Research Subject Compensation Policy

This policy is effective 1/1/2017


University research projects may compensate individuals (research subjects) for their participation in the research project in accordance with an approved IRB protocol. 

Reimbursements for travel or other costs are not included under this policy.

The University is responsible for properly accounting for all payments made to individuals to ensure fiscal accountability and meet Federal reporting obligations.  This policy is designed to provide documentation and reporting guidance to University faculty/staff involved in processing payments to research subjects while still maintaining appropriate levels of confidentiality and minimizing administrative burden when possible.

The IRS treats research subject payments – checks, cash, gift cards or other items of value – as taxable income to the recipient.  IRS reporting requirements for the University depend on the amount paid and the recipient’s tax status.  For U.S. Citizens or lawful permanent residents, the University is required to report the Name, Address, and Tax ID (Social Security Number) of any individuals who receives payments of $600 or more in a calendar year.  For non-resident aliens, the University is required to report the payments, regardless of amount of payment, and withhold 30% from the payment.


  • Faculty/staff responsible for authorizing/disbursing payments to research subjects are required to collect the appropriate information and use the appropriate payment method/procedure based on the dollar threshold, as follows:
    • For payments that are $100 or less AND the research subject is not expected to receive cumulative payments in excess of $600 for the calendar year, payments can be processed with a University check, cash, gift card or other items of value.  A record (disbursement log, spreadsheet, cash disbursement journal, etc.) of subjects being paid must be maintained in the Department issuing the payments.
    • For payments greater than $100 OR the research subject is expected to receive cumulative payments greater than $600 for the calendar year OR the research subject is a non-resident alien, payments must be processed with a University check and the recipient must complete the Participant/Substitute W-9/W-8BEN form.  The completed form(s) must be provided (either faxed or hand delivered) to Account Payable in order to process the eVoucher.
  • All payments must be supported by source documentation.  Documentation must be retained in accordance with the University’s record retention policy.  In the event of an IRS or sponsor audit/request, it is the responsibility of the PI and their unit to provide appropriate source documentation applicable to the payment method to support each payment. 
  • Any University faculty or staff who will handle the payment (i.e. cash, gift cards, or other items of value) must adhere to the University Cash Handling Policy & Procedure which requires an approved Desktop Cash Handling Procedure and required certification process. An approved cash handling procedure will include:
    • Proper segregation of duties between those who request, approve and have control over payments.
    • Tracking, inventory, and logging of disbursements. 
    • Controlled access to the payments.
  • All research subject payments must be recorded in the University general ledger using institutional account 6240-Research Participation Subject.
  • Payments should not be charged to the research project until disbursement.  Any payments that are not distributed (i.e. unused gift cards) cannot be charged to the research project.
  • Research subjects will be asked to provide basic information including name, mailing address and, in some cases, 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 (IRB) requires this notification in the language of the Consent Form.
  • This policy applies to all IRB approved human subjects research, including research IRB approved under an exemption category of review.  The only exception allowed is when the IRB has approved a waiver of documentation of consent in order to protect the identity of the research subject.

Related Procedure

Research Subject Compensation Procedure

Last updated 04/23/2024