supplemental compensation during the contracted time.

Can you provide guidance compensation allowability – vacation leave payout, overload/extra pay, job announcements, and background checks?

Fringe benefits, including vacation, are allowable (2 CFR 200.431).

Overload/extra pay is addressed in 2 CRA 200.430. There are extensive guidelines for extra pay (see 2 CFR 200.430(h)(3) and (4)). Supplemental pay should not exceed Institutional Base Salary (IBS) and must follow established written institutional policy and consistently applied to both Federal and non-Federal activities.

Job announcements for grant-funded positions are allowed (unless the sponsor or guidance says differently). See 2 CFR 200.421(b)(1).

Background checks would be allowable if they are part of the non-Federal entity’s standard recruitment program. See 2 CFR 200.463(a).

We require detailed receipts for all travel meals to make sure no alcohol has been purchased and PIs are asking why we don’t use a per diem policy. Which is more prevalent?

We don’t know the ratio of institutions using per diem versus those that pay actual expenses. Based on experience, state institutions are more likely to use a state per diem rate while private institutions may reimburse for actual expenses. If reimbursing actual expenses, requiring receipts to ensure alcohol is not charged to a federal award is a best practice and it is up to the institution to decide if they want to pay for alcohol from non-federal funds.

Is there a sample allocation plan to guide the conversation for computer devices with PIs?

A sample allocation plan is not provided in Uniform Guidance. For sample plans, consider asking this question on RESADM-L ( https://www.healthresearch.org/office-sponsored-programs/research-administration-listserv/ ).

Are membership allowed as a direct charge on awards?

Memberships, subscriptions, and professional activity costs are generally allowable as direct costs. Costs of memberships to social or dining clubs are generally unallowable. See 2 CFR 200.454.

What about direct charging dean’s or director’s salaries if they are providing “technical contributions”?

Administrative services are allowable if they meet all of the following conditions:

• Services are integral to the project/activity
• Individuals can be specifically identified with the project/activity
• Costs are included in the budget or have prior written approval
• Costs are not recovered as indirect costs

Can unrecovered F&A (Facilities & Administrative) costs and/or fringe that were included in the originally accepted budget carryover to subsequent years and used for other line items in the budget?

If the agreement allows for carryforward, the amounts could be carried forward to the next project year. Depending on budgeting restrictions, the unrecovered fringe may be able to be added to other direct cost budget lines and the F&A would carry forward as well. 

F&A is a percent of expenses, so it would be the same percent in the second year as it was in the first and if you are increasing the direct costs (by carrying forward unused budget), you would need to carry forward F&A from year one to two to cover that. 

I heard on computers, people are splitting between a grant and unrestricted funds (unobligated funds).  Ninety percent (90%) grant and ten percent (10%) unobligated funds so they have not cost-shared. Thoughts?

This isn’t necessary as computing devices can be charged as direct costs if they are essential to the project. They do not have to be solely dedicated to the performance of the Federal award. See 2 CFR 200.453.

_______________

For more Uniform Guidance FAQs, visit: https://cfo.gov/wp-content/uploads/2017/08/July2017-UniformGuidanceFrequentlyAskedQuestions.pdf

Blog post by Tricia Callahan, Senior Research Education and Information Officer, Office of Sponsored Programs and Shannon Sutton, Director of Sponsored Projects, Western Illinois University.

Part 200 - Uniform Administrative Requirements, Cost Principles, And Audit Requirements For Federal Awards

PART 200 - UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS Authority: 31 U.S.C. 503 Source: 78 FR 78608, Dec. 26, 2013, unless otherwise noted.

• Authority: 31 U.S.C. 503
• Source: 78 FR 78608, Dec. 26, 2013, unless otherwise noted.

Travel on Non-Federal Sponsored Awards

Review the Award and sponsor regulations to determine the requirements for approval and allowable travel-related expenditures. Most sponsors require that travel be in accordance with the recipient's (UW's) travel policies. If this is the case, see the UW Travel website for more information.

