Research Subject Compensation Policy & Procedures

Overview

The University of Iowa balances a responsibility to maintain various levels of confidentially for information about human research subjects with the record keeping requirements of the State of Iowa, grantor agencies and the Internal Revenue Service.

Policy

Payments to subjects in research studies will be recorded as a form of compensation.  Payment may be any type of remuneration including, but not limited to: checks, cash, gift cards, or any other items of value.  Reimbursements for travel or other costs are not considered compensation and are not covered under this policy.

Note: Any time University faculty or staff handle the payment (i.e. cash, gift cards, or other items of value), the University Cash Handling Policies and Procedures apply and require a certification process. 

For each individual payment to a research subject exceeding $75, the Research Participant/Substitute W-9 form must be completed prior to research activities occurring.  The form includes:

  • Name
  • U.S. address
  • Social Security or Taxpayer Identification Number
  • Mailing Address
  • Amount paid or value of items given as compensation
  • Citizenship (if not U.S. Citizen, the following information will be needed)
    • Immigration (visa) status
    • Tax residency country (may differ from citizenship country)
    • Permanent foreign address
  • Signature (to certify information is accurate)

For payments that are less than $75, the same information will be required except for the Social Security/Taxpayer Identification Number.   

All research subject payments must be recorded in the University general ledger using institutional account 6240-Research Participation Subject.

Confidentiality

Research subjects will be asked to provide basic information including name, mailing address and Social Security Number.  The subjects should be informed that the information allows the University to meet government reporting obligations and precautions are in place to keep this information secure.  Subjects may be given the opportunity to waive receipt of payment/s should they wish to not provide identifying information.  The Institutional Review Board requires this notification in the language of the Consent Form. 

Subjects having a compelling need for confidentiality or a concern that a connection may be made between their identity and a particular research project may be paid from a general use departmental account.  The identifying information and the use of institutional account 6240 will still be required.  An adjusting entry to move expense totals from the general use account to the project account will then be made at the department level.

Procedures

Paying Research Subjects with a Check

Requests for payments to employees and non employees are processed through the EVoucher.  The EVoucher can be used to make a single payment to one research subject or payments to multiple subjects using a bulk voucher.  However, the bulk voucher cannot be used when paying a non-resident alien research subject.  All payments will be mailed to the research subject unless the “Hold Check” box is marked.  A notation of “miscellaneous compensation” should be used as the default in the description field.  This is also what will be printed on the check stub.

  • When a payment to an individual is greater than $75, the completed Research Participant/Substitute W-9 form(s) should be faxed or hand delivered to Accounts Payable for processing.   Once processed, Accounts Payable will provide a Vendor ID for each Research Participant which is used by the department when completing the EVoucher.
  • When a payment to an individual is $75 or less, the following must be attached to the EVoucher:
    • Name of Subject
    • Citizenship
    • If not a U.S. Citizen, the following information will also be needed:
      • Immigration (visa) status
      • Tax residency country (may not be the same as citizenship country)
      • Permanent foreign address
      • U.S. address
    • Mailing address

Paying Research Subjects with Gift Cards

Purchases of gift cards for research subjects are allowed for U.S. Citizens only and can be done by using either the Procurement Card or an EVoucher. 

  • For gift cards valued greater than $75, the completed Research Participant/Substitute W-9 form(s) should be faxed or hand delivered to Accounts Payable.  The recipient list should be attached to the Procurement Card or EVoucher used to purchase the gift cards and include the following information:
    • Gift card #
    • Gift card value
    • Gift card issue date
    • Recipient’s name
  • For gift cards valued at $75 or less, the recipient list should be attached to the Procurement Card or EVoucher used to purchase the gift cards and include the following information:
    • Gift card #
    • Gift card value
    • Gift card issue date
    • Recipient’s name
    • Recipient’s address

If the gift cards have not been issued to recipients when processing the Procurement Card or EVoucher, the information must be provided to Accounts Payable (Denise Hyche) as soon as the gift cards are distributed.  This must be done prior to the calendar year-end in which the cards were disbursed, but preferably as soon as the information is known.

Any gift cards that are purchased, but not distributed to research subjects can only be used for other purposes allowed within university policy.  Unused gift cards cannot be charged to sponsored projects. 

Paying Research Subjects with Cash

When payments for research subjects must be done using cash, a Request for Approval of Cash Advance must be submitted to the Accounting and Financial Reporting department.Procedures for requesting a cash advance can be found here: http://afr.fo.uiowa.edu/home/accounting-and-financial-reporting-listserv-information/miscellaneous-cash-advances

  • For cash disbursements greater than $75, the completed Research Participant/Substitute W-9 form(s) should be faxed or hand delivered to Accounts Payable. 
  • For cash disbursements of $75 or less, the department must maintain the following information:
    • Cash amount
    • Cash distribution date
    • Recipient’s name
    • Recipients complete mailing address

Tips for traveling with cash (http://afr.fo.uiowa.edu/cash-handlling/guidelinestips-traveling-cash)

Paying Research Subjects with Other Items of Value

  • When items of value greater than $75 are provided to research subjects, the completed Research Participant/Substitute W-9 form(s) should be faxed or hand delivered to Accounts Payable. 
  • When items of value are $75 or less, the department must collect and maintain the following information:
    • Item of value
    • Value of item (purchase price)
    • Recipient’s name
    • Recipients complete mailing address

Tax Considerations

  • Non-resident aliens
    • Federal regulations require that appropriate tax must be withheld at the time of payment.  The rate may vary from year to year.
    • At calendar year-end, a 1042S tax form is mailed to the individual to be used in preparation of his/her tax return.
  • Non-employees
    • Research subject payments to non-employees exceeding a total of $599 from all University of Iowa sources during any calendar year will result in a form 1099 (Miscellaneous Income) being issued to the individual with a copy sent to the Internal Revenue Service.
  • Employees
    • Research payment to University of Iowa employees will be issued separate from an employee’s monthly or bi-weekly payroll check.  All research subject payments are taxable income, but the employee will only receive a 1099 Form at year end if the accumulation of payments exceeds $599.