Research Participation Compensation

Research studies often involve individuals who participate in the study. As needed, participants may be compensated for their participation. The method of compensation should be designed to achieve these goals:

• Ensure the confidentiality of research participants.
• Provide timely, convenient compensation to participants to facilitate, not hinder, the study.
• Record compensation in the accounting system for both financial record and IRS Form 1099 purposes.
• Document that compensation was for participation in a study.
• Ensure appropriate internal controls and adequate safeguards exist for items of value used to compensate, whether cash, checks or other.

Confidentiality

As a matter of policy the University treats all research projects involving human subjects as confidential whether or not there is a specific external requirement to do so. Thus, all research projects involving human subjects must conform to this policy.

Determining Method of Compensation

The method of compensation must be approved by Accounting Services before the research begins and should take into account the following:

• Nature and subject matter of the study.
• Dollar amount and time period of payments.
• Variability in the amount of payments.
• Number of payments and participants involved in the study.
• Location of the study.
• Confidentiality issues.
• Whether participant is employee, student or other.

Available Methods of Compensation

The preferred methods to compensate research participants are accounts payable and cash. When those options are not feasible, departments can use non-cash items such as credits to student accounts or items of value such as University gift certificates or vendor gift cards.

Accounts Payable

• Payment directly to participant, such as mileage.
• Reimbursement to a participant.
• Paying expense associated with participant, such as hotel or rental car.

Non-Cash Items

A variety of non-cash items, such as credits to student accounts, gift certificates from University business and gift cards from merchants are available to compensate research participants. The department should contact the Cashiers Office regarding student credits. For other items, the department should use University processes or a Purchasing Card to buy these items, but they must maintain documentation of the actual distribution of the items.

Cash

For some studies, it is not feasible or practical to issue University checks, usually because payment needs to be made at the time of participation (e.g., individuals may not participate if they must wait for payment) and the information to draw a check is not available, for example:

• The participants are not known in advance.
• The amount to be paid to the participants is not known in advance (e.g., the payment varies depending on what the participant agrees to do).
• Participants are paid a nominal amount.

As a general rule, projects of a short duration (typically, two months or less) should use an expense advance. Projects of a longer duration should use an imprest account.

Obtaining Expense Advance

See 2:240.

Obtaining an Imprest Account

Use the process for a petty cash fund (see 2:120). The request must include a schedule showing projected participant payments by month. The size of the imprest account will normally be no more than two month's average payments. The department processes a voucher at least monthly to replenish the account (see section below on required information on the voucher.)

Information accompanying the voucher should describe how the responsible party will safeguard the funds and document their use. For some projects with imprest accounts, there may be a need for a bank account, which requires the approval of MU Administrative Services (see 2:035).

Reimbursing an Expense Advance

If the voucher is for reimbursement of an expense advance or imprest account, receipts for all subject payments should be attached to the voucher.

• All receipts should include the participant's name, address, and the amount and date of payment.
• Receipts should be signed in ink by the participant.
• If any of the receipts are incomplete or not signed in ink, the department chair must approve the voucher.

Control and Distribution of Non-Cash Items and Cash

The University treats non-cash items like cash, so a common sense approach to ensure that the items are secured and used for their intended purpose is the goal. Consult the Cash Receipts Manual for guidance. For non-cash items and cash, the department must create control procedures like those described below and as suggested in the Cash Receipts Manual.

1. Establish a purchase, documentation and distribution process, approved by the department chair, the division fiscal officer and Accounting Services before obtaining cash or purchasing any items.
2. Keep a record of the cash or the number of items purchased and any control numbers.
3. Keep the cash/items locked in a secure location.
4. Establish a plan of how you will control and monitor the distribution of the cash/items. Regarding distribution of the cash/items, obtain a signed receipt where feasible (when not feasible, document why). When items are sent to participants, two people should be involved in the process to ensure the item is put in the envelope and delivered to Campus Mail for each compensated event.
5. Assign someone other than those involved in the research, the responsibility of following up and verifying that the cash/items were distributed and accounted for. The responsible person should audit the completed surveys and account for the number of items used.
6. When the items are paid by Purchasing Card, documentation on the distribution of the items must be kept with the Purchasing Card files. In addition, in PaymentNet, show in Transaction Notes that the purchased items were used to compensate research participants.
7. In projects where you cannot obtain the appropriate information/documentation from participants because it would inhibit the researcher finding participants, you must have the approval of the departmental chair indicating that they understand that required information will not be collected on the study.

Receipts

Unless otherwise approved by the Director of Accounting, all research compensation by cash or item of value must be documented in writing, as follows:

• Receipts should include the participant's name, address, social security number, and the amount and date of payment.
• Receipts should be signed in ink by the participant.
• If any of the receipts are incomplete or not signed in ink, the department chair must approve the receipt.

Projects Involving Grants

If the ChartField string is a grant, consult the grant accountant in OSPA to ensure that the grant allows this type of payment. They can help request approval from the granting agency, if necessary.

Reporting Compensation to IRS

Departments need to maintain records on any compensation provided unless the transaction is recorded in the accounting system in sufficient detail to enable tracking for 1099 reporting purposes. The department must maintain a spreadsheet with required 1099 information, such as name, permanent mailing address, and the payment amount. Departments should submit this information to Accounting Services, 325 Jesse Hall, at the conclusion of the study.