Human Subject Payment Guidelines

Payment or non-monetary rewards may be given to subjects as remuneration for the time and inconvenience of engaging in a research study, as well as incentive to participate. 

Guidelines for handling cash and cash equivalents as payments to human subjects: 

  • Gift cards, cash and prepaid cards must be stored in a lockable receptacle (up to $1000) or safe ($1000+) in a campus facility
  • No more than two individuals (a primary custodian and a back-up) should have access to the stored payment instruments
  • The quantity of gift cards and cash kept on hand should be limited to meet the short-term need, i.e., for two weeks of disbursements; an efficient process to replenish the card stock or cash should be established and routinely executed
  • Purchasing non-returnable gift cards is discouraged; however, if gift cards are the payment method used, the contract/grant must be reimbursed for any undisbursed gift cards
  • In situations where the custodian provides a researcher with a batch of gift cards for later disbursement to subjects, a detailed record of the transfer must be kept for audit purposes
  • When payment is made in person, the subject must sign a disbursement log to acknowledge receipt
  • The custodian must maintain written records, in conjunction with principal investigator certification, that the payments are correct and consistent with the relevant IRB approval
  • The Principal Investigator, grant administrator or business officer must conduct a periodic reconciliation by taking the beginning balance of card stock or cash, plus new cards procured or cash replenishments, less disbursements, and comparing the results to the physical card inventory or cash on hand
  • When appropriate, the number of payments issued should be accounted for by comparing the disbursements to the number of human subjects meeting the eligibility criteria for payment (i.e., submitting a survey, attending a session, etc.)
  • Researchers and payment custodians must maintain adequate segregation of duties related to monitoring the subject’s eligibility for payment, and obtaining, safeguarding, distributing and reconciling gift cards and cash
  • Per IRS rules, compensation to any single individual of $600 or more in single tax year must be reported on a Form 1099-MISC; research administrators may be required to collect the subject’s name, SSN and address to ensure reporting compliance.