Definitions:

A participant is an individual who is attending a workshop, conference, seminar, symposium, or
other short-term instructional or information sharing activity funded by a sponsored award
(grant).

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 (2 CFR 200.75).

Participant support costs paid to the participant as stipends and/or allowances are considered taxable income by the IRS.

A conference is defined in 2 CFR 200.432 as a meeting, retreat, seminar, symposium, workshop, or event whose primary purpose is the sharing and dissemination of technical information and is necessary and reasonable for successful performance under the funded award.

Individuals who are participating as human subjects in a research study are NOT considered to be participants as defined above, and this guidance would NOT apply to paying these individuals.

Business Process and Responsibilities

PI and the Office of Research and Innovation are responsible for review of awards/grants documentation and verification if an individual meets a definition of participant, and if payment can be qualified as participant support cost. They also have to make sure that payment is included in the Participant Support section of the grant budget.

In order to process payment, department needs to request a participant to be set up as supplier in Buyway system and submit the IRS W9 form completed and signed by participant. Please use Setting up Suppliers link for additional information.

After the supplier set up request has been processed by Accounts Payable, payment to a participant can be initiated in Buyway using the Payment to Individual tile.

A person requesting a payment has to include a following comment in Buyway, and copy comment to Ms. Anne Schauer, the Director of Research and Sponsored Programs.

This person is being paid as a participant on an externally funded grant.  Participants are defined in 2 CFR 200.1 as individuals receiving stipends or subsistence allowances, travel allowances, and registration fees paid to or on their behalf as participants or trainees (but not employees) in connection with a grant funded conference, or training project.

Please don’t attach the W9 form or any other document containing sensitive personal information to the payment request in Buyway.

Requests for payments to participants are reviewed and approved by the requesting Department as well as Office of Grants to ensure appropriate funding allocation and compliance with grant/award terms.

In addition, all payments to participants paid from externally-funded grant awards must comply with cost principles per OMB’s Uniform Guidance.

Taxation and reporting

Payments to participants are subject to U.S. tax laws. The IRS treats payments for participant as taxable income to the recipient. This means the recipient is responsible for reporting the payment when they file a personal tax return at the end of the year. Miami University is required by the IRS regulations to issue Form 1099-MISC for all US residents paid $600 or more in a calendar year.

If grant /award terms contains specific tax requirements, these requirements must to be fully disclosed and attached to the payment request in Buyway for the tax treatment review.

Taxation and reporting requirements for foreign nationals (non-US citizens)

If payment is requested to a foreign national (non-US citizen), it has to be indicated in appropriate check box in Buyway. If a payee is not a US citizen, they are considered a non-resident alien for tax purposes unless they are a green card holder or they passed the substantial presence test defined by the IRS and performed by the Payroll Services. Please note that the test is based on how many years the individual has been present in the US, not their immigration status.

In order for Payroll Services to perform the substantial presence test, a participant will be required to provide all relevant documentation including copy of visa, passport, form I-20 or DS-2019, I-94 with travel history included, and a completed Foreign National Information form. Please visit the Payroll Office or email Sr. Payroll Analyst, Holy Neill at neillh@miamioh.edu for additional question related to documents submission.

Any payments to participant who is determined to be a non-resident alien for tax purposes, regardless of amount, are subject to 30% automatic tax withholding unless the non-resident payee is claiming a tax treaty benefit. Payments to foreign nationals are reported on Form 1042-S.