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KUMC Research Participant Incentive Payment Policy

Policy
Purpose: 

Define the requirements for the payment of research participants under the University of Kansas Medical Center Institutional Review Board, (IRB), approved protocols for compliance with federal, State of Kansas, and University of Kansas Medical Center Research Institute, Inc. (KUMCRI) policies and procedures.

Applies to: 

The University of Kansas Medical Center (KUMC), the KU Medical Center Research Institute, Inc. (KUMCRI), and each of their affiliated entities engaged in the conduct or administration of research supported by KUMC and KUMCRI.

Campus: 
Medical Center, Kansas City
Wichita
Salina
Policy Statement: 

Incentive payments for research participants must be made in compliance with federal and State of Kansas tax rules and regulations, KUMCRI policies and procedures, as applicable, in addition to strict adherence to the IRB-approved protocol that authorizes the incentive payment.

Social Security Numbers (SSN) or Taxpayer Identification Numbers (TIN):  Social Security Numbers or Taxpayer Identification Numbers must be collected for all research participants paid from KUMCRI funds regardless of the amount of payment, except in very rare circumstances when an exception is granted prior to the payment of the research incentive. Federal tax laws require entities that make payments to an individual of $600 or more in the calendar year to report the payment on an IRS Form 1099.  This federal requirement is the basis for the collection of SSNs or TINs for all incentive payments, regardless of the amount.  Participants may receive incentives from more than one research program, so it is important to have procedures in place to assist with tracking of all payments over the course of a calendar tax year.

KUMCRI encourages payment of research subject incentives through the ClinCard System whenever possible to increase confidentiality of participant information and to streamline the payment and reporting processes and compliance requirements.

Methods of Payment: 

  1. ClinCard System – This is the preferred form of payment, as it is the most flexible and secure. KUMCRI has engaged the services of Greenphire’s ClinCard system to increase security of data, to reduce risk to the university, to provide the greatest flexibility to the researchers, and to manage payments more efficiently. 
  • The ClinCard system’s default setting requires the collection of SSN.  SSN data is entered directly into the secure ClinCard system and not maintained in KUMCRI systems.
  • The ClinCard system may be used only for funds held by KUMCRI.
  1. Gift Card Payments – This method carries higher security risk because of the “cash equivalent” nature of gift cards and holding SSN information, and therefore requires prior authorization.
  • The participant is required to provide an SSN or TIN. 
  • The purchase and distribution of gift cards must be strictly controlled using appropriate internal controls - for disbursement, accounting, and reporting, which include being monitored by two university employees.
  • KUMCRI requires use of the Subject Incentives Form; link is below.
  1. Cash Payments – Payment of cash carries the same higher security risks as gift cards and also requires prior authorization.
  • The participant is required to provide an SSN or TIN. 
  • The cash payments must be strictly controlled using appropriate internal controls for disbursement, accounting, and reporting, which include being monitored by two university employees.
  • KUMCRI requires use of the Subject Incentives Form; link is below.
  1. Non-monetary items –
  • The participant is required to provide an SSN or TIN. 
  • Disbursement of non-monetary items must be strictly controlled using appropriate internal controls for disbursement, accounting, and reporting, which include being monitored by two university employees.
  • A statement regarding the fair market value for possible tax reporting purposes of the item must be provided to the participant.
  1. Direct Payments –
  • Direct payments to research participants via check or direct deposit through KUMCRI’s financials systems are not generally allowed for privacy reasons.  All transactions formerly processed by direct payment should be managed through the ClinCard system.

    Note:  Payments of any form to non-U.S. citizens may be subject to additional restrictions in accordance with IRS regulations and U.S. tax treaties.

Contact: 

Associate Vice Chancellor for Research Administration: 913-588-5436 

Approved by: 
Vice Chancellor for Research
Approved on: 
Wednesday, June 25, 2008
Effective on: 
Wednesday, July 2, 2008
Review Cycle: 
Annual (As Needed)
Definitions: 

IRS Form 1099: Informational return sent to the IRS to report various kinds of non-wage payments made to individuals. These payments are not subject to tax withholdings but are considered taxable income and required to be reported to the IRS.

Non-cash research subject incentive: Cash-equivalent payment, such as a gift card or savings bond, for participation in a research study.

Research Subject Incentive: Check, cash, or non-cash compensation for participation in a research study. 

Keywords: 
Research, Subject, Patient, Incentives, Reimbursement
Review, Approval & Change History: 

2017 04 11: Major Revision

2015 10 26: Revised contacts

 

Research and Sponsored Projects Category: 
Research and Sponsored Projects

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