Policy 1218: Payments of Human Subject Fees

Subject Area: Procurement/Disbursement
Responsible Office: Financial Services
Sponsor: Chief Financial Officer
Originally Issued: July 2014
Revised: N/A
Refer Questions To: Shared Services Help Desk, 773-702-5800

Purpose: To ensure an effective and efficient means to make payments to human subjects in research studies and properly account for and report these payments in accordance with generally accepted accounting principles and compliance with the Internal Revenue Code.


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.

Tax Reporting

The University is obligated to report to the Internal Revenue Service (IRS) on Form 1099 all U.S. Citizens and Resident Aliens receiving cumulative remuneration greater than the annual threshold amount of $600.

The University is also obligated to report to the Internal Revenue Service (IRS) on Form 1042S all Nonresident Alien payments regardless of dollar value.

If it is unclear if a person is a resident or nonresident alien, the required foreign national forms should be collected and sent to Payroll Services for a determination.