Travel on Federal Sponsored Awards

Travel is a high risk expenditure on Federal awards. Some requirements differ from those of the UW, and expenses are routinely subject to Federal agency review. The information below identifies federal requirements and Best Practices for travel on a federal Award. The Federal Uniform Guidance reference for travel is section 2 CFR 200.475 "Travel costs" .

Travel Approval/Review

The Federal Uniform Guidance and most agency-specific regulations do not require sponsor approval for domestic or international travel. However, always review the Award and agency regulations to determine if there are any specific approval requirements.

While the Federal regulations may not specifically require approval, written sponsor approval minimizes the risk of travel expenses being questioned by the sponsor during or after Award implementation. Documentation of the need for travel, and careful management of travel funds, are best practices for avoiding challenges to travel expenses after the fact.

Document Need for Travel

Itemize and describe the need for travel in the proposal and proposal budget .

If the travel is not itemized in the proposal:

• Notify, in writing, the sponsor of the need for travel, even if their approval is not required. 
• Document how the unbudgeted travel will benefit the award. Documentation can be part of the sponsor notification or in separate documentation retained with the travel expenditures.
• Include how the travel benefited the award in subsequent sponsor-required programmatic or progress reports . 

Manage Travel Budget

• Keep travel expenditures within the Travel budget. Expenditures in excess of the budgeted amount may be questioned, even if the adjustment is within the rebudgeting authority allowed to the recipient (UW).
• If travel is unbudgeted, or actual travel expenses exceed the budget line item, be sure to document, ideally in a progress report, how the travel benefited the Award, and from which line item the funds were rebudgeted.  

Timing/Personal Travel

The travel must take place between the start and end dates of the Award. Travel cannot take place after the end of the Budget Period/Award, even if the travel is directly related to the Award. The cost of any airfare purchased during the budget period for travel that will take place after the budget period is unallowable. See  PAFC's Expenditure Timing page  for more information.

The length of the trip must coincide with travel objectives. Any additional time added to a trip is considered personal time, and related costs cannot be allocated or charged to the Award. The UW Travel webpage has information on how to allocate personal travel time or expenses.

Commercial Air Travel (Airfare)

The Federal Uniform Guidance (2 CFR 200.475) states that Federal regulations must be followed for airfare purchases. Unlike for other travel expenditures (e.g., per diem), Federal regulations do not allow a recipient’s (UW’s) established policies to supersede the Federal regulations for airfare.

As always, individual Federal agency regulations supersede the Federal Uniform Guidance. Review the Award and individual Federal agency regulations to ensure compliance with airfare purchases. Some Federal agencies have regulations that are more restrictive than the Uniform Guidance. Information on select Federal agency regulations is provided at the end of this page.

Fly America Act

Unless exempted in writing, all airfare on Federal awards must comply with the  Fly America Act  (FAA). Compliance with the Fly America Act (FAA) includes allowances for itinerary-specific exemptions and for eligible flights under both airline code share agreements and the Open Skies Agreements (which is part of the FAA), both of which are updated on a routine basis. Thus, compliance for individual flights can only be determined with access to all available flight options and up to date information on Code Share and Open Skies agreements. As the PAFC team does not have this capacity, the best option is to work with a UW travel agent to ensure compliance . The UW Travel website has information on UW Travel agents.

Class of Travel

Travel must be taken using the least expensive class of travel, more commonly known as “ economy .” This is regardless of the total travel time from point of departure to final destination or duration of flight(s).   

The Federal regulations do provide some exemptions for this requirement, which can be found in 2 CFR 200.475 (e) . Departments should review these exemptions and determine if their travel needs meet any of these exemptions. Keep in mind that individual Federal agency sponsors can make a determination if the use of any exemptions is reasonable and prudent. 

Note that under the Federal Uniform Guidance, total travel time in excess of 14 hours is NOT listed as an exception for the least expensive class of travel. This exception is listed as part of the Federal Travel Regulations (FTR), but Federal sponsored awards are subject to the Uniform Guidance and not the FTR. There is no exception to travel in other than coach or economy class based solely on the length of the trip.   

