RPG03 Payments to Human Participants in Research

Contents:

• Purpose
• Guideline
• Payment By SRFC
• Cash or Gift Card Payments
  • Payments of $100 or less
  • Anonymous Questionnaires or Surveys
  • Compelling Reason for Cash Payments Greater than $100
  • Sponsor Provided Payments
• Further Information
• Cross References

PURPOSE:

Policy RP03, The Use of Human Participants in Research, outlines the standards for the protection of human participants of research. When human participants are used in research, many times payment or compensation is provided as an incentive for participation. This guideline outlines the options for payments balancing IRS reporting regulations and the confidentiality required with certain human participant research studies.

GUIDELINE:

Institutional Review Board (IRB) approval for the use of human research participants must be provided and payments may not be made unless an IRB Study number is obtained (see RP03). Payments should be made as indicated below, even if the research participant is currently a Penn State employee. In other words, employee determination does not need to be made – all research participants will be paid by the methods below.

PAYMENT BY SRFC:

Generally, payments to research participants must be paid by Special Request for Check (SRFC), using object code 0394 and a purpose of 1099 AWARDS. (See Cash or Gift Card Payments, below, for specific situation where an SRFC is not required.) The following are required from each participant:

• Social Security Number, PSU ID, or individual tax identification number (SSNs/IDs)
• Non-Employee Information (NEI) Form and supporting documents

This information should be collected from the individuals to be paid at the time the study is conducted. Multiple individuals can be paid through a single SRFC. The payment will be made from the account number of the research project.

If a participant is not eligible for payment based on the information provided in the NEI form, then payment cannot be made through a SRFC. Thus, participant cannot be used in the study unless qualifying for a Cash or Gift Card Payment, below.

Confidentiality: If due to the nature of the research, payment to participants through the research project account would breach confidentiality, as determined by the Principal Investigator, then payments can/will be paid through a Miscellaneous General Research (MGR) account. In a separate process a Journal Voucher would be used to transfer the total payment amount – not identifying individuals – to the research account indicating that the payments were for confidential research and names and SSNs/IDs are on file in the department.

CASH OR GIFT CARD PAYMENTS

Cash or gift cards may be given to research participants in the following limited situations. There is no requirement to collect SSNs/IDs or the NEI form with cash or gift card payments.

Payments of $100 or less:

Payments of $100 or less (where the aggregate payments to participant for the particular study is $300 or less in a calendar year) may be made by issuing cash or gift cards to participants.

The Principal Investigator (PI) must keep payment records which include name, amount, date and signature of the participant confirming receipt of the cash or gift card. This record is then used to settle the cash advance or gift card purchase. The PI must also account for unused cash or gift cards and maintain cash/gift cards in a secure location.

Cash payments are issued as a cash advance to the PI using the Special Request for Check, using object code 0411 and CEN-USE. The IRB Study number should be included in the notepad. The cash must be maintained in a secure location until payments are made to participants. Settlement of advances should be done as soon as possible after the participant segment is completed, but no later than 30 days prior to the end date of the award.

Gift cards can be obtained through eBuy through approved vendor National Gift Card (NGC), with options for either physical cards or eCode. (NGC information available in SUPPLIER INFORMATION section on Purchasing web site). The IRB Study number should be noted in eBuy. Gift cards and eCodes must be maintained in a secure location until distributed to participants. Settlement of the gift card purchase must be made as soon as possible after the participant segment is completed, but no later than 30 days prior to the end date of the award.

Purchase of gift cards other than through eBuy require approval of the Financial Officer. The Purchasing Card may be used. The IRB Study number must be noted in the payment documentation (PCard Support form, SRFC notepad, or PO comment).

Anonymous Questionnaires or Surveys:

A PI may wish to include small dollar stipends (maximum $10) with an anonymous questionnaire or survey as an incentive to the recipient to complete and return the questionnaire or survey. The PI must indicate the number of questionnaires to be mailed and the amount to be placed in each envelope in a memo or email to be approved by the budget administrator. This memo or email becomes part of the back-up for the SRFC when the cash advance is requested. The Financial Officer also must review control procedures to assure that the cash is properly safeguarded and controlled. In general, a minimum of two people must be involved when putting the funds into the envelopes and then preparing the questionnaires/surveys for mailing.

Compelling Reason for Cash Payments Greater than $100:

There are situations where a SRFC cannot meet the University’s research objectives (e.g., when payments to participants must remain anonymous to all but the PI). In such situations, the University acknowledges that there is a compelling reason to permit cash payments greater than $100. There is potential financial liability for the PI and the area which approves the exception if proper payment records are not maintained, or if the IRS challenges the taxability of such payments.

To obtain this exception, a Research Participant Cash Payment Exception MUST be completed by the PI, and approved by both the budget administrator & University Tax Director. Once approved, this form must be attached to the SRFC requesting the cash advance for the PI, and must include the IRB Study number. All other requirements regarding settlement apply.

Sponsor Provided Payments:

The University prefers that all payments issued to participants follow the above guidelines. However, if a sponsor wishes to use an outside entity to issue payments to participants, then it will be the responsibility of the sponsor to manage the 1099 reporting to the IRS. Payment would be issued in the name of the sponsor, not the University. Gift cards provided by sponsors are permitted, but must be for $100 or less. Gift cards of a higher amount would require that the sponsor be listed as the payee responsible for all 1099 reporting.

FURTHER INFORMATION:

For questions, additional detail, or to request changes to this policy, please contact the the Associate Vice President for Research, Director of the Office for Research Protections or the Associate Vice President for Budget and Finance.

CROSS REFERENCES:

ADG08 - Collection, Storage and Authorized Use of Social Security Numbers and Penn State Identification Numbers (Replaced Policy AD19)

AD47 - General Standards of Professional Ethics

AD83 - Institutional Financial Conflict of Interest

RP03 - The Use of Human Participants in Research

RP05 - Research Quality in Human Participant Research

RP07 - HIPAA and Research at Penn State University

RPG01 - The Responsible Conduct of Research

Most Recent Changes:

• July 20, 2023 - Updated Subject Matter Expert to Associate Vice President for Budget and Finance; Corporate Controller updated to Office of Budget and Finance.

Revision History (and effective dates):

• June 28, 2022 -  Updated Subject Matter Expert to Jody Murawski, Assistant Controller.
• April 12, 2019 - Corporate Controller's Office added as co-steward; Kimberly Croft added as Subject Matter Expert.
• February 24, 2017 - Editorial change was made in the CASH OR GIFT CARD PAYMENTS section, Payments of $100 or Less. The first sentence of paragraph 3 was edited, adding object code and IBIS information necessary when cash payments are issued as a cash advance.
• December 13, 2016 - New Guideline.