Research Participation Payments
Revised: 08/18/2016; 11/05/2018
Division of Finance
Research studies often involve individuals who participate in the study. As needed, participants may be paid for their participation. The method of payment should be designed to achieve these goals:
- Ensure the confidentiality of research participants.
- Provide timely, convenient payments to participants to facilitate, not hinder, the study.
- Record compensation in the accounting system for both financial record and IRS Form 1099 purposes. For the purpose of payment to research participants, employees and nonemployees will be paid in the same manner.
- Ensure appropriate internal controls and adequate safeguards exist for items of value used to provide payment, whether cash, checks or other.
Expanded definition and information for this policy is available under Resources below.
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.
The following procedures assist with ensuring compliance with the above policy:
Determining Method of Payment
The method of payment must be determined 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.
- If all participants are paid.
- Location of the study.
- Confidentiality issues.
- Whether participant is employee, student or other.
Available Methods of Payment
Research participants could receive funds from the University for reimbursement and/or compensation. Please see the hyperlinks for processing instructions to ensure prompt payment and contact your department fiscal office for assistance. When those options are not feasible, departments MUST contact the Subject Payment Coordinator (see link under Resources below) and obtain approval for the requested payment method.
Reimbursements include payments to research participants and suppliers for travel related expenses incurred while participating in the research study. Reimbursements are considered non-taxable if in accordance with UM Policy 22310 – Expense Reimbursements (See link under Resources below).
Compensation includes cash and non-cash items used to pay research participants for participating in the research study. Compensation is considered taxable and reportable to the IRS whether employee or nonemployee. As such, departments will be responsible for obtaining the research subject’s 1099 information including name, social security number and permanent mailing address.
- Compensation to research subject via check, gift card, or cash (additional information under Resources below):
- Used when it is not feasible or practical to issue a University check.
- All cash advances must be repaid in full within 21 calendar days following completion of research. Ongoing research cash advances will be due 3 months from the issuance date of the cash advance and must be repaid prior to receiving the next cash advance. Failure to repay a cash advance within this period may result in the amount being deducted from payroll earnings and may further result in loss of this courtesy.
- The department must maintain a spreadsheet with required 1099 information including the payment amount. The spreadsheet must be provided to AP Shared Services following compensation.
- Compensation to Research Subject via Merchandise
- Payment for merchandise is typically done using Purchasing Card. In PaymentNet, note the IRB# for which the purchase was made.
- The department must maintain a spreadsheet with required 1099 information, including the merchandise description and value. The spreadsheet must be provided to the AP Shared Services following the compensation.
- Compensation to Research Subject via Survey Resource
- Qualtrics is a common web based survey supplier. The Assessment Resource Center is managing activities related to use of Qualtrics, both for divisions, departments and for individual researchers. (Additional information in link under Resources below).
Safeguarding of Assets
The University treats gift cards and 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. The department must create control procedures like those described below and as suggested in UM Policy 25501 – Cash Funds. (Additional information in link under Resources below)
- Segregation of Duties: Establish a purchase, documentation and distribution process to ensure duties are segregated between these roles.
- Purchase: Document cash/items purchased, including any control numbers.
- Security: Store the cash/items in a secure locked location until distribution to research participants.
- Receipts at Disbursement: When distributing cash/items, obtain a receipt.
- Receipts should include the participant’s name, address, social security number, the amount/value of item, and date of payment.
- Receipts must be signed in ink by the research subject to document acknowledgement of the payment.
- When items are mailed to participants, two people must be involved in the process to ensure the item is put in the envelope and delivered to Campus Mail for each compensated event.
- Verification: 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 receipts and account for the number of items used on the Verification of Receipts for Subject Payment Form.
Projects Involving Sponsored Activities
If the Chartfield string debited for the subject payments is a sponsored project and involves payments other than checks or cash, the department may consult OSPA Post Award to ensure that the sponsor allows this type of payment. If there are no sponsor restrictions, then the PI should ensure that all allowability criteria are met in accordance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 200 and the terms and conditions of the award. OSPA can help request approval from the sponsoring agency, if necessary. For additional information, see Resources below.
Raffle or Drawing
If research participants are compensated based on selection from a raffle or drawing, when not all research participants are paid and the selection is random, this is considered a game of chance. Games of chance must be approved by Division of Finance-Accounting.
In research studies 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 Department Chair indicating that they understand that required information will not be collected on the study. The exception must also be approved by the Subject Payment Coordinator. When we are not able to collect 1099 information (social security numbers, name and address) compensation may be subject to 28% taxable withholding.
- UM Policy 27011 – Payments to Research Study Participants
- UM Policy 22310 – Expense Reimbursements
- UM Policy 25501 – Cash Funds
- Compensation to Research Subject via Check
- Compensation to Research Subject via Gift Card
- Compensation to Research Subject via Cash
- Reimbursement to Research Subject
- Reimbursement for travel paid directly to Supplier (ex. direct bill for hotel)
- Subject Payment Coordinator
- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 200
- Verification of Receipts for Subject Payment Form