Human/Research Subjects

Policy

The University recognizes the need to provide reasonable incentives for individuals who participate in research as human subjects. As such, the University permits payments and incentives under the following conditions:

  • Payments to Human Subjects over $100 per occurrence must be paid directly to the individual via University check. Gift cards, gift certificates or in-kind payments over $100 per occurrence are not permitted as remuneration for participation in a research study. Refer to the University Check section within the Paying Human Subjects procedures and guidelines.
  • Human Subject payments $100 and under per occurrence can be processed via University check or other methods including petty cash, gift cards or in-kind payments. Refer to the Cash Payment section within the Paying Human Subjects procedures and guidelines.

Paying by University Check:

Payments to human subjects greater than $100 must be paid by University check processed though the Independent Contractor section of Payroll Services. Payments should be processed through ePayment.

Required Forms

  • U.S. Citizens
    • IRS Form W-9 (Request for Taxpayer Identification Number)
    • IRB Number (#)
  • Permanent Residents
    • IRS Form W-9 (Request for Taxpayer Identification Number)
    • Copy of Permanent Resident Card
    • IRB Number (#)
  • Foreign Nationals
    • IRS Form W-8BEN, Certificate of Foreign Status of Beneficial Owner for United States Withholding (if determined to be a Resident for tax purposes, complete IRS Form W-9)
    • Form¬†UPP-192, Alien Determination of Residency Form
    • Copy of front and back of the individual's I-94 Card, Departure Record or ESTA Receipt
    • Copy of Immigration document (e.g. I-20, DS-2019), if applicable
    • IRB Number (#)

Paying by Cash:

Payments to human subjects of $100 or less can be paid by cash methods, such as petty cash, gift cards or in-kind payments. Payment should be processed through ePayment or GEMS.

  • U.S. Citizen or Resident Alien: If a one-time research subject payment is $100 or less, the requirement to obtain documentation is waived. Even though the requirement to collect documentation is waived, Principal Investigators (PIs) are required to keep a log documenting the names of human subjects and payments to those human subjects. In the event of an IRS audit, it will be the responsibility of the local units to supply clear supporting compensation documentation. It is the responsibility of the Principal Investigator (PI) to collect a completed W-9 from each U.S. citizen or resident alien if at any time either at the beginning of each research study/clinical trial or during the course of the research study, it is recognized that the human subject will receive a total of $600 or more in a calendar year as remuneration.
  • Nonresident Alien: If it is known that the research subject is a nonresident alien for tax purposes, payments should be paid through University check and required documents for foreign nationals should be collected (see above). Principal Investigators (PIs) are required to keep a log documenting the names of nonresident alien human subjects and payments to those human subjects. In the event of an IRS audit, it will be the responsibility of the local units to supply clear supporting compensation documentation.

Paying Reimbursements:

Reimbursements for out-of-pocket expenses in relation to the research study are generally not reportable payments. Reimbursement includes payments to research subjects to cover out-of-pocket expenses they incur while participating in clinical research, e.g., reimbursement for travel expenses such as taxi fare or parking. Reimbursement may be made only if a receipt for the expense is provided by the subject. Reimbursement of expenses based on receipts is not considered taxable income.

Responsibilities of Principal Investigator:

The Principal Investigator is ultimately responsible to assure proper accounting of payments made to subjects for fiscal accountability and federal tax purposes and to maintain privacy of the human subject. Other responsibilities include:

  • Ensure that all human subjects are informed during the consent process (verbal or written) of the human subject's responsibility of reporting human subject remuneration to the IRS.
  • Document the names, of human subjects and payments to those human subjects in a log for studies involving surveys where incentive payments $100.00 or less are used as enticement to complete the survey and the returned survey contains no identifiers and is considered anonymous. (Exception: nonresident aliens)
  • Document the number of human subjects and payments to those human subjects in studies where the human subject remains anonymous (where the IRB has approved a waiver of consent) and no identifiable information is collected.
  • Ensure that all Protected Health Information (PHI) collected and forwarded to Payroll Services for payment of a human subject does not link the subject to the research study by title, include medical information, diagnostic information, medical/personal information or other PHI protected by law. Payment documentation must identify the account number from which the fee will be paid, the name of the human subject, social security number and amount of payment. No further information is required for IRS purposes.
  • Ensure that potentially sensitive data is protected.
    • All collected forms should be sent to Payroll Services and should not be retained locally
    • Participants' social security number should not be kept on a local desktop, laptop, or other computing device
  • Payroll Services must be notified not later than December 15th, if any human/research subject received payments totaling $600.00 or more in the current calendar year.