If a traveler purchases airfare other than in the least expensive class of travel, the portion of the cost of the airfare that is in excess of the least expensive class of travel is not allowable on a sponsored award.

If any of the exemptions to the Federal travel regulations are used:

• Include the anticipation of and the reasoning for any exemptions in the proposal.
• Clearly document the use of any exemptions and rationale for their use. Retain this documentation with the travel expenditures so it can be easily retrieved if questioned by the sponsor.

Type of Ticket

The least expensive unrestricted airfare is allowable. Unrestricted airfare allows for cancellation or changes with a penalty value that is less than the cost of the ticket.

Airfare purchased on a restricted fare is allowable as long as the ticket is used. If the restricted ticket is not used, then the cost of the ticket is unallowable.

Any fee paid to obtain a more desirable seat is considered to be the traveler's personal choice and therefore is not allowable on a federal award. Seat fees paid using non-federal awards must follow UW Travel policy .

Non-Commercial Air Travel

The cost of non-commercial air travel (e.g., leased or chartered aircraft) includes the cost of lease, charter, operation (including personnel costs), maintenance, depreciation, insurance, and other related costs. The use of this type of travel, in lieu of commercial air travel, must be justified as being reasonable (i.e., commercial air travel is unavailable). If commercial air travel is available, then the cost of non-commercial travel in excess of commercial travel is unallowable.

Travel Other Than by Air

Federal regulations require that travel be taken by the most direct and expeditious routing, which typically involves, when available, commercial air travel. If commercial air travel is available but the traveler wishes to travel by another means (e.g., vehicle, bus, train), any cost for this conveyance that is above the cost of commercial air travel is unallowable.

For example: The traveler is traveling from Seattle to San Francisco. The cost of the least expensive unrestricted economy airfare plus the cost of transportation to/from the airports is $500. The traveler elects to take the bus to San Francisco and the cost of the bus fare plus transportation to/from the bus station is $300. The routing via the bus would be allowable as the total cost is less than the total cost via airfare.

Best Practices

• Purchase airline tickets through UW contract travel agents to ensure FAA compliance and take advantage of any negotiated fare agreements.
• If personal time is added to a trip, ensure that the cost allocations are clearly documented and any personal-related costs are not allocated to the Award.

The Federal Uniform Guidance allows for the use of the recipient’s (UW’s) established policies and practices for Per Diem. See the UW Travel page on Per Diem for information.

• Any meals that are reimbursed directly instead of included in the per diem allowance must be within the meal allocation for the per diem rate. This includes any meals for the traveler as well as meals paid by the traveler for other people.
• Conference centers may charge lump sum amounts for lodging, meals, and conference fees. In this case, an itemized list of each expenditure must be obtained from the conference center. This is to ensure that the cost for meals and lodging does not exceed the allowable per diem amounts. 

Agency-Specific Regulations

As always, an Agency’s specific policies supersede the Uniform Guidance, and any Award-specific Terms and Conditions supersede agency regulations. Below are links to Federal agency regulations on travel:

NSF Proposal & Award Policies & Procedures Guide (PAPPG): Section II.C.2.g. (iv)

NIH Grants Policy Statement (GPS): Section 7.9, see “Travel/Employees”

Post Award Fiscal Compliance email: [email protected]

For questions and issues relating to Effort Reporting, email: [email protected]

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• Participant Support Costs Guidance
• Issued: March 2022
• Revised: May 2023
• Responsible Office: Office for Sponsored Programs
• PDF version of Participant Support Costs Guidance

Participant Support Costs as defined by 2 CFR §200.75 , 200.456 , are 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 conferences, or training projects (note that participant support costs do not apply to NIH training grants).

