Sneak Preview: EPA Updates Participant Support Cost Guidance
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Environmental Protection Agency (EPA) recently issued updated guidance informing its recipients that its policies addressing participant support costs will correspond with the Office of Management and Budget’s (OMB) 2024 revisions to the uniform guidance (2 C.F.R. Part 200).
The 2024 revisions to the uniform guidance, which became effective for new awards and modifications to existing awards on Oct. 1, amended the definition in §200.1 for “participant support costs” as “direct costs that support participants and their involvement in a federal award, such as stipends, subsistence allowances, travel allowances, registration fees, temporary dependent care and per diem paid directly to or on behalf of participants.”
OMB also added a definition for “participant” in the uniform guidance to mean “an individual participating in or attending program activities under a federal award, such as trainings or conferences, but who is not responsible for implementing the federal award. Individuals committing effort to the development or delivery of program activities under a federal award (such as consultants, project personnel or staff members of a recipient or subrecipient) are not participants. Examples of participants may include community members participating in a community outreach program, members of the public whose perspectives or input are sought as part of a program, students, or conference attendees.”
EPA guidance adopting the uniform guidance at 2 C.F.R. §1500.1 expands the participant support costs definition to include subsidies, rebates and other payments to program beneficiaries to encourage participation in statutorily authorized environmental stewardship programs.
The 2024 revisions also removed several prior written approval requirements (§200.407), including the requirement for prior approval for participant support costs. However, the transfer of funds budgeted for participant support costs to other budget categories requires prior written approval (§200.308(f)(5)). In addition, participant support costs are now required to be documented in the recipient’s or subrecipient’s written policies and procedures and treated consistently across all federal awards (§200.456).
(The full version of this story has now been made available to all for a limited time here.)
Join us for our following Thompson Grants event:
Federal Grants Forum: Navigating the 2024 Uniform Guidance Changes | Oct. 29-30, 2024 | Virtual Event
Thompson Grants Workshop: Subrecipient Monitoring |Nov. 13, 2024 | Virtual Event
