Human subjects participating in university research projects are often compensated for their time and commitment with cash or non-cash items. Principal investigators (PIs) and other faculty/staff members who are conducting sponsor funded research or internally funded research are responsible for ensuring that subjects are eligible to receive payments (in accordance with U.S. Tax and Immigration laws) and for ensuring that the payment process is appropriate.
Managing Research Subject Payments
There are a number of possible mechanisms for paying human subjects, but whichever method is chosen must be approved by the Institutional Review board as part of its review and approval of the study protocol.
Options for Payment
Subjects may be paid by:
- cash from a human subjects petty cash account
- check from a human subjects checking account
- gift card (physical or electronic)
- check as a miscellaneous payment through Accounts Payable
To comply with taxation requirements, payments must be made through AP for amounts:
- > $500 per subject per calendar year for US citizens and resident aliens
- > $100 per subject per year for non-resident aliens
Human Subject Cash and Checking Accounts
To establish either a petty cash account or a checking account for the purpose of paying study participants, a Human Subject Petty Cash Fund Information Sheet, signed by the Principal Investigator (PI) and the Chair/Dean, is submitted to the Grants Accounting department. Once the account has been established by Grants Accounting, additional funds can be requested using the Human Subjects Account Replenishment form.
With each payment, the account custodian should complete a Human Subject Payment Receipt and have it signed by the subject. The receipts must be maintained securely and confidentially with the project records.
Gift cards may be used for single payments, or payments in aggregate, of up to $100 per subject, per protocol, per year, for all research subjects. Although gift cards are somewhat similar to cash or checks in their use, the mechanism by which they are managed is quite different.
Gift Card Purchase
Gift cards are obtained through Workday Procurement, using standard department procedures. It is important to order only the number of cards that will used because there is no mechanism for returning gift cards that have been purchased but not distributed to subjects. The cost of gift cards remaining at the end of the project will be transferred from the project to the department associated with the project and become department property.
Gift Card Distribution
When a subject has completed participation in the study, the account custodian should issue a gift card, complete a Human Subject Payment Receipt, and have it signed by the subject. The receipts must be maintained securely and confidentially with the project records. A separate receipt is required for each gift card distributed.
Gift Cards Reconciliation on a Sponsored Project
While a project is active, the value of undistributed gift cards (gift cards on hand), plus the value of all Human Subject Payment Receipts retained by the project should equal the amount of expense charged to the project for gift cards. When a project is completed, any undistributed gift cards should be given to the appropriate department and the charges for these gift cards should be transferred from the project to the department. A final reconciliation of gift cards on a project should confirm that the value of all Human Subject Payment Receipts retained in the project files is equal to the total expense for gift cards charged to the project.
Mailing Gift Cards
If gift cards are to be mailed to the human subject in exchange for completing a survey or other purpose that makes collecting subject signatures impractical, the reconciliation is still required.
- there should be two employees in the room at all times while the gift cards are prepared for mailing
- project personnel must keep a list of recipients with all the demographic information required on the Human Subject Payment Receipt (including the address to which the gift card is being mailed)
- both employees are required to sign the list
- the unit's SFO is also required to sign the list
Payment through Accounts Payable
This payment method can be used for all research subject payments to U.S. citizens and residents. Its use is required for payments > $500 per subject, per protocol, per year to U.S. citizens or residents. Payment recipients automatically receive a 1099 form from the university.
Payments to Nonresident Aliens
Special processing requirements apply to payments to nonresident aliens. The university must comply with regulations of both the IRS and the Department of Homeland Security. The rules regarding payments to nonresident aliens are complex and the penalties for violations are harsh and can include deportation from the United States. For additional information contact the Grants Shared Services Center.
Ohio State is piloting two other methods for human subjects payments:
- Greenphire reloadable gift cards, primarily for clinical research studies
- Amazon Mechanical Turk (also known as AMT or MTurk), for survey research
Additional information will be provided if these methods are opened campuswide.