Paying Human Participants and Maintaining Confidentiality
Frequently Asked Questions
- What options are available for making payments to human participants? Payment methods available are listed below in preferred order:
- Prepaid Debit Cards
- Non-cash payments/Cash Advance
- Is the human participant payment method for a University employee different than a non-employee?
No, same payment methods as FAQ #1.
- Is a supplier number required to pay human participants?
For prepaid debit card a supplier number is not required. For other payment methods, if a supplier number is already established, that number must be used. If a supplier number has not been set up and if the cumulative payment to a human participant is less than $600 in a calendar year (annually), a supplier number does not need to be established. These payments can be issued using the Clusters Single Payment Supplier Number.
- What Federal tax ID number is required when a human participant is submitting a W-9 form?
For entities the number is the Tax Identification Number (TIN); for individuals the number is their Social Security number (SSN).
- Does having the Tax ID number (TIN or SSN) on a supplier record violate HIPAA?
No. The tax ID number is considered private information and using it on a supplier record is not a violation of HIPAA.
- What documentation should be sent for imaging of human participant payments? What should be retained in the department?
It is required that the confidentiality of the study and the human participant(s) be maintained. Therefore, any information identifying the human participant(s) or name of the study must be excluded from the payment documents and any attachments. All of the details should be maintained in the departmental files.
- Are taxes deducted from payments to human participants?
Required taxes are withheld on payments to foreign nationals and reported to the Internal Revenue Service on form 1042 S. Taxes are not deducted from payments to non-foreign national participants, but payments may be reportable income.
- Is the payee signature required when a human participant receives payment?
It is a requirement to have all recipients sign a log acknowledging receipt of payment for all methods except check unless the logistics of the payment/study makes this impossible.