Participant support costs (PSC) are a restricted budget category frequently proposed on National Science Foundation (NSF) awards. Other sponsors may vary slightly in their definitions and restrictions for participant support costs. Participant support costs defined under this guidance should not be confused with costs associated with participants in a clinical trial or research project, such as incentive or human subject payments.  Similarly, this guidance does not apply to participants in courses or conferences that are expected to produce a deliverable or provide a benefit to the research outlined in the project scope of work

Applicability

This guidance applies to federal funding and individuals that are in the role of receiving instruction or training from a federal award.

Roles and Responsibilities

Department/local level managing unit.

Local units are responsible for developing proposals and managing awards in compliance with this guidance and the guidance provided by the sponsor regarding Participant Support Costs. This includes coordination with the PI and OSP/ORA. Local units assume the primary responsibility for posting relevant Participant Support Costs and retaining related documentation/records in accordance with the terms of the award and Harvard policies. 

Principal Investigator (PI)

The Principal Investigator is responsible for working with the local unit to communicate the needs of the project and budget and is ultimately responsible for the charges on the federal award.

Office for Sponsored Programs/Office of Research Administration (OSP/ORA)

The submitting offices are responsible for ensuring participant support costs are appropriately budgeted and if awarded (via initial request or revision), setting indicators in the GMAS system. ORA and OSP should serve as a resource to the local unit and submit prior approvals to the sponsor if necessary.

Defining and Charging Participant Support Costs

To correctly propose participant support costs in a federal funding application, it is important to review the program announcement carefully and consider the following information.

Who is a participant?

A participant is defined as a person who is the recipient, not the provider, of training associated with a workshop, conference, seminar, symposium, or other short-term instructional or information sharing activity. Participants are not required to provide any deliverable to the University, and they are not subject to Harvard human resources policies (e.g., they cannot be terminated for failure to perform).

Participants may include students, scholars, and scientists from other institutions, representatives of private sector companies, teachers, and state or local government agency personnel. A person classified as an intern would be paid as an employee and not as a participant, because the intern, while receiving certain training, is also providing services.

Who is not a participant?

• Employees of the University 
• An employee of the sponsor
• Advisory Board members
• Interns who have paid appointments
• Anyone who has a deliverable or is primarily providing a service to the project.

What types of sponsored projects may include participant support costs?

Participant support costs are typically incurred for projects that include an education or outreach component. Participant support costs are allowable with prior sponsor approval, per the Uniform Guidance. These types of costs are most commonly included in National Science Foundation (NSF) grants, such as the following programs:

• Research Experiences for Undergraduates (REU)
• Research Experiences for Teachers (RET)
• National Research Traineeship (NRT)
• Research Training Groups (RTG) in Mathematical Sciences
• Integrative Graduate Education and Research Traineeship Program (IGERT)

Note:  Other federal and non-federal sponsors may allow participant support costs under some circumstances. Refer to the funding announcement for specific instructions.

What costs may be included as participant support costs?

Participant support costs include expenditures for items such as the following:

• Stipend  (object codes 6440, 6450, 6452, 6455):   A stipend is a set amount of money to be paid directly to the participant in connection with a short-term training activity. Note that short-term means the appointment period approved by the sponsor. Individuals receiving stipends under participant support costs must be paid as a stipendee and not an employee.
• Travel (object codes 7651, 7652, 7653, 7654, 7671, 7672, 7673, 7674): Travel includes the costs of transportation and associated costs and must follow sponsor guidelines (e.g., US flag carrier, coach class, most direct route) as well as Harvard’s travel policies and guidelines. The sole purpose of the trip must be to participate in the conference or training activity. If a training activity involves field trips, the cost of transportation for participants may be allowable.
• Subsistence Allowance : The cost of a participant’s housing and per diem expenses necessary for the individual to participate in the conference or training activity are generally allowed, provided these expenses are reasonable and limited to the days of attendance. This includes registration fees. Although they may participate in meals and snacks provided at the meeting or conference, participants who live in the local area are not entitled to subsistence payments. Please note that catering (object code 8060) is not a permissible expense.
• Fees : The fees paid by or on behalf of a participant in connection with meetings, conferences, symposia, or training projects are generally allowable costs. Additionally, these fees may include laboratory fees, and passport or visa fees for foreign participants.
• Other : Certain costs in support of the participant’s involvement may be allowable, including training materials, printing costs for presentation materials to be distributed at a conference, laboratory supplies and services that can be tied to specific participants. Please note that supplies for participants are allowable, whereas general conference supplies must be charged to the non-PSC account. See procedures document for additional guidance on accounts. Check the funding announcement for guidance.

