Payments to Research Subjects Policy

University research projects may require the participation of human subjects. Often, these individuals receive payments - in the form of cash, checks or non-cash items - for their participation. Principal investigators (PIs) and other faculty/staff members who are conducting sponsor funded research or internally funded research are responsible for:

• informing all subjects that any payment received for participation, regardless of amount, is taxable income
• ensuring that subjects are eligible to receive payments (in accordance with U.S. Tax and Immigration laws)
• ensuring that the payment process is appropriate (e.g. not providing subject payments from personal funds and seeking reimbursement).

Generally, the same procedures pertain no matter whether subjects are paid from sponsored projects or department funds. Differences are noted below. Also all references to a year mean a calendar (or tax) year.

For payments, both cash and non-cash, of up to $100/subject/calendar year, it is not necessary to determine the citizenship status of the research subject. However, for single payments of more than $100, or when it is anticipated that a subject will receive multiple payments from a single research protocol that will add up to more than $100 in a calendar year, a potential subject’s citizenship status must be reviewed before the subject is enrolled in the study. The review is intended to ensure that the person’s visa category allows them to receive income from the university. Payments to nonresident aliens that will exceed $100 in a calendar year must be processed through University or OSURF Accounts Payable, depending on the source of funds. For payments processed through Accounts Payable, each research subject is required to complete an AP Compliance Form (substitute W-9).

University employees may receive research subject payments like any other subject, provided that their participation is entirely voluntary and is clearly unrelated to their employment duties. Payments should be processed in accordance with this policy.

PIs and other faculty/staff conducting research are required to collect names and signatures from the recipients of cash payments or non-cash gifts. To provide for subject confidentiality, the subject list is maintained by the PI in the study file, and an anonymous log (for example, a listing of the date, amount, and a subject study number) is provided to the department or OSURF to document the use of funds.

For OSURF research subject payments greater than $500/subject/year (or greater than $100 for non-resident aliens), an exception to the requirement to submit an OSU AP Compliance Form may be granted if the study is of a highly sensitive nature and a Certificate of Confidentiality has been secured from the Department of Health and Human Services. After receiving the Certificate of Confidentiality, Principal Investigators must obtain approval from their College Associate Dean for Research and from their Senior Fiscal Officer before submitting a formal request to the OSURF Manager of Accounts Payable. If the exception results in any IRS tax liabilities, these amounts will be charged to the PI’s college.

The following table summarizes the procedures for payments to research subjects. The companion document, Managing Research Subject Payments, provides additional details on the various payment methods.