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Research Participant Incentive Payments

    • Last Updated: 06/13/2017
    • Effective Date:

    Policy Statement

    The University often conducts research where there is a requirement to obtain participation of and/or responses from individuals.  Researchers frequently find it necessary to offer incentives in order to obtain sufficient participation.  These incentives may be in the form of cash, checks, gift cards, non-monetary items or expenses paid on behalf of the participant.  All payments are subject to tax laws.  The University is required by IRS regulations to submit 1099 forms for all participants paid $600 or more per calendar year and must also adhere to the uniform administrative requirements set forth in OMB Uniform Guidance. 

    The Research Participant Incentive Policy has been in practice since the 1980's.  The original policy placed a $50 threshold on payments to human subject participants without requiring social security numbers for tax purposes; required payments to employees be processed as extra compensation (payroll); and required all payments to non-resident aliens, regardless of dollar amount, be processed by check request. 

    In order to meet the increasing needs of the research community, minimize the administrative burden, and comply with federal reporting requirements, the original policy was revised and the following guidelines provided: 

    • Subjects are defined as individuals who participate in research, and include but are not limited to individuals from the community or local schools; UGA employees, students, or retirees; and non-resident aliens.
    • Participant payments or events should be detailed in the sponsor-approved budget, if they are to be paid from sponsored accounts.
    • A subject receiving an incentive payment of $100 or less is not required to provide his/her social security number unless the Principal Investigator anticipates that the subject will receive subsequent incentive payments that will total $600 or more during the calendar year.
    • A subject receiving an incentive payment in excess of $100 is required to provide his/her social security number.  The only exception to this requirement is for a subject participating in a study where the IRB has approved a waiver of signed consent form according to 45 CFR 46.117(c)(1)(i.e., that the consent form is the only record linking the subject to the research and the principal risk would be potential harm resulting from a breach of confidentiality.)  Refer to http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.html#46.117 Non-resident alien participants will be subject to 30% tax withholding unless they are participating in studies with an IRB approved waiver of signed consent form as described above.
    • Methods of incentive payments regardless of amount include:
      Cash
      Check
      Gift Cards
      Non-monetary items (t-shirts, books, etc.) 

            Expenses paid on behalf of the participant for group events

    Reason for policy
    To define the requirements for incentive or pre-incentive payments made to research participants in IRB-approved studies or participation in other creative studies.
    Procedures

    The University often conducts research where there is a requirement to obtain participation and/or collect information from participants. These participants may include any individual necessary for the research being conducted, i.e. external individuals, UGA employees, students, retirees, non-resident aliens, etc.  Researchers frequently find it necessary to offer incentives in order to obtain sufficient participation. These incentives may be in the form of cash, gift cards, checks, or non-monetary items and are subject to Internal Revenue tax laws. There are specific rules that must be followed in order for the university to remain in compliance.  In order to meet the needs of the research community, minimize the administrative burden, and comply with federal and tax reporting requirements, the following guidelines for choosing and processing a method of payment, as well as recordkeeping requirements, are provided.

    Guidelines for choosing method of payment:

    The researcher has several payment options available for incentive payments:

                Cash (includes cash and checks from a petty cash account)

                Gift Card

                Check (includes checks processed through Accounts Payable via UGA check request)

                Non-monetary items (T-shirts, books, etc.)

                Expenses paid on behalf of the participant for group events

     

    Depending on the amount and method of payment, the following conditions and requirements apply:

    1.      Participant receiving an incentive payment of $100 or less.

    A.    Cash or Gift Card payment:  No collection of the participant’s social security number is requiredunlessthe researcher anticipates that the participant will receive incentive payments, from all sources, totaling $600 or more during the calendar year.

    B.     Check payment:  No collection of the participant’s social security number is requiredunlessthe researcher anticipates that the participant will receive incentive payments, from all sources, totaling $600 or more during the calendar year.

    C.     Non-monetary items:   No collection of the participant’s social security number is requiredunlessthe researcher anticipates that the participant will receive incentive payments, from all sources, totaling $600 or more during the calendar year.