What costs cannot be included as participant support costs?

• Incentives/prizes, memorabilia, or gifts, unless the cost is specific to the project, sufficiently justified at the proposal stage, and approved by the sponsor. For questions on the approved budget, please reach out to your pre-award administrator.
• An incentive payment to encourage an individual to participate as a human subject in a research study is not a participant support cost and should be budgeted as an “other direct cost” bearing full overhead.
• Honoraria or fees paid to a guest speaker or lecturer
• Conference/workshop support costs such as facility rental, building services, video recording, audio transcription, program printing, catering, supplies, or media equipment rental
• Subaward to a provider for multiple training events (i.e., an ongoing contract with specific terms and conditions)
• Agreements with employers (e.g., public school system) to reimburse the employer for the costs related to sending its employee to a conference or workshop. It is recommended that the PI inform participants prior to the initiation of the project about any costs associated with their participation in the project that are not covered.
• Expenses for collaborators to meet at a single destination and discuss a research project’s progress and direction. Such expenses should be budgeted under travel or other expenses as allowed by the sponsor
• Costs for collaborators to attend project meetings, conferences, or seminars

Expense Allowability

For a direct cost to be charged to a sponsored award, the cost must comply with terms and conditions of the award, federal regulations, and Harvard Policy.

For participant support costs to be allowable:

• The costs must be programmatically justified;
• The costs must be explicitly included in the budget and the budget is approved or prior written approval is received from the Federal awarding agency; and
• The expense does not take indirect costs.

For costs to be classified as participant support costs, they must support the participant’s engagement in the activity. The project may incur costs that are allowable on the award, but do not qualify as participant support costs; these costs should be budgeted and expensed on accounts bearing full overhead.

The “other” category under participant support costs must be specific and justified to be allowable. For NSF, costs included under this subcategory may be related to community building activities, lab supplies and services. 

It is not appropriate for a person to be a participant on the project and perform work on the same project at the same time. Participants do not perform work or services. An individual cannot be classified as a participant and an employee in the same budget period. If the project spans years, it is possible that the participant’s role may evolve as the scope of work shifts in the later years of the project. If this happens, the change must be documented and justified.

Rebudgeting 

When is prior approval required.

Participant support costs must be budgeted in the proposal and approved by the sponsor. Approval is noted in the Notification of Award (NOA). Specifically, NSF will identify a dollar amount in the NOA under the Participant Support Cost budget category. Prior approval is required for any significant change to the scope of work.

Per CFR 200.308(c)(5) , prior approval is required to transfer funds budgeted for participant support costs to another expense category.  If rebudgeting of PSC is needed, prior approval is required depending on the action that needs to be taken.  Please reference the FDP Prior Approval Matrix and the terms of the award for guidance on sponsor-specific prior approval requirements.  As general best practice for PSC:

Prior approval is typically required if:

• Participant Support Costs will be charged and were not already budgeted and approved for the award
• Funds will be moving out of any PSC budget category and into a non-PSC budget category (For example: PSC travel costs into non-PSC Lab Supplies)
• Any other situation as specified by the sponsor

Prior approval is not typically required if:

• The rebudget is solely amongst PSC cost categories (stipends, subsistence allowances, travel and other), as long as the scope of work remains the same and the PSC category was approved prior to the rebudget (at proposal or award stage). 
• Funds are moving out of a non-PSC budget category and into a PSC budget category (so that more may be expended on PSC-related costs), as long as the scope of work remains the same and the PSC category existed prior to the rebudget (at proposal or award stage). 

As always, check the award and sponsor terms to confirm whether prior approval is needed. See the Procedures for Participant Support Costs document for more information.

