Paying Human Subjects Directly
- Prior to payment.
The following must be confirmed prior to payment being made to a third party by a certified approver or by contacting the 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 contact.
- Individual will receive payment as a human participant rather than as a participant/consultant.
- Current IRB approval status must be confirmed before payment is initiated.
- Determine form of compensation and the correct form to use.
The form needed to process the payment depends on what type of compensation is being issued or needed. Payment methods are listed below in preferred order. If a particular type of payment is not listed here, contact the Helpline at 612-624-1617 for assistance.
Making Direct Payments to Human Participants – payment methods available in preferred order (employees included):
- Reloadable prepaid debit card
- Follow Administrative Procedure: Making Payments using Prepaid Debit Cardsto create the study and request the required number of reloadable prepaid debit cards.
- Register the participants in the portal and provide them the reloadable prepaid debit card.
- Load additional stipends and reimbursements onto the participant’s reloadable prepaid debit card as necessary.
- Payment by check (non-reimbursement):
- Complete a Check Request Form (CRF). Determine if a unique supplier number is already set up or must be set up.
- If a supplier number is not required, payment can be issued using a Single Payment Supplier number. Follow Administrative Procedure: Making Payments Using Single Payment Supplier Numbers.
- Use an existing Zero Balance Account to issue payment.
- Request a cash advance (when cash is needed to distribute to participants on-site) (see Appropriate Handling of Cash Advances):
- Process a Travel Authorization and a Cash Advance in the financial system to request an advance for the employee responsible for disbursing the cash to the participants.
- Complete a Reimbursement Request (UM 1911) and process it in the Expense Module to account for the distribution of the cash advance funds. Include the number of payments made and the denominations in the documentation.
- Non-cash payments (i.e. gift certificates, T-shirts, etc.), when purchasing items to distribute to participants, the suppliers should be paid by:
- Using the University's procurement card.
- Processing the supplier invoice.
- Complete a Check Request Form to request payment (if an invoice cannot be obtained).
- Non-cash items (i.e. gift certificates, T-shirts, etc,) must be inventoried and tracked
- Reimburse expenses incurred by participant (for expenses such as travel, parking, daycare):
- Add funds to a pre-paid debit card.
- Use a Check Request Form for US residents and for nonresident aliens.
- Complete the payment document, while maintaining confidentiality.
It is required that the confidentiality of the study and the human participant(s) be maintained. The justification required on the payment document is: “Details are on file in department and available for audit”. Attachments identifying the human participant(s) or the name of the study should NOT accompany the payment document. Therefore, when completing the appropriate form(s) requesting reimbursement or payment, include only the name and address of the payee, social security number, account string and amount. Journal entries for payments made using Zero Balance Accounts should only designate the account string and amounts.
- Maintain payment records.
To protect the confidentiality of participants, all details must be maintained in the departments with the Principal Investigator or research team. Departments are required to maintain proof of payments made to research participants for both cash and non-cash payments. This can be in the form of a log or pre-numbered department receipts. The recipient is required to sign the log or the receipt to indicate the payment was received, unless it is a non-cash payment of nominal value. Non-cash payments under $10 are not required to have a signature.
- Report total payments of $600 and over.
Due to confidentiality requirements for participant payments, the payment detail required by the IRS must be stored in the departments issuing the payments and is not available centrally for all participant payments, such as non-cash payments, cash payments made on-site from Cash Advance funds, and payments made from Zero Balance Accounts. As a result, University departments are required to obtain a W9 and report the names, addresses, social security numbers and total amount of payments made by the University to individual participants who receive cumulative payments/value of $600.00 or more during a calendar year. This information must be forwarded by mail to the Purchasing Services by December 31st every year.