Research Participant Incentive Payments
Post Award Accounting
View policy pdf: Research Participant Incentive Payments Policy
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:
Non-monetary items (t-shirts, books, etc.)
Expenses paid on behalf of the participant for group events
Responsible University Senior Administrator: Vice President for Finance & Administration
Responsible University Administrator: Associate Vice President for Finance Division
Policy Owner: Post Award Accounting
Policy Contact: Gail Chester
Phone Number: 706-542-9230