Documentation

Recommended documentation.

Documentation must be retained when managing participant support costs and may vary based on scope of work or revisions to the award (prior approval or rebudget requests).

At a minimum, programmatic documentation should include:

• Sign-in sheets for participant attendance at workshops
• Documentation on supplies that are ordered or distributed to participants and how they support the participant in the project activity
• List of participants the materials are for 
• Support for allocating costs as “other” or “fees”. Please see the Sponsored Cost Allocation Methodology Guidance for information on allocating costs.

Programmatic documentation should be retained in the local unit.

Importance of Documentation

Please note that some sponsors, such as NSF, will explicitly list PSC in the notice of award budget. Other sponsors may not be as explicit. Therefore, it is crucial to maintain all communication and other documentation that would support the inclusion of PSC on the award. Procuring these documents and providing context in cases of audit or review is largely the responsibility of the department/local level managing unit. Maintaining such documentation at the department level is important to compensate for portfolio changes and employee turnover.

• Procedures for Participant Support Costs
• FDP Prior Approval Matrix 
• Participant Support Costs Informational Video (login required, approx 30 mins)
• Sponsored Expenditure Guidance
• Closeout and Reporting Policy for Sponsored Awards
• Sponsored Cost Allocation Methodology Guidance
• Participant Support Costs FAQs

May 2023: Updated FAQ #13 to reflect updated NIH Grants Policy Statement definition of Participant Support Costs that excludes R25s.

• Absence Management Guidance
• Administrative and Clerical Salaries on Federal Awards
• At-Risk Account Guidance
• Capital Equipment: Summary of Policy for Capital Equipment in Schools with Sponsored Research
• Consulting or Related Service Agreements
• Cost Sharing Policy
• Cost Transfer Policy
• Data Use Agreements
• Effort Reporting Policy
• Entering Preproposals into the Grants Management Application Suite (GMAS) Guidance
• eRA Commons Registration Requirements for Senior/Key Personnel
• Establishing an Internal Grant-Making Program
• Federal Work Study on Sponsored Awards Policy
• Fixed Price Residual Balances Guidance
• Guidance on Charging Approved Family and Medical Leaves to Sponsored Awards
• Foreign Awards Paid in Foreign Currency Guidance
• Gift vs. Sponsored Award Policy
• Indirect Costs - Policy for the Application of Indirect Costs to Sponsored Awards
• Intellectual Property
• Interest Income Paid on Non-Federal Sponsored Funds
• Interfaculty Involvement (IFI) Guidance
• International Collaborations and Activities
• International Projects Guidance
• NIH Public Access Policy
• Negotiating and Signing Authority for Agreements Related to Research
• Guidance Regarding Individuals Outside of the United States Being Paid with Sponsored Funding
• On-Campus and Off-Campus Indirect Cost Rates Policy on Federal Sponsored Awards
• Participation Agreement and Visiting Participation Agreement
• Procurement
• Program Income Guidance
• Proposal Submission Deadlines
• Provost Criteria
• Publications
• Retention of Research Data and Materials
• Service Centers: Academic Service Center Policy
• Severance on Sponsored Awards
• Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Collaborations: Guidance on Conflict Management Considerations
• Sponsored Expenditures Guidance
• Sponsored Travel Guidance
• Stipends on Sponsored Awards
• Subrecipient Monitoring Policy
• Subrecipient vs. Contractor Guidance
• Tuition Policy

• Regulations All Titles
• title 2 Grants and Agreements
• chapter II CHAPTER II—OFFICE OF MANAGEMENT AND BUDGET GUIDANCE
• part 200 PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS
• subpart E Subpart E—Cost Principles
• subjgrp 42 General Provisions for Selected Items of Cost
• § 200.475 Travel costs.

View all text of Subjgrp 42 [§ 200.420 - § 200.476]

§ 200.475 - Travel costs.

AUTHORITY: 31 U.S.C. 503

SOURCE: 78 FR 78608, Dec. 26, 2013, unless otherwise noted.

