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Scope

This document describes how human research Participants taking part in a study approved by the campus Institutional Research Board (IRB) are compensated for participating in University research projects.  This policy provides authoritative guidance regarding issuing and controlling payments to research study Participants.

Reason for Policy

This guideline is necessary to ensure the proper handling of confidential research subject information and ensure compliance with reporting requirements associated with compensating research study Participants. 

Policy Statement

All payments to human Participants are treated with utmost confidentiality. Research studies often involve individuals who participate in the study. As needed, Participants may be compensated for their participation. The method of compensation should be designed to:

• Ensure the confidentiality of research Participants
• Provide timely, convenient compensation to Participants to facilitate, not hinder, the study
• Record compensation in the accounting system for both financial records and IRS Form 1099 purposes
• Document that compensation was for participation in a study
• Ensure appropriate internal controls and adequate safeguards exist for items of value used to compensate, whether Cash, checks or other

Determining Method of Compensation
The method of compensation must be determined before the research begins and should take into account the following:

• Confidentiality
• Nature and subject matter of the study
• Nature of the Participant population
• Dollar amount and time period of payments
• Variability in the amount of payments
• Number of payments and Participants involved in the study
• Location of the study

If the ChartField string debited for the subject payments is a sponsored project and involves payments other than checks or Cash, the department may consult Sponsored Program Office to ensure that the sponsor allows this type of payment. If there are no sponsor restrictions, then the PI should ensure that all allowability criteria are met in accordance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR 200 and the terms and conditions of the award. SPO can help request approval from the sponsoring agency, if necessary.

Available Methods of Compensation
Research Participants could receive funds from the University for reimbursement and/or compensation.  

The types of payments to Participants may include:

• Reimbursement to a participant, such as mileage.
• Paying expenses associated with participant, such as hotel or rental car.
• Compensation payment direct to participant via:
  • Check
  • Gift Card – prior approval required from Campus Accounting
  • Cash
  • Merchandise
  • Survey Resource

Control and Distribution of Non-Cash Items and Cash
Non-Cash items should be controlled similar to Cash using an approach to ensure that the items are secured and used for their intended purpose. For non-Cash items and Cash, the department must create control procedures.

• Segregation of Duties: Establish a purchase, documentation and distribution process to ensure duties are segregated between these roles.
• Purchase: Document Cash/items purchased, including any control numbers.
• Security: Store the Cash/items in a secure locked location until distribution to research Parti