This policy establishes guidelines and processes for paying human participants who are involved in University research studies, complying with the legal obligation to maintain their confidentiality and the tax reporting requirements associated with these payments.
Departments must have an Institutional Review Board (IRB) approval on file prior to engaging and paying human participants.
Individuals who take part in University research studies often receive payment for their involvement as human participants. University faculty and staff have a legal obligation to maintain the confidentiality of those individuals, whether issuing a payment to the individual or making payments to third parties that provide research-related services and/or products. The payment process must maintain their confidentiality while meeting Internal Revenue Service (IRS) reporting requirements and conforming with the University's standard accounting and payment practices. Units must ensure that information identifying the human participants or name of the study are excluded from the payment documents and any attachments. All of these details must be maintained in the departmental files.
Payments and Tax Reporting
IRS regulation requires the University to report payments to human participants totaling $600 or more during a calendar year. Units must be in compliance with the Administrative Procedure: Submitting 1099 Reportable Non-Payroll Payment Information.
Prior to payment
Units must confirm the following prior to payment(s) being made. Contact the Institutional Review Board (IRB) Office for assistance.
- Individual receiving payment is an eligible human participant at the time of the research involvement and that IRB approval was current at the time of participant
- Individual will receive payment as a human participant rather than as a participant/consultant.
- IRB approval status is current.
Payment methods available are listed below in preferred order. Additional information on payment methods can be found in the Procedures section of this policy.
- Reloadable prepaid debit card
- Payment by check
- Non-cash payments
- Request a cash advance (limited circumstances, such as for certain populations, and must be approved by Purchasing Services prior to requesting funds to ensure allowability of use of cash)
- Payments to a third party
Employees receiving a cash advance for payments to human participants must not open a bank account to hold the cash advance until disbursement, nor commingle the cash advance with any other department change funds, cash on hand, or personal funds. Employees receiving a cash advance for payments to human participants must comply with all University internal controls related to the proper handling and safeguarding of University cash.
Reason for Policy
To implement Board of Regents Policy: Research Involving Human Participants (PDF). This policy and related procedures establish the payment process that University faculty and staff must use to comply with privacy and IRS regulations when making payments to human participants who take part in University research studies.