    D.     Expenses paid on behalf of the participant for group events:  No collection of the participant’s social security number is required for training and other group sessions.  Departments are to document participants attending each event to support charges posted.  Best practice includes a sign in sheet for each session / event.  If HIPPA laws apply, the sign in sheet may be kept confidential at the department level.  Otherwise a copy should be attached to items submitted for payment.

    2.      Participant receiving an incentive payment over $100: 

    A. Cash or Gift Card payments:  The participant is required to provide his/her social security number except when participating in a study where the IRB has approved a waiver of a signed consent according to 45 CFR 46.117(c)(1)(i.e. that the consent form is the only record linking the subject to the research and the principal risk would be potential harm resulting from a breach of confidentiality).  Refer to http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46.117 Non-resident alien participants will be subject to 30% tax withholding except when participating in a study where the IRB has approved a waiver of a signed consent according to 45 CFR 46.117(c)(1)(i.e. that the consent form is the only record linking the subject to the research and the principal risk would be potential harm resulting from a breach of confidentiality). 

    B. Check payment:  The participant is required to provide his/her social security number except when participating in a study where the IRB has approved a waiver of signed consent according to 45 CFR 46.117(c)(1)(i.e. that the consent form is the only record linking the subject to the research and the principal risk would be potential harm resulting from a breach of confidentiality). Refer to http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46.117 Non-resident alien participants will be subject to 30% tax withholding except when participating in a study where the IRB has approved a waiver of a signed consent according to 45 CFR 46.117(c)(1)(i.e. that the consent form is the only record linking the subject to the research and the principal risk would be potential harm resulting from a breach of confidentiality). 

    C.  Non-monetary items:  The participant is required to provide his/her social security number except when participating in a study where the IRB has approved a waiver of signed consent according to 45 CFR 46.117(c)(1)(i.e. that the consent form is the only record linking the subject to the research and the principal risk would be potential harm resulting from a breach of confidentiality). Refer to

    http://www.hhs.gov/ohrp/humansubjects/guidance/45cfr46.htm#46.117 

    3.      Incentive payments being paid from restricted (i.e., sponsored) accounts should be detailed in the sponsor approved budget. Contact the Post Award Accounting at 706-227-7222 for assistance.

    University processes for payment methods

    1. Cash payments:

    Step 1:       Establish a petty cash fund

    Complete the Application for Research Participant Compensation Fund located at http://www.busfin.uga.edu/forms/compensation_fund.pdf. Submit the completed form to the Bursar’s Office with a letter of explanation, signed by the department head/dean/director and the fund’s custodian, regarding the purpose of the fund and an analysis justifying the dollar amount requested.

    The petty cash custodian must follow the appropriate guidelines necessary for effective petty cash management.  These guidelines include but are not limited to the following:

    A.    establishing a bank account from which you can obtain cash or write checks to provide payments according to the petty cash policy

    B.     providing a written reconciliation of the fund to the Bursar’s office periodically and at the end of the study;

    C.     ensuring the safety and security of the fund;

    D.    holding the fund account separately from all other accounts and not commingling personal funds with the petty cash funds;

    E.     ensuring that expenditures from the fund comply with all legal and regulatory requirements, and university policies; and

    F.      promptly cooperating with the Internal Auditing Division during periodic physical audits.

    Step 2:       Disburse and record cash payments

    There should be a dated, chronological record of the original entry for each individual payment. Any method is acceptable for payments of $100 or less, as long as an audit trail is maintained. Examples include receipt forms or a cash journal/log.

