Printed on: 11/20/2019. Please go to for the most current version of the Policy or related document.
University of Minnisota  Procedure

Paying Human Subjects Directly

Administrative Procedure

See Job Aid: Transaction Justification/Documentation Standards for All Non-Sponsored and Sponsored Transactions.

  1. Prior to payment.

    1. Confirm the individual receiving payment is an eligible human subject at the time of the research involvement and that IRB approval was current at the time of subject contact.
    2. Confirm that the individual will receive payment as a human subject rather than as a participant/consultant.
    3. Current IRB approval status must be confirmed before payment is initiated. Approval can be confirmed by a certified approver or by contacting the IRB office for assistance.

    Any University research that uses humans, human tissue, surveys of human subjects, or human subjects’ records requires Institutional Review Board (IRB) review and approval, irrespective of its funding source. These conditions extend to all research such as social and behavioral sciences as well as research in the health and biological sciences. Further information regarding human subjects is available on the IRB website at

  2. 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. Use the list below as a general guide. If a particular type of payment is not listed here, contact the Helpline at 612-624-1617 for assistance.

    Making Direct Payments to Human Subjects – Options Available (employees included):

    1. Reloadable Prepaid Debit Card
      1. Follow Administrative Procedure: Making Payments using Prepaid Debit Cards to create your study and request the required number of reloadable prepaid debit cards.
      2. Register the subjects in the portal and provide them the reloadable prepaid debit card.
      3. Load additional stipends and reimbursements onto the subject’s reloadable prepaid debit card as necessary.
    2. Payment by check (non-reimbursement):
      1. Complete a Check Request Form. 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.
      2. Use a Zero Balance Account to issue payment.
    3. Payment by Visa gift card (cards to be distributed to subjects for their personal use)
      1. Determine the number of cards and card values needed.
      2. Complete and forward Gift Card Request Form to the Office of Investments and Banking.
      3. Requester will be contacted by the Office of Investments and Banking when cards are available for pick up.
    4. Request a cash advance (when cash is needed to distribute to subjects on-site) (see Appropriate Handling of Cash Advances):
      1. 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 subjects.
      2. Complete an Employee Expense Worksheet 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.
    5. Non-cash payments (i.e. gift certificates, T-shirts, etc.), when purchasing items to distribute to subjects, the suppliers should be paid by:
      1. Using the University's Procurement Card.
      2. Processing the supplier invoice.
      3. Complete a Check Request Form to request payment (if an invoice cannot be obtained).
    6. Reimburse expenses incurred by subject (for expenses such as travel, parking, daycare):
      1. Use a Check Request Form for US residents and for nonresident aliens.
      2. Use a Zero Balance Account to issue payment.
      3. Add funds to a pre-paid debit card.
  3. Complete the payment document, while maintaining confidentiality.

    It is required that the confidentiality of the study and the human subject(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 subject(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.

  4. Forward document for processing.

  5. Maintain payment records.

    To protect the confidentiality of subjects, all details must be maintained in the departments. Departments are required to maintain proof of payments made to research subjects 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.

  6. Report total payments of $600 and over.

    Due to confidentiality requirements for subject payments, the payment detail required by the IRS must be stored in the departments issuing the payments and is not available centrally for all subject 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 subjects who receive cumulative payments/value of $600.00 or more during a calendar year. This information must be forwarded by mail to the Disbursement Services Tax Desk by December 31st every year.

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