Costs and Fees
Participant Support Costs are excluded from the Modified Total Direct Costs (MTDC) base for federal projects. Indirect costs may not be applied to Participant Support Costs for federal projects.
Participant support costs are defined in the Uniform Guidance as 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. MTDC is the base to which F&A (indirect cost) rates are applied. The Uniform Guidance excludes participant support costs from the MTDC base and defines this base for sponsored projects awarded on or after December 26, 2014 as follows:
- MTDC means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000
Participant is defined as an individual who is the recipient of a service or training provided at a workshop, conference, seminar, symposium or other short‐term instructional or information sharing activity funded by a sponsored project. An MBL employee may not be a participant. Funds provided for participant support typically may not be used for other categories of expense without specific prior agency written approval. Review the terms and conditions of your award.
For NIH awards these costs are only allowable when specifically identified in the funding opportunity announcement (FOA). For the purposes of Kirschstein-NRSA programs, this term does not apply. NIH will continue to use the terms trainees, trainee-related expenses, and trainee travel in accordance with NRSA Regulations.
Reference: 45 CFR 75.456 /NIH Interim Grant General Condition (Section 5.4)
NIH FAQ link: Are participant support costs allowable?
VISA COSTS FOR SHORT-TERM TRAVEL
Uniform Guidance, Section 200.463(d) recruiting, describes when visa costs are allowable as a direct cost on federal awards: Short-term, travel visa costs (as opposed to longer-term, immigration visas) are generally allowable expenses that may be proposed as a direct cost. Since short-term visas are issued for a specific period and purpose, they can be clearly identified as directly connected to work performed on a Federal award.
For these costs to be directly charged to a Federal award, they must:
(1) be critical and necessary for the conduct of the project;
(2) be allowable under the applicable cost principles
Basic visa application and required fees, such as anti-fraud fees, are allowable direct costs provided they meet the definition above.
Premium processing fees, dependent form fees are NOT allowable as direct charges to a federal award.
Uniform Guidance Section: 200.463
1. I have a postdoc or research associate that is coming from outside the U.S. to work on my federal award, can I charge the cost of his visa to the grant? According to the new Uniform Guidance [§ 200.463 (d) “Recruiting Costs”] you may charge visa application fees to your grant provided the postdoc/researcher is critical and necessary for the conduct of the project.
2. I have a postdoc or research associate that needs to have his/her visa renewed, can I charge the cost of his visa to the grant? No. Visa costs are only allowable as part of recruitment not retention.
3. I have a postdoc who is here on a J-1 visa and is transitioning to a H-1B visa. May I charge the costs of the new H-1B visa to a federal award? No. Only those visa costs associated with the initial recruitment may be directly charged to a federal award.
Defines computing devices as supplies and allowable as a direct cost if essential and allocable, but not solely dedicated to the project.
Computing Devices are machines that cost less than $5,000* and are used to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or “peripherals”) for printing, transmitting and receiving, or storing electronic information.
- Charging computing devices as direct costs is allowable for devices that are essential and allocable (provide benefit), but are not solely dedicated, to the performance of a federal award. Such devices are also allowable if solely dedicated to the performance of a federal award.
- Federal sponsors may impose requirements for these costs to be included in the proposal budget and may require a budget justification. Until the federal agencies release specific information, budget justifications may be used at the discretion of the principal investigator.
- Inventory tags may be affixed to computing devices at the discretion of the department; inventory tagging facilitates accountability, availability for reuse, and appropriate disposal.
Non-federally Sponsored Projects: Direct charging of computing devices to a non-federally sponsored project is appropriate if the computing device benefits the sponsored project. Some non-federal sponsors may have specific requirements for direct charging of computing devices and should be addressed at proposal time.
*There is no change in policy regarding treatment of items over $5,000. If the acquisition cost of a computer is greater than $5,000 (and has useful life of more than 1 year), it should be categorized as computing equipment.
The Uniform Guidance is effective for federally sponsored agreements and new funding increments awarded on or after December 26, 2014.
Federal awards received before December 26, 2014 must continue to follow the requirements in OMB A-122.
Individual memberships are not an allowable direct charge on a federally sponsored project.
Do not propose or charge individual memberships (business, technical or professional) to a federally sponsored project. An individual’s membership in business, technical, and professional organizations is generally not an allowable expense as a direct charge on a federally sponsored project. If there are exceptional circumstances that make a membership expense an allowable, allocable, and reasonable charge to a federally sponsored project, please work with the Office of Sponsored Programs to review the circumstances.
Non-federally Sponsored Projects
An individual’s membership fees in business, technical, and professional organizations may be charged to non-federally sponsored projects (excluding sponsors who cite A-122 or Uniform Guidance) as long as the benefit can be adequately articulated in the business purpose.
Unallowable Membership Dues/Fees
Membership fees or dues, such as airline, social, dining and country club dues cannot be charged directly to federal or non-federal sponsored projects.
1. I must be a member of the association hosting the conference in order to submit an abstract or paper. Can this be direct charged to the federal award that supported the research? Unless you have prior written approval from the agency, individual memberships cannot be direct charged to a federal award and are considered an indirect cost. They must be charged to an appropriate non-sponsored account.
2. If I become a member of the association hosting the conference, I get a cheaper conference fee; in fact, the combined membership fee plus the member-conference fee is less than the non-member conference fee. Since I’m saving the government money, can I charge this membership fee to the federal award that supported the research? While this sounds logical, unless you have prior written approval from the agency, individual memberships cannot be direct charged to a federal award and are considered an indirect cost. They must be charged to an appropriate non-sponsored account.
PUBLICATION COSTS Updated: 09/01/2015 The Uniform Guidance allows publication costs to be charged to the award during the close out period. MBL needs adequate time to close awards, therefore, publication costs may be charged during the period of performance and subsequently, during the first 60 days following the end date of the federally sponsored project.
- Publication costs for electronic and print media, including distribution, promotion, and general handling are allowable. If these costs are not identifiable with a particular cost objective, they should be allocated as indirect costs to all benefiting activities of the non-Federal entity.
- Page charges for professional journal publications are allowable where:
(a) the publications report work supported by the Federal Government; and
(b) the charges are levied impartially on all items published by the journal, whether or not under a Federal award;
(c) the non-Federal entity may charge the Federal award before closeout for the costs of publication or sharing of research results if the costs are not incurred during the period of
performance of the Federal award.
Uniform Guidance Section: 200.461