Procedure: 103-Payments to Human Subjects
- Payment to Individual Instructions
- UW-Madison Human Research Protection Program
- Health Insurance Portability & Accountability Act (HIPAA)
- Step by Step Instructions for Obtaining IRB Approval for Human Subjects Research
Statement of Procedure:
Follow the below procedures when making payments to human subjects.
Payments of less than $100 (de minimis payments)
- Custodian Funds and Payments to Individual Reports (PIRs) – Custodian Funds and PIRs may be used to make de minimis payments of less than $100.00. Departments are encouraged, but not required, to obtain a social security number from the subject when disbursing de minimis research subject payments.
Payments of less than $300
- Payment to Individual Report (PIR) – Payments of any amount can be processed on a Payment to Individual Report (PIR). A check is issued directly to the research subject. Follow the Payments to Individuals (PIR) Policy and Procedures and the below Taxation and Identification Requirements.
- Custodian Funds – The Custodian (Principal Investigator) can make payments directly to research subjects via check, gift card, or cash. Follow the Custodian Funds Policy for all payments from replenishable or temporary custodian funds. The Custodian is personally responsible for determining the amount of the advance and complying with Taxation and Identification Requirements.
Payments of $300.00 or more
- Payment to Individual Report (PIR) – All payments of $300.00 or more must be processed on a Payment to Individual Report (PIR). A check is issued directly to the research subject. Follow the Payments to Individuals (PIR) Policy and Procedures and complying with Taxation and Identification Requirements.
Note: Payments to Human Subjects are to be paid by the methods listed above only. Employees are not to pay these costs using P-Cards or personal funds and seek reimbursement.
Per the Internal Revenue Service regulations, information on participants in research studies must be obtained for tax reporting purposes. Dean/Director’s or their designees are responsible for monitoring the dollar amounts and frequency of human subject payments to ensure tax compliance. If an exception exists, it should be noted on the PIR or Custodian Fund Request Form.
Documentation Requirements for use of Custodian Funds
Human Subjects Recipient Log must be completed for all payments. A copy of the log must be attached to the Custodian Fund Accounting Form to account for the distribution of custodian funds. A W-9 must be attached to the log for each individual receiving a payment of $100 or more. The completed log must contain the following information for each participating recipient:
- Amount Paid to Each Recipient
- Name or Recipient Identifier
- Date Received by Recipient
- Check number or Gift Card Identifier
- Signature or Initials of Each Recipient
Who should know this procedure?
Deans, Directors, and staff handling payments to human subjects.
For tax questions contact Jose Carus.