The University of Nebraska-Lincoln (UNL) often conducts research studies that involve the use of human participants. The suitability of any payment to a research participant in a human subject research protocol will be determined by UNL’s Institutional Review Board (IRB) , and the related protocol must be approved or determined to be exempt by the IRB before the study is conducted.
Human subject payments include gift cards, cash, checks, and other forms of payment given to participants in research that are consistent with the approved IRB protocol. These are incentive payments to encourage individuals to participate in a research study and provide private data/information through intervention or interaction. This includes participation in surveys, interviews, and other forms of data and/or biospecimen collection. These payments/incentives must be directly related to research activities and the budget justifications should include a correlation between the payment and the research activity.
The following outlines the use of gift cards, cash, or checks as payment mechanisms and advises when the gathering of research participant tax information is required.
Participants should not receive their compensation until they have completed the research, or portions of the research, as applicable, and/or as approved by the IRB. The distribution of e-gift cards must follow the timing, process, or payment scheme as approved, including bonus payments, research milestones, or compilation of research payments over time. If a subject voluntarily withdraws or is removed from the study based on PI review as it relates to, for example, risk to or eligibility of the subject, the PI must decide what is appropriate for payment based on the approved research study or consultation with the IRB. Additional information about research incentives, distribution, milestones, bonuses or other payment procedures can be accessed in UNL Human Research Protection Program Policy #3.015, “Research Participant Payment and Incentives.”
The University must report incentive payments to the IRS that total more than $600 to an individual in one calendar year. The payments will be reported on Form 1099-MISC, Miscellaneous Income. Incentive payments in any amount are taxable income and should be reported by the recipient on his/her individual income tax return. Individuals receiving incentive payments are advised to consult their personal tax advisor regarding the tax treatment of these payments. Please note social security numbers are only required to be collected for individual payments over $100.00. Participants will be asked to complete the appropriate Accounting Compensation Form. Please refer to the Compensation/Incentives and Accounting Guidance for more information regarding collection and storage of social security numbers and the Accounting Compensation Forms to be completed by research participants.
Calendar Year End Process:
At At the end of each calendar year, Accounting will subtotal payments over $100 by participant. Any individual receiving total annual payment exceeding $600 will be issued a 1099-MISC form. The compensation forms for participants earning less than $600 annually are shredded no later than January 10th.
The department is responsible for providing oversight for the implementation of these procedures. The administrative personnel identified by the department to provide oversight has the responsibility to assure the related activity, reconciliations and the overall processes are legitimate, appropriate and in accordance with University and regulatory guidelines. The departmental business office should perform an annual internal review of each project to ensure the following:
- Ensure that all orders have received the PI’s approval.
- Ensure a monthly audit has been performed for e-gift cards, physical gift cards and cash, with any noted anomalies reported.
- Ensure that all cash and physical gift cards are being kept in a secure, locked location with limited access.
- Ensure that any physical gift cards or cash remaining at the end of a sponsored project are returned. Gift cards can be returned to Jessica Cronin in the Office of Research & Economic Development. Cash is to be returned to the Bursar.
- Ensure compliance with the University’s records retention and Social Security Number policies and procedures
- Annual reviews must be signed off on by the business or finance manager of the college or unit.
Payments to research participants can be processed using these methods:
Virtual Gift Cards
Virtual Incentives (VI) is a digital rewards platform for compensating research participants for IRB approved research projects. PI’s are able to manage their own VI account, allowing for swift payment processing and a customizable compensation experience. With VI, participants are now allowed to receive Visa eGift Cards, with no additional processing fees. Or, if you have a different brand you are looking for, there are 195 different options to choose from.
Each IRB approved project will be set up with its own program.
Types of programs available:
- Virtual Visa
- E-gift card that can be used anywhere that accepts Visa cards
- GiftCard PASS
- This option allows recipients to choose from brands you have included in the pass (ex: each recipient selects either Starbucks, Amazon or Target).
- Can choose from over 195 brands
- This option allows you to choose and send a specific Brand to recipients in a program (ex: everyone receives an Amazon.com eGiftcard)
To get started, submit your completed template letter for Virtual Incentives, along with a copy of your current IRB approval letter, to firstname.lastname@example.org. A program will be set up in VI Now for your study’s specific needs and training for use of the platform will be provided.
Physical Gift Cards*
Physical gift cards can be purchased from Amazon, Target or Walmart. Orders are placed to last approximately three months and quantities are not to exceed $5,000 without prior written approval.
*We will be primarily transitioning to Virtual Incentives by end of FY22.
If planning to compensate your research participants using cash payments, these funds will need to be requested from the Bursar’s office. You should only request enough funds to be used within three months and should plan on a one week lead time for the Bursar to secure your funds. Send a completed On-Campus Requisition form and a copy of your current IRB approval letter to email@example.com.
Please use a participant payment log similar to this to track your incoming and outgoing cash.
Checks, which are called warrants by the State, are used to make payments to one or more payees to whom the University is required to furnish a check, where no services or goods have been provided by the payee and the payment is of non-taxable nature to the payee.
To request checks made payable to human subjects:
- Complete a Warrant Request Form
- Include IRB project number and “Research Participant Payment” in Explanation box
- If payment is over $100, a SSN for the participant is required
- Send the completed form to Accounting at firstname.lastname@example.org