CITE AS: 2 CFR 200.475

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2 CFR § 200.447 - Insurance and indemnification.

(a) Costs of insurance required or approved and maintained, pursuant to the Federal award , are allowable.

(b) Costs of other insurance in connection with the general conduct of activities are allowable subject to the following limitations:

(1) Types and extent and cost of coverage are in accordance with the non-Federal entity 's policy and sound business practice.

(2) Costs of insurance or of contributions to any reserve covering the risk of loss of, or damage to, Federal Government property are unallowable except to the extent that the Federal awarding agency has specifically required or approved such costs.

(3) Costs allowed for business interruption or other similar insurance must exclude coverage of management fees.

(4) Costs of insurance on the lives of trustees, officers, or other employees holding positions of similar responsibilities are allowable only to the extent that the insurance represents additional compensation (see § 200.431 ). The cost of such insurance when the non-Federal entity is identified as the beneficiary is unallowable.

(5) Insurance against defects. Costs of insurance with respect to any costs incurred to correct defects in the non-Federal entity 's materials or workmanship are unallowable.

(6) Medical liability (malpractice) insurance. Medical liability insurance is an allowable cost of Federal research programs only to the extent that the Federal research programs involve human subjects or training of participants in research techniques. Medical liability insurance costs must be treated as a direct cost and must be assigned to individual projects based on the manner in which the insurer allocates the risk to the population covered by the insurance.

(c) Actual losses which could have been covered by permissible insurance (through a self-insurance program or otherwise) are unallowable, unless expressly provided for in the Federal award . However, costs incurred because of losses not covered under nominal deductible insurance coverage provided in keeping with sound management practice, and minor losses not covered by insurance, such as spoilage, breakage, and disappearance of small hand tools, which occur in the ordinary course of operations, are allowable.

(d) Contributions to a reserve for certain self-insurance programs including workers' compensation, unemployment compensation, and severance pay are allowable subject to the following provisions:

(1) The type of coverage and the extent of coverage and the rates and premiums would have been allowed had insurance (including reinsurance) been purchased to cover the risks. However, provision for known or reasonably estimated self-insured liabilities, which do not become payable for more than one year after the provision is made, must not exceed the discounted present value of the liability. The rate used for discounting the liability must be determined by giving consideration to such factors as the non-Federal entity 's settlement rate for those liabilities and its investment rate of return.

(2) Earnings or investment income on reserves must be credited to those reserves.

(i) Contributions to reserves must be based on sound actuarial principles using historical experience and reasonable assumptions. Reserve levels must be analyzed and updated at least biennially for each major risk being insured and take into account any reinsurance, coinsurance, etc. Reserve levels related to employee-related coverages will normally be limited to the value of claims:

(A) Submitted and adjudicated but not paid;

(B) Submitted but not adjudicated; and

(C) Incurred but not submitted.

(ii) Reserve levels in excess of the amounts based on the above must be identified and justified in the cost allocation plan or indirect cost rate proposal .

(4) Accounting records, actuarial studies, and cost allocations (or billings) must recognize any significant differences due to types of insured risk and losses generated by the various insured activities or agencies of the non-Federal entity . If individual departments or agencies of the non-Federal entity experience significantly different levels of claims for a particular risk, those differences are to be recognized by the use of separate allocations or other techniques resulting in an equitable allocation .

(5) Whenever funds are transferred from a self-insurance reserve to other accounts (e.g., general fund or unrestricted account), refunds must be made to the Federal Government for its share of funds transferred, including earned or imputed interest from the date of transfer and debt interest, if applicable, chargeable in accordance with applicable Federal cognizant agency for indirect cost, claims collection regulations.

(e) Insurance refunds must be credited against insurance costs in the year the refund is received.

(f) Indemnification includes securing the non-Federal entity against liabilities to third persons and other losses not compensated by insurance or otherwise. The Federal Government is obligated to indemnify the non-Federal entity only to the extent expressly provided for in the Federal award , except as provided in paragraph (c) of this section.

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