Guidelines for Compensation to Human Research Participants

Guideline Scope and Introduction

Research studies done by Bradley affiliated researchers that involve human subjects must be reviewed and approved by Bradley’s Institutional Review Board (IRB), known at Bradley as the Committee on the Use of Human Subjects in Research (CUHSR). When compensation or incentives are given to research participants, CUHSR works together with the Office of Sponsored Programs and Bradley’s Financial Services to comply with Federal regulations to properly pay participants. When participants are paid by researchers, they must comply with the Bradley University payment procedures and satisfy Internal Revenue Service (IRS) reporting obligations. The personal information obtained when following these guidelines is confidential. A host of ethical issues surround the issue of payment and incentives for research participants. A thorough discussion of those issues can be found at this HHS.gov link.

General Guidelines

1. Human subjects participating in research are not paid to provide a service to the university as an employee. Payment to subjects for participation in studies is not considered a benefit but a recruitment incentive.
2. Per federal tax law Bradley Financial Services must issue to individuals receiving “miscellaneous income” a 1099 form when either an individual payment or the sum of all payments, regardless of origin, exceeds $600 in a calendar year. Thus, all investigators who are using Bradley funds (any University funds including grant awards) are required to track incentive payments, provide participants with an informed consent document, and notify Financial Services when either an individual payment or cumulative payments approach $600.00 in a calendar year (see procedures below).
3. If Financial Services reports funds distributed to an individual participant to the IRS, anonymity of such participant cannot be maintained. The information provided to the IRS does not identify the recipient as a study participant or the purpose of the payment.
4. The Principal Investigator (PI) is responsible for informing research participants that the value of any payment they receive for participating in research studies may be taxable income. This is done in the informed consent process. See the last several pages of this document for possible informed-consent language.
5. If the participant is not a U.S. Citizen, please refer to the Payment to Non US Citizens sections under special circumstances in this document.
6. Remuneration from Bradley University include cash or check, gift cards and gift certificates, electronic gift cards, electronic transfer and value of tangible items.
7. Distribution of monetary funds at any amount must be recorded – see the procedures below.
8. For payments greater than $100.00, the researcher must contact Financial Services.
9. If Bradley students receive compensation for participating in a human subject study, the research team must clearly articulate that receiving such compensation may impact financial aid because the federal government treats remunerations of this type as income. The research team is responsible for sharing the names of student participants with Financial Services and the dollar amount of payments (or value of goods or services) they have received regardless of amount.

Procedures

1. Tangible items. Tangible items (not gift cards) that are valued below $50.00 do not need to be reported or recorded. Examples of tangible items include but are not limited to: clothing, mugs, pens, food, etc.
2. For other studies when monetary amounts (cash, gift cards or prizes, etc) are distributed in any amount up to and at $100 (or tangible items valued above $50.00 and not more than $100) the Research Participant Receipt form must be filled out. Follow the instructions on the bottom of the form.
3. For studies when monetary amounts (cash, checks, gift cards or prizes, etc) are intended to be distributed in any amount beyond $100 the researcher must contact financial services to work out the most appropriate procedures to pay participants. Participants may need to fill out applicable tax forms and provide their social security number before being paid.
4. When cash is needed to pay participants, the researcher will need to fill out a Bradley University Advance Request Form.

Special Circumstances

1. Personal funds
   1. Personal funds are out of pocket expenses that will not be reimbursed by any University account.
   2. Because no University funds are used, the individual researcher does not need to report the payment to Financial Services.
   3. Because it is up to the recipient of the funds to report payment to the IRS, include a tax statement in your consent form. See the consent language page suggestion on wording in this situation.
   4. Disburse the funds exactly how you specified in your CUHSR application.
2. Non-U.S. Citizen or Non-US National (aka nonresident alien)
   1. Payroll will withhold a 30% federal tax on any payment to a non-U.S. citizen or national, unless the non-resident can claim a tax treaty benefit.
   2. The participant must file a Foreign National Information Form (IRS Form 8233) to claim an exemption or reduced tax based upon an applicable treaty.
3. Third-party Vendors- If a third-party vendor is used to identify and pay participants, you must provide CUHSR with documentation that the vendor is in compliance with IRS policies if the vendor is not on the approved list.
   1. Note: Inclusion of a vendor on the list is not an endorsement, but rather it indicates that the vendor is known to be in compliance with IRS policy.
   2. Approved third-party vendors:1) Amazon Mechanical Turk, 2) Qualtrics

References

1. IRS Form 1099-MISC, Miscellaneous Income: https://www.irs.gov/forms-pubs/about-form-1099-misc
2. IRS Form 8233, Exemption from Withholding on Compensation for Independent (and Certain Dependent)
3. Personal Services of a Nonresident Alien Individual, https://www.irs.gov/forms-pubs/about-form-8233