    For incentive payments of $100 or less, a log may be used with a minimum of the participant name or identifying number, amount of incentive received, and the participant’s signature or check mark (no signature). If no participant signatures are obtained, the Principal Investigator must sign the log as documentation that the payments were disbursed.  An example log form may be found at:

    http://www.busfin.uga.edu/forms/Log_ResearchParticipantPayment.pdf

    In lieu of the log form, the following receipt form may also be used for recording the payment of $100 or less:

    http://www.busfin.uga.edu/forms/Research_Participant_Receipt_under.pdf

    For incentive payments over $100, the following receipt form must be completed:

    http://www.busfin.uga.edu/forms/Research_Participant_Receipt_over.pdf

    Step 3:       Reimburse petty cash

    Reconcile the petty cash account and attach log or appropriate receipt to the petty cash voucher for reimbursement and forward to the Accounts Payable Division

    For additional information, refer to the Petty Cash and Change Funds Policy and the Petty Cash and Cash Purchases procedure.

    If additional assistance is needed, contact the Bursar’s Office at 706-542-1625 or Accounts Payable at 706-542-2786.

    2. Gift card payments:

    Step 1: Establish a petty cash fund

    Complete the Application for Research Participant Compensation Fund located at http://www.busfin.uga.edu/forms/compensation_fund.pdf to obtain gift cards. Submit the completed form to the Bursar’s Office with a letter of explanation, signed by the department head/dean/director and the fund’s custodian, regarding the purpose of the fund and an analysis justifying the dollar amount requested.

    WalMart gift cards are available through the Bursar’s Office. Allow 4 months to obtain gift cards from other vendors. 

    The petty cash custodian must follow the appropriate guidelines necessary for effective petty cash management.  These guidelines include but are not limited to the following:

    A.    establishing a bank account from which you can obtain cash or write checks to provide payments according to the petty cash policy

    B.     providing a written reconciliation of the fund to the Bursar’s office periodically and at the end of the study;

    C.     ensuring the safety and security of the fund;

    D.    holding the fund account separately from all other accounts and not commingling personal funds with the petty cash funds;

    E.     ensuring that expenditures from the fund comply with all legal and regulatory requirements, and university policies; and

    F.      promptly cooperating with the Internal Auditing Division during periodic physical audits.

    Step 2:       Disburse and record gift card distributions

    There should be a dated, chronological record of the original entry for each individual payment. Any method is acceptable for payments of $100 or less, as long as an audit trail is maintained. Examples include receipt forms or a gift card journal/log.

    For incentive payments of $100 or less, a log may be used with a minimum of the participant name or identifying number, amount of incentive received, and the participant’s signature or check mark (no signature). If no participant signatures are obtained, the Principal Investigator must sign the log as documentation that the payments were disbursed.  An example log form may be found at:

    http://www.busfin.uga.edu/forms/Log_ResearchParticipantPayment.pdf

    In lieu of the log form, the following receipt form may also be used for recording the payment of $100 or less:

    http://www.busfin.uga.edu/forms/Research_Participant_Receipt_under.pdf

    For incentive payments over $100, the following receipt form must be completed:

    http://www.busfin.uga.edu/forms/Research_Participant_Receipt_over.pdf

    Step 3:       Reimburse petty cash

    Reconcile the petty cash account and attach log or receipt to the petty cash voucher for reimbursement and forward to the Bursar’s Office.

    For additional information, refer to the Petty Cash and Change Funds policy and the Petty Cash and Cash Purchases procedure.

    If additional assistance is needed, contact the Bursar’s Office at 706-542-1625.

    3.  Check payments: 

    There are two methods you may use to make a research participant’s incentive payment by check. The first method is through a check written from a petty cash account (the procedures for issuing a check via this method are outlined in item 1: Cash Payments above). The second method is to initiate a check request through the Accounts Payable Department. When creating the electronic check request, please select "Research Participant" for the type of request in the Request Information Section. For additional information regarding the Electronic Check Request policies and procedures, see the Electronic Check Requests.

    If additional assistance is needed, contact the Procurement Office at 706-542-7066 regarding check requests or the Bursar’s Office at 706-542-1625 regarding petty cash.

    4. Non-monetary items: 

    Non-monetary items (T-shirts, books, etc.) are acquired by the research unit. Regardless of the method by which the research unit obtains non-monetary items for use as incentive payments to research participants, these items are considered payments and must be tracked. Likewise, reasonable measures must be in place to safeguard and secure the non-monetary items.

    Step 1:       Obtain non-monetary items

    Non-monetary items may be obtained either through a petty cash account or purchase order. The procedures for establishing and using a petty cash account are the same as step 1 under item 1: Cash Payments above. The procedures for purchase requests are located at Purchase Requests.

    Step 2:       Disburse and record non-monetary gift distributions

    There should be a dated, chronological record of the original entry for each individual payment of a non-monetary item. Any method is acceptable for such payments valued at $100 or less, as long as an audit trail is maintained. Examples include receipt forms or a journal/log.

    For incentive payments valued at $100 or less, a log may be used with a minimum of the participant name or identifying number, amount of incentive received, and the participant’s signature or check mark (no signature). If no participant signatures are obtained, the Principal Investigator must sign the log as documentation that the payments were disbursed (i.e., non-monetary items were distributed).  An example log form may be found at:

    http://www.busfin.uga.edu/forms/Log_ResearchParticipantPayment.pdf

    In lieu of the log form, the following receipt form may also be used for recording the payment of $100 or less:

    http://www.busfin.uga.edu/forms/Research_Participant_Receipt_under.pdf

    For incentive payments valued over $100, the following receipt form must be completed:

    http://www.busfin.uga.edu/forms/Research_Participant_Receipt_over.pdf

    Step 3:       Reconcile appropriate accounts

    Reconcile account(s) from which non-monetary items were obtained. If paid by a petty cash account, attach purchase receipt and disbursement log/receipt to the petty cash voucher for reimbursement and forward to the Bursar’s office.  If paid by purchase order, retain log/receipt until the participant total incentive exceeds $600 for the calendar year.  These receipts should be then forwarded to Accounts Payable for IRS tax reporting.

    5. Items paid on behalf of participants:  Training events and other group sessions outlined in the budget of sponsored accounts may be direct charged. An agenda and dated sign in sheet is to be kept as backup for these charges. 

    For additional information, refer to the Petty Cash Funds policyand Change  and the Petty Cash and Cash Purchases procedure and the Purchase Request procedure.

    If additional assistance is needed, contact the Bursar’s Office at 706-542-1625 regarding petty cash and the Procurement Office at 706-542-7066 regarding purchase orders.

    Forms/Instructions
    Additional contacts
    Policy definitions

    IRS - Internal Revenue Service

    IRB - Institutional Review Board

    1099 - Miscellaneous Income Tax Form

    Human Subjects (Research Participant) Payment - Any form of direct or indirect inducement offered or received in exchange for enrolling individuals in human subjects research that is paid as reimbursement in excess of the reasonable cost of utilizing human subjects.

    Responsibilities

    Responsible University Senior Administrator: Vice President for Finance & Administration

    Responsible University Administrator: Associate Vice President and Controller

                Policy Owner: Post Award Accounting

                Policy Contact: Gail Chester

                Phone Number: 706-542-9230
    Record Retention

    This series provides a record of the establishment and administration of individually sponsored grant and contract restricted funds accounts, documents compliance with fiscal reporting requirements, and includes billing information for accounts receivable from sponsoring agencies and from departments for gift account fees. Grants may be federal, state, corporate, or private. This series may include but is not limited to: project summaries; grant authorizations; contract documents; project budget change and adjustment forms; invoices; receipts; cashier's receipts; equipment purchase orders; prior approval request forms; account request forms; vendor telephone contact logs; subcontracts; sponsored programs post award accounting monthly budget summary statements; institution billings balance sheets; reports for sponsored programs post award accounting that are operating on direct payments; final financial reports; property reports; patent/invention reports; contractor's release report; assignment of refunds and rebates documents; equipment disposition reports; and related documentation and correspondence.

    Record Copy: Institutional Archives; Post Award Accounting

    Retention: Contracts, patents, and agreements for use of research outcomes: Permanent. All other accounting records: 7 years after final financial report is submitted and the account is closed, unless otherwise specified as longer by the terms of the contract

    Citation or Reference: OMB Uniform Guidance; BOR Research Grant Records 0472-09-006